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Managing Social Networking

Records

Records

Jerry Kirkpatrick

Records Management Specialist

(Retention Schedules Imaging Requests Training)

(Retention Schedules, Imaging Requests, Training)

Records Management Division

Arizona State Library, Archives and Public Records

A Division of the Arizona Secretary of State

(2)

Objectives

Objectives

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Introduction

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What is Web 2.0 / Social Networking

ƒ

Review of Records Management Statutes

ƒ

Records Retention Schedule for SocNet Records

ƒ

Guidance on SocNet from RM Standpoint

Training on SocNet

ƒ

Training on SocNet

(3)
(4)

What Web 2.0 Looks Like

Application

Description

Examples

Blogs

Web log

Communication

Blogs

Web-log

Communication

Public

comment

Wiki

Interactive

webpage

Project

management

Review

Review

documentation

Social

Web based

Reach a wide

Social

Networking

Web based

community

Reach a wide

audience

Networking

Collaborative

Shared editing

SharePoint

Collaborative

Editing

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Web 2 0 - Connected

Web 2.0 - Connected

(7)

Why Do We Even Need This Topic?

How well do your people understand electronic records?

1

10

1 – know nothing

5 – somewhat capable

10 – completely competent

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(9)

“Records” — As Defined By Statute

Records — As Defined By Statute

A.R.S. § 41-1350

“records” means all books papers maps

... records means all books, papers, maps,

photographs or other documentary materials,

regardless of physical form or

characteristics

made or received by

characteristics

. . . made or received by

any governmental agency in pursuance of

law or in connection with the transaction of

public business and preserved or appropriate

public business and preserved or appropriate

for preservation by the agency or its

legitimate successor as evidence of the

organization functions policies decisions

organization, functions, policies, decisions,

procedures, operations or other activities

of the government, or because of the

informational and historical value contained

informational and historical value contained

(10)

YES

Recorded Information

Are you or your organization the creator of the record? Did you generate or receive the i f ti t f t h i l/ d i i t ti k i d ti b i ?

YES

YES information to use for your technical/administrative work in conducting agency business?

Does it contain informational value as evidence of your organization’s functions, policies, decisions, procedures, operations, mission, programs, projects, or activities? RECORD NO RECORD NO YES YES RECORD RECORD

Is it material that originated in another office or outside your agency, but you commented or took action on the material?

Does it document business actions, such as: what happened, what was decided, what advice was given, who was involved, when it happened, the order of events and decisions?

NO

YES

Is it a draft or interim document that has not been circulated to others or does not contain substantive comments and for which there is a final version being maintained? RECORD

YES decisions?

NO

NO

Is it an original document related to agency business that does not exist elsewhere?

RECORD

Is it published or processed information that you received and use as reference? YES

Is it a copy of a document or correspondence kept only for convenience of reference

on which no action is taken? YES

NO NO

RECORD

RECORD

on which no action is taken?

NO

YES Is it information accumulated and maintained at the workplace,

but which does not affect or reflect the transaction of your program business?

Is it junk mail or documentation that has no work-related informational or evidentiary

NO

YES

RECORD

RECORD

Courtesy of Anna W. Nusbaum, CRM Sandia National Laboratories

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value?

When in doubt, treat it as a record.

(11)

Records Management

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Establish and maintain an active continuing program

Establish and maintain an active, continuing program

for the economical and efficient management of

the public records of the agency.

ARS 41-1346(A)(1)

Records Management means the creation and

eco ds

a age e t

ea s t e c eat o a d

implementation of systematic controls for records and

information activities from the point where they are

created or received through final disposition or

created or received through final disposition or

archival retention, including distribution, use,

storage, retrieval, protection and preservation.

(12)

Ownership of Records

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All

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All records made or received by public

officials or employees of this state in

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the course of their public duties are

the property of the state.

ARS 41-1347(A)

(13)

What is a Public Body?

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ƒ

The state, any county, city, town, school

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district, or political subdivision

ƒ

Any branch, department, board, bureau,

commission co ncil or committee of the

commission, council or committee of the

foregoing

ƒ

Any public organization or agency

ƒ

Any public organization or agency

supported in whole or in part by monies

from the state or a political subdivision

from the state or a political subdivision

of the state

(14)

Accountabilityy

All officers and public bodies shall

maintain all records

reasonably

maintain all records … reasonably

necessary or appropriate to

maintain an accurate knowledge of

maintain an accurate knowledge of

their official activities and of any

of their activities which are

of their activities which are

supported by monies from the

state of any political subdivision of

state of any political subdivision of

the state.

ARS 39-121.01(B)

(15)

Accountability continued

y

Make and maintain records containing

adeq ate and proper doc mentation

adequate and proper documentation

of the organization, functions,

policies decisions procedures and

policies, decisions, procedures and

essential transactions of the agency

designed to furnish information to

designed to furnish information to

protect the rights of the state and of

persons directly affected by the

persons directly affected by the

(16)

Arizona Electronic Transactions Act

z

A.R.S.§ 44-7041. Creation; retention; conversion of written records

A. Each governmental agency shall determine if, and the extent to

which,the governmental agency will create and retain electronic records

and convert written records to electronic records.

Any governmental

agency that is subject to the management preservation determination of

agency that is subject to the management, preservation, determination of

value and disposition of records requirements prescribed in sections

41-1345, 41-1345.01 and 41-1346 through 41-1351 and the permanent

public records requirements prescribed in section 39-101 shall comply with

those requirements.

B. State agencies shall comply with the standards adopted by the

Government Information Technology Agency pursuant to Title 41, Chapter

Government Information Technology Agency pursuant to Title 41, Chapter

32.

C. All governmental agencies shall comply with the policies that are

bli h d b h S

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established by the Secretary of State pursuant to section 41-132 and that

apply to the use of electronic signatures.

(17)

Records Retention

Records Retention

and Disposition

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(18)

Purpose of a Retention Schedule . . .

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Describe the record series

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State how long each record

series needs to be kept

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Instructions for cutoff,

retirement and final

disposition

(19)
(20)
(21)
(22)
(23)
(24)
(25)

Definition of Historical Record

General Retention Schedules

Any record series listed as permanent on a general retention

schedule should be transferred to the State Archives when

schedule should be transferred to the State Archives when

the agency or political subdivision no longer wishes to

maintain those records. You can reach the State Archives at

602-926-3720 or 800-228-4710 to discuss the transfer of the

records

records.

If a record is historically significant, it is a permanent

record. Records are deemed historically significant when

they:

they:

ƒ Document a controversial issue

ƒ Document a program, project, event or issue that results

in a significant change that affects the local community,

i

city, county or state

ƒ Document a program, project, event or issue that involves

prominent people, places or events

ƒ Document a program, project, event or issue that resulted

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,

in media attention locally, statewide or nationally

(26)
(27)
(28)

Social Networking Guidance

g

1. For the Record

ƒ

For public bodies, any information created for, or received from

Social Networking / Web 2.0 applications will probably be a record.

Social Networking / Web 2.0 applications will probably be a record.

ƒ

If the information / data meets the requirements of the definition of

a “record” in Arizona Revised Statutes (A.R.S.) §41-1350, then you

will need to retain such information.

ƒ

Any Social Networking (SocNet) records will need to be managed in a

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way that complies with all of the Records Management requirements

found in State Statutes. (See A.R.S. §39-101, §41-1330-55)

2. SocNet is No PicNic

ƒ

The Statutory requirements regarding Records Management of

public records are never easy, and that is especially so for these

records.

ƒ

You need to be prepared for these challenges, and aware of the

difficulties you will face in complying with these requirements

difficulties you will face in complying with these requirements

regarding SocNet records.

ƒ

It is our hope that you will be able to think about these issues before

you decide the extent of your involvement in SocNet / Web 2.0 – and

take the necessary steps to ensure successful management of these

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records.

ƒ

Remember, e-mail has been around for over 15 years and we are all

still trying to properly managing e-mail records.

(29)

Social Networking Guidance

g

3. It’s the Content (and Intent), Stupid

ƒ

The transitory nature of most SocNet communication does not mean that any

records created or received while using these tools will be transitory.

ƒ

It is the content and the intent of the communication that determines

whether these communications will qualify as records, and the specific

retention period required for such records.

ƒ

In the case of comments / postings / feedback, most of this will be unique

and will need to be retained per specific records series / retention periods

4. For Once, Try NOT to be Original

ƒ

Copies / duplicates of information already existing and being managed

elsewhere by an Agency are NOT public records.

ƒ

You will want to set up guidelines for what topics / subjects / information can

ƒ

You will want to set up guidelines for what topics / subjects / information can

be blogged, posted or networked.

ƒ

Try to avoid asking for public comment on policies, procedures or topics

coming up for possible consideration at future Board / Council meetings.

This may make such communications, “Executive Correspondence” and these

types of records are Permanent – requiring retention on paper or microfilm

types of records are Permanent – requiring retention on paper or microfilm.

ƒ

As much as possible, ask employees to use information / data / records that

already exist elsewhere in your Agency. It is much easier to manage

information on your own website(s) than it is to manage pages on Facebook,

or any other SocNet site.

ƒ

Keeping original unique information under your direct control and posting

ƒ

Keeping original, unique information under your direct control and posting

only duplicate information to SocNet sites places you in a better position to

manage your electronic records and content.

(30)

Social Networking Guidance

g

5. King of the Content

ƒ Who controls the content of these SocNet records? In most cases, the SocNet website will have full control over the content of everything posted to their sites.

ƒ And, they will usually control the retention of the records, therefore controlling the

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entire Records Management process. It is difficult to manage what you have no control over.

ƒ Most SocNet sites have little to no Records Management capabilities since they view this type of communication as transitory. But remember, just because SocNet

information may be viewed as temporary and casual does not mean its records are transitory; it’s all about the content

transitory; it s all about the content.

ƒ As public bodies, you will need to “manage” these records, as you would any other records.

ƒ The State of Arizona has approached some of the larger players in the SocNet world, and is working with these sites to incorporate controls and features needed by public bodies that have not been previously designed into these sites.

by public bodies that have not been previously designed into these sites.

ƒ Most of the capabilities being discussed have been developed by first making these sites aware of statutory requirements for records management, security, and so on. One pending enhancement is the ability to “certify” a page as being a true “State of Arizona” Agency or Officer page.

6. If you Can’t, Should You?

ƒ The Statutes require public bodies to “efficiently and effectively” manage their records.

ƒ For instance, if you are not prepared to manage messages posted to your page, then you should consider turning off the capability of allowing others to leave wall

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(31)

Social Networking Guidance

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7. E-mail Comments and Postings

ƒ

Comments, wall postings, etc received by Users, Friends, Fans (and

others) of your SocNet site will probably be unique records.

)

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ƒ

As such, you will need to capture and retain them accordingly.

ƒ

Comments posted to some sites can be forwarded as an e-mail, which

increases your ability to better manage these unique records.

ƒ

Consider forwarding these e-mails to an Agency account, similar to those

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used to capture public comments made on your government websites.

8. Notify and Involve Information Technology (IT)

ƒ

Most Records Managers will need to partner with their Information

Technology colleagues if they want to truly manage the great potential

Technology colleagues if they want to truly manage the great potential

and challenges posed by SocNet.

ƒ

Make sure your IT professionals are able to track the use of these

technologies as they do e-mail and other e-communications.

ƒ

Involve them by asking how you can capture, retain and manage these

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records.

ƒ

Any electronic communication requires a concerted, coordinated effort

on behalf of your Records Management and IT personnel.

ƒ

There may already be an I.T. policy governing use of the internet and

related tools and sites but you can make sure Records Management

related tools and sites, but you can make sure Records Management

concerns are fully addressed in these policies.

(32)

Social Networking Guidance

g

9. No Policy, No Service

ƒ

Have a policy on SocNet (along with other e-communications) and focus on

Records Management responsibilities and requirements.

ƒ

Public bodies need to know what their employees are using SocNet for, and

what information is being created and / or received. This can best be done

upfront, by defining the parameters of SocNet activity.

ƒ

Make sure your policy sets the party / parties responsible for capturing,

retaining and managing these SocNet records, or you will ensure that no one

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is responsible.

ƒ

If you don’t want to totally reinvent the wheel, you can review over 100 Social

Networking usage and / or governance policies at the following links:

ƒ

Social Media Policies Database of Over 110 Organizations

http://www socialmediatoday com/SMC/155843

http://www.socialmediatoday.com/SMC/155843

10. The Matrix

ƒ

An essential outgrowth of either the I.T or Records Management policy for

Electronic Communications and SocNet will be the matrix.

ƒ

You will need to create and maintain a matrix of your Agencies / Divisions /

Employees use of Web 2.0 technology, best broken down by application.

ƒ

This matrix should include the specific technology involved, Departments

involved, web address / location of each, and the opportunities / potential for

each.

ƒ

See an example of the excellent Federal government matrix at the following

US.gov link:

(33)

Social Networking Guidance

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11. Use the Terms

ƒ

What do you do if someone in the public posts a message to your SocNet

site that is offensive or obscene? Do you immediately remove the post

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and delete the record? Do you allow the post to remain on your wall?

Do you remove the post but retain it at a secure portion of your site?

ƒ

Remember that posts to a government SocNet site are probably going to

meet the statutory definition of a record, and must be managed

accordingly.

accordingly.

ƒ

Consider incorporating the Terms of Use established by the venue for

your SocNet activities into your Policy. These Terms of Use already

define ones participation in SocNet, so why not reflect them in your

policy?

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In most cases, these Terms of Use will address issues such as profanity,

intellectual property and / or copyright infringement, and other difficult

issues.

12. Train, Train, Train

12. Train, Train, Train

ƒ

You can never train too much on the Records Management aspects of

SocNet and other forms of electronic communication.

ƒ

Training is an important aspect of any compliance program, and is a

sure line of defense for any public body.

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Remember the four pillars of an effective Records Management Program

– Retention Schedules, RM Policies, Training and Documentation.

(34)

Social Networking Training

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1. Annual Training

ƒ

Users are almost always the weakest link in an information system

Users are almost always the weakest link in an information system,

and may inadvertently divulge sensitive information through a social

network.

ƒ

Few effective technical security controls exist that can defend

against clever social engineering attacks.

ƒ

Often the best solution is to provide periodic awareness and training

of policy, guidance, and best practices. The proper use of social

media in the Federal Government should be part of annual security

awareness training.

2. What to (Not) Share

ƒ

Provide specialized training to educate users about what information

to share, with whom they can share it, and what not to share.

ƒ

For an example of establishing departmental policy on what to share

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on social media websites, see U.S. Air Force New Media Guide.

3. Policy & Guidelines

ƒ

Provide guidance and training based on updated agency social

media policies and guidelines including an updated Acceptable Use

media policies and guidelines, including an updated Acceptable Use

Policy (AUP) specific to social media websites.

(35)

Social Networking Training

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4. Where’s the Line?

ƒ

Employees be mindful of blurring their personal and professional

Employees be mindful of blurring their personal and professional

lives.

ƒ

Don’t establish relationships with working groups or affiliations that

may reveal sensitive information about job responsibilities.

5 Att k Ri k

5. Attack Risks

ƒ

Educate users about the risks of information disclosure when using

social media, and make them aware of various attack mechanisms.

6 Who Are You?

6. Who Are You?

ƒ

Provide employees guidance concerning if and how they should

identify themselves on social media websites, depending on their

official role.

7 T ll M M

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7. Tell Me More About Yourself

ƒ

Provide specialized awareness and training on privacy requirements

and restrictions.

ƒ

Educate users about social networking privacy controls to help them

take control of their own privacy both in their personal profile and

take control of their own privacy, both in their personal profile and

any profile they use for work-related activities.

(36)

Social Networking Training

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8. What’s The Harm?

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Educate users about specific social media

threats before they are granted access to social

media websites.

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Users may be desensitized to openly granting

unnecessary access to their private information.

ƒ

For example, users may click “OK” without

reading the full message and understanding the

reading the full message and understanding the

permissions they are granting.”

The following is an excerpt from the September 2009, Federal

CIO Council publication, Guidelines for Secure Use of Social

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Media by Federal Departments and Agencies

(37)

Social Networking Policy Points

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1. Employee Access

ƒ

Lines have blurred lately as personal, professional and official agency

use of social media tools has become common, raising questions about

whether employees should have access to social media sites and the

whether employees should have access to social media sites and the

proper means for gaining access.

ƒ

Agencies are managing access in two ways:

ƒ controlling the number and type of employees allowed access to

social media sites or

ƒ limiting the types of sites that are approved for employee access.

2. Account Management

ƒ

This entails the creation, maintenance and potential destruction of social

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media accounts.

ƒ

Lacking a policy for this could result in a situation where an agency's

leadership is in the dark about what types of accounts are being

established, maintained or closed by their employees for professional or

official agency use

official agency use.

3. Acceptable Use

ƒ

Such policies outline an organization's position on how employees are

expected to use, restrictions on personal use and consequences of

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violating the policy.

ƒ

This is perhaps one of the more disquieting, gray areas of social media

policy, as it's difficult to make clear-cut distinctions between

(38)

Social Networking Policy Points

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4. Employee Conduct

ƒ Address what is "right" and "wrong" as far as employees' behavior, and sets out consequences should a violation occur. q

ƒ In addition to standard conduct codes like racially offensive language, address issues more specific to social media, including respecting the rules of the venue, striving for transparency and openness in interactions, and being respectful in all online interactions.

5 Content 5. Content

ƒ Issues of who is allowed to post content on official agency social media sites and who is responsible for its accuracy.

ƒ In many cases, content creation is given to the department or person who created the account, with the agency's public information officer being responsible for ensuring the accuracy of posted information and adherence to existing social ensuring the accuracy of posted information and adherence to existing social media guidelines.

ƒ More and more, professionals are engaging in work-related group discussions on sites like GovLoop and LinkedIn, and leaving online comments in response to work-related topics on external blogs, another concern for agencies.

6. Legal Issues

ƒ General approach to legal issues -- using generic text that requires all employees to adhere to applicable laws and regulations without specifying which are applicable

ƒ specific areas of law like privacy, freedom of speech, freedom of information, public records management, public disclosure and accessibility.

ƒ Some agencies' policies proactively address potential legal issues by requiring using various disclaimers on social media sites

(39)

Social Networking Policy Points

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7. Security

ƒ Agencies are trying to develop best practices to ensure security of their data and technical infrastructure in light of new uses, users and technologies

ƒ Two specific concerns:Two specific concerns:

ƒ Technology concerns focused on password security, functionality,

authentication of identity using public key infrastructures and virus scans. ƒ May inadvertently post information about themselves or the agency on social

media sites, which attackers then use to manipulate users. A related concern is the inadvertent posting of citizens' personal and protected information by p g p p y

agency employees.

8. Citizen Conduct

ƒ Grappling with instant two-way public communication between government and citizens is relatively new,

ƒ Policies vary on how to deal with the content of such comments.

ƒ Rules of conduct that are posted on the agency's site. These rules generally refer to limitation on offensive language, inciting violence or promoting illegal activity.

ƒ Rules detail who will have the responsibility of approving public comments ith t i i t d t il t h t k t t bl

without going into detail as to what makes a comment acceptable.

The following is an excerpt from, 8 Essential Elements for an Effective

Government Social Networking Policy, by Karen Wilkinson, staff writer for Government Social Networking Policy, by Karen Wilkinson, staff writer for

References

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