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Appendix “I”

Records and Information Management Review

Findings, Recommendations & Strategic Plan Report

Prepared by:

February 10, 2014

The Information Professionals

CES-11-2014-1 - Appendix "I"

Table of Contents Executive Summary ............................................................................................................ 1

Project Overview and Methodology ...................................................................................... 3

RIM Program Values ........................................................................................................... 4

Findings and Recommendations .......................................................................................... 4

1. Vision /Accountability / Staffing .................................................................................... 4

2. Policies & Procedures ................................................................................................... 7

3. Record Content Identification ....................................................................................... 9

4. Capture, Access & Use ................................................................................................11

5. Storage & Disposition .................................................................................................15

6. User Engagement: Training & Communication .............................................................17

7. Protection & Security ..................................................................................................19

Vital Records Protection and Business Continuity .................................................................................. 21

8. Technology Use ..........................................................................................................24

9. Monitoring: Compliance & Quality ...............................................................................27

Information Governance Maturity .......................................................................................28

Strategic Plan ...................................................................................................................32

Overview ................................................................................................................................................. 32

RIM Program Policy Development .......................................................................................................... 32

Classification Scheme and Retention Schedule ...................................................................................... 32

Destruction and Hold Policy & Data Asset Inventory ............................................................................. 33

Implementation Training ........................................................................................................................ 33

Electronic Document & Records Management System (EDRMS) ........................................................... 34

Records Manager Job Description .......................................................................................................... 34

Appendix A - Project plan & Timeline

The Information Professionals

Records & Information Management Review - Findings, Recommendations & Strategic Plan Report

EXECUTIVE SUMMARY

This report covers a project that was undertaken to: • Determine the current state of information management within the District Municipality of

Muskoka; • Develop recommendations for building on strengths and rectifying deficiencies; and • Develop a strategic plan for implementing the recommendations over the next three years

taking into account other District initiatives and budgetary constraints. The project was conducted between September 3, 2013 and February 7, 2014. During that period the consultants conducted interviews with every department to determine the current state of their information management practices and any issues they had with accessing information on both physical and electronic media. A committee of Administrative Support staff was also formed by the District Clerk to work on developing a standard file classification structure that would be based on a functional, corporate basis rather than using departmental schemes. The consultants provided several rounds of review and feedback on the classification scheme as it was being compiled. The report contains findings covering all aspects of information management within the District. It also makes 36 distinct recommendations for improvement covering all components of a comprehensive, effective and efficient Records and Information Management (RIM) program. The major findings are:

• There is no corporate policy which defines the purpose, objectives, scope, authorities and responsibilities of RIM within the District.

• The lack of a corporate classification scheme has greatly hindered the flow of information within and between departments. This has resulted in significant duplication of information and an inability to access information when the person who created the paper or electronic file structure is not present.

• The retention By-law is outdated and does not reflect current legislative, audit and operational requirements. Staff realize that it is inadequate so they tend to keep everything forever.

• The District can benefit greatly from the implementation of software that manages records on all media in accordance with District policies.

• The personnel resources allocated to managing information are not sufficient to develop and maintain a RIM program that will meet the District's needs.

The major recommendations are:

• Establish corporate responsibility for the RIM program with the Clerk’s office as part of an "umbrella" policy for the RIM program.

• Continue the development of the corporate classification structure using the modified TOMRMS structure.

• Use the corporate classification scheme for all physical and electronic records, including shared drives and Outlook folders.

• Update the District retention By-law to reflect current legislative and operational requirements and apply it to current physical and electronic record holdings.

• Create and deliver a series of training sessions for all staff on the principles of RIM, the District policy, classification scheme and retention By-law and how to implement them within their work areas.

The Information Professionals Page 1


• Proceed as soon as possible with the development of system requirements for a comprehensive Electronic Document and Records Management System (EDRMS).

• Create a new position within District Clerk's department with responsibility for the District's RIM program.

The Strategic Plan presented at the end of this report has been informed by the realities of other priorities and the limitations of staff and financial resources necessary to develop, implement and maintain the RIM program. It's phases are:

• 2014 o Prepare and approve a corporate RIM policy; o Complete the classification scheme and retention By-law development and obtain

necessary approvals; o Provide training for all personnel on the use of the classification scheme and retention

By-law; o Using the approved retention By-law to purge outdated and duplicate records; and o Apply the classification scheme to the remaining records;

• 2015 o Develop a set of system requirements and features for Records Management software

and procure the application which best meets the requirements and budget limitations; o Develop a job description for a District Records Manager and recruit a suitable

candidate; and o Investigate the suitability of enhancing the RM software to include the functionality of

an Electronic Document and Records Management System.

A detailed project plan and timeline is attached as Appendix A.

It is very obvious that there is a need to improve the way in which information is managed and used within the District. There is also a very strong desire among the vast majority of staff to effect the changes necessary. There is an acceptance that this type of change will not be without some angst but that the advantages will far outweigh the temporary disturbance. We are certain that, as long as there is visible and demonstrable support from senior management for this program it will succeed in achieving proper information governance and will greatly enhance the accessibility and usability of the District's information resources.



PROJECT OVERVIEW AND METHODOLOGY

This report has been compiled from the information gathered during 15 interviews conducted at The District Municipality of Muskoka from September 9th to 16th, 2013. The interviews focused on the current policies, procedures and related activities within the District offices for the management and use of information. Participating personnel were asked to describe their current processes and share what they liked and disliked about the way information is currently managed and accessed within their functional area and within other District departments with which they are familiar. They were also asked what their top priority would be to improve the Records and Information Management (RIM) program. Throughout the interviews all participants were eager to inform the consultants of their RIM program perceptions and appeared to be very open about the current situation. There was also a unanimous desire to effect significant improvements to both the governance of information and the way in which it is accessed. This Recommendations Report has been organized in the phases of the RIM lifecycle beginning with foundational elements and ending in the retention or disposition of District records. The findings are a "statement of fact" about the current state of the District's RIM program that have been validated with the Project Team and amended where necessary. It is the second of three reports for the development of a RIM strategy. The Recommendations Report presents options for dealing with the deficiencies noted in the findings, including some timelines and estimated costs where possible. This report will form the basis for a discussion regarding program priorities and the availability of resources to address the issues over the next three years. Once the priorities and resources have been determined, a realistic and attainable strategic plan will be developed and provided for discussion.

Note to Reader

Audits of information management programs and the resulting report of findings tend to emphasize deficiencies and, therefore, can be seen as "painting a bleak picture". While the report is accurate the reader is cautioned to be mindful of the context in which the current state was attained. The Records and Information Management (RIM) program has been operating with a staff allocation that is well below any comparable Ontario municipality. Of the 25 Ontario Counties that we have as clients, The District Municipality of Muskoka is the only one that does not have at least one person assigned on a full-time basis to their RIM program. There is a difference between something being effective and being efficient. District staff are for the most part able to access required records, albeit with some difficulty and wasted time searching. What this report points out are the inefficiencies in the current processes and some deficiencies that are important in a comprehensive program. The issues noted in this report are not a result of lack of dedication or effort but more attributable to a lack of committed resources.



RIM PROGRAM VALUES

The recommendations outlined below are based on the following values: • Records Management is a program, not a project. Once established, the Program will continue to

evolve over time; • Records and information are corporate assets that must be managed at the enterprise level; • Consistency and controls are essential for the successful use of automated tools and applications; • Records should support the transparency and accountability expected by stakeholders and the

public; • Information and records must be reliable and trustworthy; • Litigation is not seen as a primary risk or information management driver; • Access to information must be maintained and improved, especially as staff changes occur and the

use of electronic information increases; and • Costs are to be managed and reduced through improved productivity and efficiencies in order to

maximize allocation of limited resources to core business operations.

FINDINGS AND RECOMMENDATIONS

1. VISION /ACCOUNTABILITY / STAFFING

Best Practice

Effective records management programs are endorsed and supported by high-level executive support. Records and information are recognized as important assets that belong to the organization and that require governance and control at an enterprise wide level. RIM staff are engaged in strategic initiatives to identify and implement clearly defined goals, objectives, policies and procedures. Responsibilities are assigned for program oversight, execution and ongoing maintenance with roles assigned to all stakeholders including senior management, RIM practitioners, and end users.

Vision

Council has allocated funds over the next two years to be used to develop and implement a comprehensive RIM program. In meetings with the consultants, SMT members have reiterated their desire to significantly improve the way in which information is managed and used within the District and have acknowledged that this will require change and a certain amount of angst for all staff members. It is our assessment that SMT's concept of what the RIM program should be is fairly limited. This is most likely because the current program is very rudimentary and decentralized and does not provide a view of what an effective program can encompass. A program that is comprehensive, effective and efficient and includes records on both paper and electronic media (including emails) is not familiar to them. In addition, new technology initiatives that include a RIM component have not typically included input from the Clerk to ensure that the requirements and functionality necessary to effectively manage the records created and received are identified and met. It was expressed that the governance aspect of the program is the responsibility of the Clerk and her staff and that the desire of most senior staff is to enhance retrievability of information when needed, regardless of where it resides. This is not to imply that SMT is not interested in governance. They



recognize and fully support the need to be compliant with legislation, guidelines and best practices. However, they see substantial benefits to be gained from increasing the reliability, authenticity, integrity and retrievability of the District's information resources. The development of the strategic plan will provide a more holistic view of the scope of the RIM program and a unified vision among District staff at all levels.

Accountability

Records and information management activities are very decentralized within the District of Muskoka. Although the Clerk has legislated responsibility for the District's records, implementation of the RIM program has taken a decentralized approach with every department "doing their own thing". This has resulted in very different types of programs and approaches to information management within and between departments. The vast majority of efforts to manage information effectively have concentrated on physical records. This responsibility has been largely delegated to the administrative support staff. There are a number of centralized departmental filing systems using movable aisle shelving. Generally access to these records requires the assistance of the Administrative Assistant(s) or support staff for the department. Over the past months there has been an initiative to take a more enterprise wide corporate approach to managing information. The initial thrust has been the development of a standard classification scheme which will be used by all departments but it has created an awareness and desire to have a comprehensive program which would standardize policies and procedures across the District offices and enable a greater degree of accountability.

Staffing

Because of the decentralized approach noted above, the tasks associated with managing the RIM program are not truly given to any one individual. While the Clerk has corporate responsibility for records, her duties as District Clerk and those of the Deputy Clerk, do not leave them with sufficient time to operate, let alone develop, an effective and comprehensive RIM program. An Administrative Support Staff user group has been formed and is working on developing an enterprise wide classification structure for the District.

Program Scope

The current program scope is, for the most part, concerned with the management of physical records. The management of electronic records has been started within some departments through attempts to create a standardized structure for shared drives but the success rate is very low. Some departments are converting physical documents to image format upon receipt but this is not a common practice. The management of emails is not standardized in any way. The variations on what is retained or deleted and how the emails are stored are as many as the number of staff members. One of the promising initiatives is the shared IT services between the District and three of the lower tiers. Although it is limited to some applications and related IT support and infrastructure it has the potential to extend the management and sharing of information between the District and all six lower tiers.



Recommendations 1. Give a one hour presentation to SMT on how Records Management and Document Management

can integrate to provide both governance and accessibility and the various levels of functionality available.

This presentation should be conducted by the consultants in order to bring their practical experience in implementing the various types of systems. The purpose of the presentation will be to expose senior staff to the range of options which should be considered, the relative merits and costs of each and the advantages to the District of adopting each type of solution. The presentation should be given as part of the Recommendations presentation to SMT.

2. Explore the possibility of extended synergies between the District and the lower tier municipalities.

The initiatives to share IT and procurement services with some of the lower tiers has demonstrated some of the synergies that can be achieved when resources are pooled to satisfy common requirements. Extending the current scope of services to include a common Electronic Document and Record Management System (EDRMS) would greatly extend the benefits attained and would make it more feasible to pursue a comprehensive software package. Establishing a common system between the District and at least some of the lower tiers would reduce the total costs for the technology infrastructure through the use of a shared server with distinct records repositories. It would also greatly facilitate the electronic exchange and sharing of common records.

There should be a working group established between the District and the lower tiers that would include those responsible for Records Management within each municipality. This would greatly facilitate the exchange of ideas and identify specific initiatives where synergies can be realized through more collaboration and/or sharing of resources. It may also be possible to share the services of the RIM Manager to at least provide oversight for their programs.

3. Establish corporate responsibility for the RIM program with the Clerk’s office as part of an "umbrella" policy for the RIM program.

It is imperative that responsibility for the RIM program is established in one position, ideally with the District Clerk as designated by legislation. The draft Retention By-law which is modelled on the City of Barrie's By-law gives the District Clerk authority to change the retention periods with the approval of the District's auditor. This is certainly a step in the right direction but there must also be a District policy which establishes the program scope, responsibility and accountability at all staff levels and which identifies key sub-policies and procedures for certain components of the program including periodic audits and updates. This "umbrella" policy can be developed internally by adapting those developed by other municipalities. It should be approved by SMT.

The policy should state: • The policy objective/purpose; • Policy objectives and principles (accountability, integrity, accessibility, retention, etc.); • Definition of terms; • The need to include all District records, regardless of their storage medium; • Related policies (sub policies and other District policies);



• Applicability; • Program requirements such as preservation of archival records, use of imaged and

electronic records and disposition; and • Roles and responsibilities at all staff levels.

Should you choose to have the consultant develop the policy the cost would be $1,000.00

4. Create a new position within District Clerk's department.

The Administrative Support Staff User Group is the first step in creating a structure for implementing and maintaining a progressive and effective RIM program. It is an excellent and critical vehicle for establishing components such as the classification scheme and the operational retention requirements. However, the Administrative Support staff have extensive departmental functions which limit the amount of time available to devote to enhancing the program. They are also focused on the needs of their immediate departments and do not have an enterprise view of records and information management needs.

If the District's RIM program is to provide a dependable level of governance and enhance the availability and usability of information it will require someone with an enterprise wide viewpoint who is dedicated to the program on a full-time basis. This person will work with the Administrative Support staff who will serve as departmental liaisons and Subject Matter Experts (SMEs).

One of the next steps in this multi-stage project is to work with Human Resources to develop a job description for a Records Manager position. It is estimated that the salary range for this position will be at least $45,000 to $60,000.

5. Ensure that records management responsibilities are included in the job descriptions for Administrative Support staff.

The Administrative Support staff within each department will play a vital role to assist in training, maintenance, compliance monitoring and recommending enhancements to the RIM program. This departmental RIM responsibility should be added to the job descriptions for the Administrative Support staff.

2. POLICIES & PROCEDURES

Best Practice

Clear, concise and complete policies and procedures that reflect current practice are essential for achieving transparency, managing legal liability and risk, defining authority and responsibility, instructing staff as to corporate expectations, and maintaining consistency within an organization. Following documented policies and procedures is important for ensuring efficiency during current operations when, for example, more than one person is involved in the completion of a process, a temporary staff person is assigned a task, or when an employee leaves a position and someone else takes over the position. In the event of litigation, proving that documented policies and procedures are followed, supports the admissibility of evidence by establishing that the information is used and relied upon in the normal and ordinary course of business. Consistent records capture, identification and



storage according to these documented policies and procedures is essential for both short and long term information retrieval, legislative compliance and risk management.

Current Situation

Policies are one of the foundational elements for any RIM program. They support and amplify the "vision" of the entire program as endorsed by senior management. The policies should state the objectives that are to be met to ensure that the program fulfills the vision. Policies change only periodically and should be approved at a very senior level. Procedures define how the policies are to be implemented and should be dynamic to reflect changes in business requirements, workflows and the tools used in managing and accessing information. The only approved "policy" for the RIM program is the 1977 retention By-law (77-20) which has been acknowledged as unreliable and out of date. The following corporate documents were developed in 2009 and 2010 but are still in draft format:

• Records Management and Classification System; • Assigning Coding and Maintaining File Indexes, Records Management & Classification System; • Managing Paper Copy Filing, Records Management & Classification System; and • Managing Electronic Departmental Filing, Records Management & Classification System.

Forms such as the Records Destruction Authorization and Certificate, the Department File Index Template, the Secondary Codes Summary and the Records Retention Authorization Form have also been developed but their use is not widespread. Processes have been put in place to encourage departments to create lists of records that are be destroyed out of the records storage room but formalized procedures and training have not been identified. IT has developed the District's Business Continuity and Resiliency Plan and has a current plan for system backups. They have also provided the Electronic Records Management Change Request Form which is used to identify and assign access levels of staff to shared drive folders. The Planning and Economic Development department has developed a draft policy and procedure for managing records within the department. It is very comprehensive and includes departmental forms and instructions on the structure to be used for electronic records storage. POA has a very detailed set of procedures that were developed and provided by the Ministry of the Attorney General. In all interviews staff expressed the desire to comply with corporate policies and procedures for managing information. They easily recognized the need for uniform corporate standards and an approach to meeting those standards. The most common sentiment expressed is "we want to comply but we need direction". Recommendations 6. Develop and approve a set of RIM policies to further define the high-level objectives, program

components and responsibility identified in the umbrella policy. Required policies include but are not be limited to policies that:

• establish the use of microfilmed, imaged and electronic records for evidentiary purposes;



• define the roles and purposes of components such as email, voice communication, instant messaging and social media;

• identify RIM as part of Human Resources training; • Identify records required for Disaster Recovery and business continuity; and • Ensure records security.

7. Develop procedures to implement the approved policies including how to:

• Classify/apply classification; • Use shared drives effectively; • Prepare records for inactive storage; • Manage the records storage facility; and • Destroy records.

Some of these procedures can be developed using the frameworks of the draft procedures mentioned above. There are many excellent sections in them that can certainly be used as a starting point in developing a single set of corporate procedures. It is also possible to leverage ones developed by other municipalities which are readily available through any of the committees that have been formed throughout the province. Procedures for using any software that is acquired will have to be developed after the acquisition of the software program.

Ideally, the proposed Records Manager would develop these procedures. Alternatively, the consultants can be engaged to develop these policies and procedures at a cost of $10,000 to $15,000.

3. RECORD CONTENT IDENTIFICATION

Best Practice

Two foundational elements in a well designed records management program are the classification and identification of retention requirements for all business records and information. Best practice requires that the content of information holdings is identified by function, and then by business activity and/or records series in a hierarchical structure. The resulting structure must be simple, with as few levels in the hierarchy as feasible to meet user access needs. Each category must be mutually exclusive and defined in scope notes to identify what is included (and in some cases, excluded) from the category. Since retention requirements are dictated by the content of a record, the retention and content category are directly linked. The structure must be consistently applied regardless of the media in which the information is stored. Collectively, the policies and procedures, classification and retention tools provide the core platform required for an enterprise wide records management program. They should be viewed as the corporate standard upon which all departmental records handling practices are based. In an enterprise wide system, deviation from these standards is not permitted. Users can not be permitted to add or modify classification categories to make the structure unique to their department. Nor can they choose to retain records for less or more time than indicated in the retention standard. Where the corporate standard does not meet user needs, a coordinated approach is taken to modify and update the standard, ensuring that all changes are reflected across the enterprise. That being said, no department



will use all categories or elements identified in these tools. In the ideal situation, each department or user group is provided with a subset of only those categories and information that they use on a day to day basis. This is often referred to as a departmental file plan.

Current Situation

The classification scheme establishes the common language/terminology and taxonomy that will be used to describe record content and enable all other program components. It is virtually impossible, or at least unmanageable, to develop retention schedules, set security permissions and access rights, identify Personal Information Banks (PIBs), identify and protect vital records and identify and preserve historical/archival records unless and until a standard classification scheme is in place and used. To use an old metaphor, how can one locate information regarding oranges if others are calling them apples? Currently there is no corporate standard for classifying paper or electronic records. In the latter part of the 1980s Arenburg Consultants developed a file classification scheme for the District but it was not adopted in all departments nor has it been updated to reflect changes in recordkeeping requirements over the past 25 years. Consequently, there are many variations of it in use, none of which are fulfilling current needs adequately. Some departments have adopted their own filing methodologies which are loosely based on The Ontario Municipal Records Management System (TOMRMS). TOMRMS is a classification structure that encompasses corporate functions and all of the functions that Municipalities are mandated to provide according to regulations. It covers recordkeeping and retention requirements for both upper and lower tiers and does require some modification to reflect the requirements of the type of municipality using it. TOMRMS is in use in more than 135 Ontario municipalities and is considered to be the de facto standard for Ontario municipal records. There is a general assumption that any files that are retained in satellite locations outside of the main District building such as the water treatment plants are organized solely according to the preferences of staff working there and that they do not conform to even the departmental standards that may be in use informally within the part of the department in the main building. There has been a concerted effort within the District to modify the base TOMRMS classification scheme to more closely reflect the District's needs. A committee of Administrative Support staff and the Clerk has been working on developing a consensus classification scheme. In many cases, the scope notes describing the type of documents included in the category have been expanded and refined to provide additional detail and to reflect the nuances of upper tier information content. Great progress has been made but there are a few inconsistencies that need to be addressed. There are several instances of a record series where the scope note indicates that "all records" pertaining to a particular project or subject are included. For example:

• D26 - Major Developments - Includes all records regarding major multi-component developments in Muskoka

• E05 - Environmental Monitoring (Water Quality) which also seems to include air quality monitoring plus a very wide range of other topics;

• W10 - Water and Sewer Administration and W12 - Waste Management Administration each of which include agreements, studies, plans, policies, etc.

• T15 - Air Transportation Services which states "All records relating to Muskoka Airport will be filed under T15-MA1". This would include invoices, policies, contracts, agreements, etc.



The desire to group case related information such as everything relating to a particular property, road, project or person was a common theme expressed in the interviews. This is very typical and is the source of a great deal of resistance to adopting a function based uniform classification scheme in which the records for the Muskoka Airport, as an example, would be split into many folders according to the type of record being used or the activity that is being conducted such as financial, legal, operational, etc. The complaint is usually that one does not want to have to go to multiple folders in many cabinets to get the complete picture on a particular topic. This is somewhat balanced against the acknowledgement that the different aspects (legal, financial, operational, etc.) of the project, property or road need to be identified separately. In a few departments this issue has been addressed by using an expansion folder that is indexed by the main identifier for the project (project number), property (Assessment Roll Number) or road (Section number) and then having sub folders inside that contain the various components. In addition to the detailed classification structure scope note document, there is an overview document that provides an overview table of the second level categories. This overview is a very good user aid for department staff to use when assigning documents to a folder or searching for information.

Recommendation

8. Continue the development of the corporate classification structure using the modified TOMRMS structure.

As noted above, the most difficult task in developing the District classification scheme will be to establish an understanding that all records must be identified by function and activity/record series. For instance, contracts are, first and foremost, a document that identify the District’s legal obligations. They must be classified within the Legal primary/Function and not departmentally (i.e. as Works or Transportation) or by subject (Air Transportation Services). The administrative support staff who attended the information session conducted on September 30th understand the need for functional rather than departmental filing but may need further training and demonstration on how this can be effectively implemented for both paper and electronic files.

4. CAPTURE, ACCESS & USE

Best Practice

In order to allow for the ability to conduct a federated search across all District record repositories, all corporate information and records must be accessible to all employees with appropriate confidentiality clearance, including those outside of the Responsible Department. To facilitate access by all current staff, and to make it possible to access records for as long as they are retained in accordance with the retention schedule, it is necessary that all information and records be identified according to the content as defined by the corporate classification structure. Access is significantly enhanced through the proper use of metadata to describe records by key index fields and/or keywords that permit case file grouping, and extend search and retrieval capabilities far beyond that of the classification structure. It is also necessary to identify all corporate repositories so that the actual locations of where records may be stored are identified. Retaining records and information in repositories such as email boxes that are accessible to only one individual is not an endorsed approach.



Current Situation

Apart from the sporadic use of either departmental filing schemes or the "Arenburg" filing system there is no standard for how information is organized. Furthermore, even where there is some use of naming conventions for files, with few exceptions, it does not extend to the electronic records. The inability to find required information outside of one's own work environment is evidenced by the amount of duplication of documents and files. This applies to both paper and electronic documents but, because most paper management is effected by the Administrative Support staff, it is much more prevalent within the shared drives. This is true within departments but it is much more evident when viewed from a corporate perspective. There are multiple copies of By-laws, agreements, plans, specifications, invoices and almost any type of document that is used by more than one person or department. In addition to the obvious effect on storage requirements for both physical and electronic documents, this situation creates an environment where there is no real ability to create a single, accurate picture of any particular event, project, property, etc. The various shared departmental drives are almost universally regarded as being very difficult to search. Some interviewees stated that they use the "CTRL>F" function to search for required documents but, given the number of documents stored in the shared drives this can take a long time. Furthermore this type of search depends on some commonality of naming conventions for files and documents. Staff stated that stepping through the shared drives hierarchically may be acceptable at the first and second levels but once it goes beyond that level the identification of files or documents is at best very time consuming because of how files and documents are named. The information environment for both physical and electronic records is very siloed. Information is stored and accessed only on an individual, departmental or team basis. These pockets of information result in an inability to identify and retrieve required information from across the corporation. The most graphic example of information existing in silos is email. Although there are exceptions, staff often use their Inbox and Sent items folders in Outlook as records repositories. Given that only the owner of the Outlook account and the System Administrators within IT can access a particular email account, the information contained within it cannot form part of the corporate information repository that is identified and accessed by others. The amount of information stored within emails is growing exponentially and the management of it is very inconsistent. This is exacerbated when a staff member moves to a new position within the District. Their Outlook account moves with them meaning that it now contains information which probably does not relate to their new function and which is also not available to the person who succeeded them in their previous position. There is no consistent method of document version control within the District. Variations include adding "Draft" and "Final" to the name of a document but it was related that often there are ones labelled "Final Draft" and "Final, Final" or other combinations. Some staff use the date of the document in the file title but this is also inconsistently applied. The effect of the lack of version control is significantly amplified when documents flow between departments. Because the convention for version control, if it exists at all, varies widely between and within departments it is almost impossible to accurately identify the most current version. This may have serious consequences for decision making and definitely increases the amount of time staff spend looking for information.



Recommendations

9. Use the corporate classification scheme for all physical and electronic records, including shared drives and Outlook folders.

Conversion of the existing physical and electronic files to the new classification scheme can be a major project that will consume a large amount of resources. The issue becomes one of which files to actually convert. Does it make sense to convert a file which will not be accessed again? But, how does one know which ones will be accessed and which ones will be dormant?

The most practical and affordable approach is to apply the classification scheme on a "date forward and as touched" basis. Using this methodology one chooses a cut-off date for the old system and thereafter all records are classified according to the District scheme. This applies to both physical and electronic records, including email folders. For electronic records the existing shared drives are made "read only". For emails, staff are instructed and trained to use only sub-folders that are based on the District classification scheme.

For the most part, legacy documents are brought forward and converted only when they are accessed/touched, thus rendering them "current". Over time the legacy system will decrease in volume and the only records remaining will be those which are dormant. There are, however, some types of records where the entire volume will be accessed at some point and/or which have a long term retention period assigned. For these types of records one can either employ temporary help (summer students, OW clients through HRDC, etc.) to assist in converting the records either at the outset or at a future point when the volume has decreased due to "as touched" conversion.

10. When any physical records are classified to the new classification scheme, use Excel to create a file list using a standard template.

Creating file lists in electronic format greatly increases not only the ability to identify and locate required information but also enables the easy identification of duplicate files. Corina Giles, Clerk at The Town of the Blue Mountains, developed a file listing template in Excel that can be used on a departmental or corporate basis (prefer departmental at this point). It can be locked to read only to ensure that there is no double editing and to restrict modifications to administrative support staff. It also has fields for keywords such as Assessment Roll Number (ARN), address and project number and it can be used to apply retention values. Perhaps most important is that the data can be exported to any commercial software. While it is certainly not at the level where the District RIM program will be, it is an excellent interim step and it employs software that is on every desktop and is familiar to most users.

11. Develop and Implement a standard file naming convention.

It came as no surprise that the most common reason cited for not being able to find information is not being able to determine how the other person actually named the file. Although the inability to decipher how another person names a file is a common occurrence in most organizations, it is not very difficult to develop a corporate standard for both physical and electronic records.

Physical files should always be "named" (labelled) according to the standard classification scheme to identify the record series. The naming of the folder (the descriptive label) requires a



consensus but in most cases it is very straightforward. The use of ARNs or municipal address, a project number or employee name is very obvious and requires only a minimum of coordination. Where records are used within many departments there must be a consensus/standard for the file name. This, like the development of the classification scheme, requires some negotiation but most people are willing to compromise as long as there is a uniform standard which is used in all departments.

The use of naming conventions for electronic files should mirror the system for the physical files and vice versa. Few things are more confusing than working with two diverse filing schemes. With electronic files, one must be careful not to include too much additional information in the file name (such as author, date, etc) which are already part of the standard structure. As will be discussed below, version control should be included where required.

Ideally, the proposed Records Manager would develop these procedures. The consultants can be engaged to develop these naming conventions at a cost of $2,000.00.

12. Develop and implement a corporate standard for applying version designation to the file naming convention.

The lack of version control for many record types is a major time waster and greatly decreases the integrity of records and staff confidence that they are referencing the most recent and accurate version of a document. While it is not required for all record types, where it is appropriate it is a major improvement to records management and accessibility. The development of a District standard should also be conducted on a consensus basis. There are many variations such as using "Draft" and "Final" in conjunction with Version 1, 2, etc. or 1.1, 1.2, etc. Until an EDRMS is obtained any system which is simple will suffice as long as it is used by all staff where required.

In conjunction with the development of the version control methodology, the need to keep versions once the document has reached final status should also be identified. Most EDRMS allow for automatically deleting all drafts, keeping all or even the last 3, 4 or 5 drafts. The standard method will need to be defined at some point.

13. Include the requirement for version control based on document type in the list of system requirements for Document/Records Management software.

14. Declare Outlook to be a records delivery system and not a records repository and implement a control procedure to force staff to move emails into the corporate document repository.

The only way to gain control of emails and to bring them into the corporate document repository is to force users to move emails that are corporate records out of Outlook and into the same repository and filing structure as all other electronic documents. Because staff has formed a habit of using Outlook as a records repository with all of the associated problems noted above, it is necessary to remove the "crutch" that Outlook provides. Implementing a policy that states that Outlook is not to be used for records storage and emails that are more than a certain number of days old (45, 60, etc.) are, by default, considered transitory and will be automatically deleted will force compliance.



It may not be possible to implement this type of policy until an EDRMS is implemented that provides for an easy mechanism for "dragging and dropping" emails from Outlook into the EDRMS repository. In the interim staff should be encouraged/forced to use the standard folder structure noted above. They can also be trained on the proper method of moving emails to shared folders using the Windows "Save As" function. While not as easy as "drag and drop" it does provide a relatively easy way to move emails to their proper storage location along with other related electronic documents.

15. Include the requirement for email integration in the list of system requirements for the EDRMS.

5. STORAGE & DISPOSITION

Best Practice Records and information must be stored in such a way as to ensure that the privacy, security and accessibility requirements are not compromised. It must also be protected from damage or loss that may result from the environment in which it is stored or the way in which it is handled. In order for the retention practice to be defendable as the normal and ordinary course of business for evidentiary purposes, records destruction must be consistently applied. All content is to be destroyed according to the schedule, regardless of the repository or media where it is stored. Ensuring that all information is destroyed can be very difficult in an electronic world where it is so easy to copy multiple people in an email distribution list and where multiple information repositories exist. Records which contain information relating to the history of the corporation must also be identified, assessed for their archival value, preserved in an appropriate environment and catalogued for access.

Current Situation

Storage

Physical records are stored throughout the main office in fixed and moveable-aisle cabinetry. In most cases, end-tab folders are used with appropriate colour coding. Where either the Arenburg or modified TOMRMS schemes are used, the classification code is displayed at the top of the folder. The cabinets are adequate for the storage of physical records but they are close to capacity and in some cases have exceeded it. Inactive records are stored in either a records storage room commonly referred to as the Archives Room in the main building, in the Public Works building on Cedar Lane and at the airport. The Payroll department has a locked cage within the Archives room for storing employee related inactive records. Anyone who has key access to the building is authorized and has access to the storage room. The shelving is well suited for the purpose and the boxes appear to be labelled properly although we did not compare the contents to the label on the outside of the box. The Archives Room is also at capacity. The amount of electronic records storage continues to grow almost exponentially. When more storage space is added it seems to reach capacity very quickly. IT expressed the view that they do not have sufficient space even for backups.



Retention Application & Destruction

Given that the retention By-law is 36 years old it is not used as a reference when determining whether or not records can be destroyed. This is somewhat of a moot point because, other than financial records which follow the CRA requirements, very few records are being destroyed. Staff stated that they are reluctant to destroy anything because they are not sure how long they are to be retained. In the departments where some destruction is taking place, index logs of what is being destroyed may be but are not always kept. Examples were given where departing staff carried out a purge of the records that they maintained and no record of what was destroyed was created. There has not been a directed deletion of any electronic records other than requests to reduce email messages when the email server reaches capacity. Records which may have archival/historical value have not been identified at a corporate level. Staff tends to keep records based only on business requirements. As mentioned previously, some departments are imaging documents as they are received or produced. In Public Works the original (source) document is retained and placed in a departmental folder which mirrors the shared drive folder structure. In other departments the source document is destroyed after imaging. The imaging of source documents followed by destruction of the source document results in reliance of the imaged record for business and evidentiary purposes. This process is allowed within the Evidence Acts across Canada but they all cite using national standards as a benchmark for the integrity and quality of the imaging program. The Canadian General Standards Board (CGSB) identifies the imaging standard in CAN/CGSB-72.11-93 Microfilm and Electronic Records as Documentary Evidence. This standard, along with its "sister" standard for electronic records (CAN/CGSB-72.34-2005 Electronic Records as Documentary Evidence), define program objectives for all aspects of the imaging program (completeness of capture, accuracy, authorization, maintenance, audit trails, supervisory and disposal). They are not prescriptive but rather they define what is to be achieved and leave the determination of how that is to be accomplished to the actual user. The methods will vary greatly depending on the tools used. One of the major requirements of both standards is to have a corporate policy which specifically approves the use of the type of media (microfilm, image or electronic) for evidentiary purposes. In the case of imaged records, the destruction of the source must also be authorized but only after the quality of the images and indexing have been assured. There is no such policy for the District and it is almost certain that the objectives of the standards are not known to users nor are they being met.

Recommendations

16. You have already contracted with us for the development of a retention schedule tied directly to the approved classification scheme. When the corresponding By-law is approved and the procedure is defined:

• Identify archival selection criteria for the District. The TOMRMS classification structure identifies categories that may be of potential archival interest.

• Review records for their historical value as defined in the retention schedule and set them aside for evaluation by an archivist or historian;

• Apply the retention periods to records in the Archives/Inactive Records Room. This will create space to accommodate records from the active office areas;



• Purge physical records in the active office areas. Destroy any that are beyond their retention date or are copies of originals held elsewhere and have not been designated as archival. Move those which are inactive to the Archives/Inactive Records Room.

17. Ensure that all confidential and/or personal records stored in the Inactive Records room are secured

against unauthorized access.

18. Create a new share drive structure using the District classification scheme and instruct all users to save new documents or move existing documents that will be required to the new shared drive.

19. Modify the existing shared drives to "read only" to prevent new documents from being stored there. Records which are accessed from them will be moved to the new shared drives rather than being resaved to the previous drives.

20. Remove duplicates from the existing shared drives by using a software program such as Duplicate File Finder.

Initially this will be used to identify exact duplicates. Once the initial purge has been completed the parameters for matching can be expanded slightly to identify probable duplicates which can also be removed.

21. Have the Administrative Support staff review the remaining folders to identify files that can easily be matched to the District classification scheme and which then can be deleted in accordance with the retention By-law.

22. Obtain the CGSB imaging standard noted above and use it to audit the current imaging activities to determine what procedural changes are required to ensure compliance.

23. Obtain the CGSB standard for electronic records and use it to audit system features and IT procedures to ensure compliance.

6. USER ENGAGEMENT: TRAINING & COMMUNICATION

Best Practice

Training and guidance must be provided to support staff in capturing and maintaining their records and information. This includes requirements for all aspects of records and information lifecycle management including capture, identification, classification, protection, organization, storage and destruction. Simply providing staff access to corporate policies and procedures is not sufficient for ensuring that the recordkeeping expectations have been reviewed, understood and applied. Frequent and regular communication is required to support and reinforce the expectations of the organization. It is especially important that this training and communication begins as soon as new staff are hired. This applies to all new employees who have a role in the record and information creation or use including full, part time and temporary staff.

Current Situation

The District does not have a formalized process for briefing new staff on what they need to know about managing information when starting their employment at the District. Each department is responsible for training their staff on expectations regarding recordkeeping. Managers or the Administrative Support staff will sometimes train departmental staff on the current filing approach but this training is



inconsistent, even within a department. Within the Administrative Assistant group, there are inconsistencies in the understanding of and approach to how documents and records should be identified and how the functional classification needs to evolve. The general consensus of the staff interviewed is that recordkeeping training is desperately needed but that very little is provided. In most cases, departmental staff rely on their Administrative Support staff to file and retrieve documents because they have not been trained to understand and use the system. The only exception to the lack of training is in the Provincial Offences Administration area. The current staff were provided with extensive training, manuals and job shadowing during orientation when the responsibility was transitioned by the Province to the District. Although ongoing training is not provided, the Ministry of Attorney General continues to distribute directives to update requirements, with eight directives having been received this summer. The Municipal Court Managers Association offers advice, training and suggestions on various court practices at its regular workshops.

Recommendation

24. Create and deliver a series of training sessions for all staff.

With the increasing use of electronic records as the media of choice by all staff, it is necessary to ensure that all departmental staff including those working in remote locations, and not just the Administrative Support staff, are able to consistently name, classify, save and retrieve documents. A training program must be developed and provided for all staff to inform them and help them to apply the new policies and procedures. This training is best provided in stages as each phase of the Records Management program is put in place. Initial user training should include:

• An overview of the RIM program and why user participation is essential; • How to understand and use the classification structure for saving and retrieving

documents; • How to use the naming convention to consistently name electronic and paper files; • Etiquette and proper usage of email; • Etiquette and proper usage of the shared drives; and • Required steps and process for transitioning to the Classification Structure format in the

shared drives.

Ongoing user training and communication will be required to ensure that staff is kept current on any changes to the RIM program. This can be through a combination of formal training sessions, communiqués relating to program updates sent by the Records Manager, and informal instruction/staff briefings provided by the Administrative Assistants/Record Liaisons in each department. Ongoing training will include:

• Periodic updates on changes to the classification structure or revised policies and procedures; and

• Extensive training on the use of the EDRMS software once it has been installed.

Ideally, the proposed Records Manager would develop the training material. Alternatively, the consultants can be engaged to develop the training material at a cost of $4,000 to $5,000.



25. Provide more in-depth training for Administrative Support staff in each department.

Although all staff at the District have records management responsibilities, their perspective is one of being end-users of the information. The Administrative Support staff have a more in-depth involvement in the management of departmental records and will provide support for the RIM program for their departmental staff. In addition to the general user training, more advanced training will be required to develop this knowledge base. Advanced training for the Administrative Support staff should include: • How to monitor the shared drive to ensure consistency and accuracy in file classification and

naming; • How to apply the retention By-law periods to physical and electronic records (part of this

project); • How to effectively use the inactive records storage room; • How to support users in the use of RIM software, once it has been installed.

Ideally, the proposed Records Manager would develop the training material. The consultants can be engaged to develop the training material not related to the RIM software at a cost of $3,500.

26. Develop and deliver records management training to all new staff as part of their staffing initiation when they join the District.

The training provided to new staff should give an overview of records management and identify expectations for managing records in an enterprise system. This training sessions should be delivered by the Records Manager so that a consistent message is established across the organization. The Departmental Records Liaison may provide additional, department specific guidance as required.

The Records Manager can develop the training material or consulting assistance can be provided to develop the training materials based on the staff training material recommended above at a cost of $1,000 in addition to the costs above.

7. PROTECTION & SECURITY

Best Practice

Records and information are created and retained by organizations to document transactions, support business decisions and meet legislative and regulatory requirements. In order to fulfil these purposes, records and information must be protected to ensure accuracy, authenticity and integrity. Furthermore, adequate protection must be given to ensure that privacy and confidentiality are maintained. It is also imperative that records and information are protected sufficiently to enable business recovery and continuity in the event of a disaster. Typically, between 2% and 5% of an organization’s total record holdings are considered vital for business continuity after a disaster. Vital records for continuity purposes are those documents that are required by the District to reconstruct operations or infrastructure, establish or protect its legal or financial position, or necessary to protect the rights and interests of the employees or stakeholders.



Current Situation

Protection

One area of vulnerability for District records relates to the use of shared network drives as departmental repositories. Although shared drives are a huge step forward in creating the ability to capture corporate electronic documents and share them with other potential users within the department, it is not possible to effectively ensure authenticity or integrity. Any user authorized to access and modify documents in the directory generally has the ability to delete, modify and overwrite all of the documents, regardless of whether they created the document or not. There is no way to automatically capture versions and often no logs are created to identify document activity such as who accessed a document, what was modified, who completed the activity, or when a change was made. File deletion is being logged for all shared drives. However, using the logs to determine who accessed a file would be onerous and time consuming. It is very easy and likely that changes are made to documents unintentionally. There is always the risk that someone has intentionally destroyed documents without it coming to anyone’s attention.

Paper files are also vulnerable. Some departments log all documents coming into the department but there is no way of knowing or tracking who has used the document and where it is currently filed. Public Works does scan and save all incoming documents using Adobe Messenger. Paper documents are filed in the department’s central file and the electronic copy is circulated to the appropriate recipient for action, however, this is the exception. Even with the scanning of all incoming documents, the paper and shared drive files do not necessarily mirror one another, since users are required to submit documents that they create internally or received via email to the administrative support staff for filing. Charge out processes are generally not used for paper files so there is no way of tracking files or establishing chain of custody by identifying who has used them or to ensure they are returned to the appropriate file location.

Privacy

The District of Muskoka is required to comply with the Municipal Freedom of Information and Protection of Privacy Act. Most staff are aware of the need to protect the privacy of individuals. This is especially the case for the Provincial Offences Administration where employees are required to swear an oath of confidentiality. Paper documents and files that contain personal information are usually locked up, kept in a locked facility or segregated from the main repositories. Typically, any employee information in the departments will be locked up by the Commissioner. Payroll has a separate locked section in the records storage room for its inactive files. Provincial Offences maintains all active files that are before the courts in locked file cabinets, and the electronic records are held in a Ministry owned server and provincial courts document repository. However, once the case has been heard/settled, the inactive paper records are sent to the records storage room and housed in the unrestricted access area. In some departments such as Community Services where personal information can be found in most files, the files may not be physically locked up but staff are mindful of the need to restrict access on a need to know basis. Privacy is maintained for electronic files through the network security permissions.



Although the intent is generally to protect the privacy of individuals, there is no specific identification of which records include personal information, there are no procedures documented to identify how or when to protect personal information and general departmental staff may not be aware of processes that should be followed to protect information privacy.

Security & Confidentiality

The need to ensure security and confidentiality goes beyond the protection of privacy. The District does not assign a security classification for its records to identify whether they are public, confidential or internal documents. IT sets security permissions on shared drives according to the names of people in a department or the people who need access. At a minimum, each department usually has a shared departmental drive and a management drive that only the management staff and sometimes their administrative support staff have access to. There are additional shared drives that are accessible to a subset of employees in multiple departments. For example EMS and Emergency Planning staff have a shared drive to support departmental collaboration. Only authorized people named on the access list can access each shared drive. However, the folder permissions are difficult to administer in this environment, resulting in a lack of consistency in how permissions are applied to subfolders. There are cases were staff will inherit the permissions to access a folder when they should not. When staff move to a new position within the District, their permissions to access certain folders are not always changed, resulting in their ability to access folders when they no longer have a "need to know". The District is in the process of implementing Active Directory to create user groups and streamline the management of permissions on the network. One staff person indicated that they have spent a year working out a group permission model so they could ensure internal security and confidentiality within the departmental shared drive. Access to applications such as iCity and InfoHR is restricted to the appropriate staff using the application-specific log on. Maintaining security and confidentiality for paper files is user driven. Management staff may indicate the need for a file to be kept confidential so it is retained in a separate location such as a file drawer or office. In some cases, the support staff questioned whether there really was a need to restrict access to these files within the department, since they didn’t appear to be any more confidential than others in a departmental filing system.

Vital Records Protection and Business Continuity

The District has established a Business Continuity and Resiliency Plan that addresses computer hardware resiliency/ availability, provides shadow copy services that give users a twenty one day window in which to revert to a previous backup version after random file deletions or random file corruption, and a cycle of weekly and monthly backups for long term disaster recovery. A remote backup server hot site is located at the Town of Bracebridge. This remote server does not have the capacity to hold all of the electronic applications, documents and data retained by the District so it is necessary to identify the applications and records that are vital and need to be captured for business continuity purposes. The process of identifying applications and records for business continuity has begun, but further work and documentation is required. At present, the shared drives are backed up on tapes but are, for the most part, not on the hot site server. Some records are captured in FilePro and located in the iCompass cloud, and would be available in the event of a disaster as well. The records held at the Watershed



offices are backed up on an external hard drive on a schedule defined by the individual staff members working in the office. It is taken home for protection. Although technology infrastructure is vital for disaster recovery and business continuity, it is also important to recognize that some vital records will be held in paper or some other physical media rather than in an electronic format. Records that may be identified as vital and only in physical form, are currently retained in the departments or are stored in the records storage room in the basement of 70 Pine Street. These records are vulnerable and may not be recoverable if there were a disaster such as a fire or a major flood at the District offices. Record series that were identified as potentially vital and irreplaceable include the Consent Agreements, Housing and Child Care files. A number of departments indicated that they have a crash binder or battle box for use in the event of an emergency. The crash binder is held by various people and is retained offsite, but the contact information and passwords contained in it may not always be up to date. One area indicated that they have a battle box but it is stored in the department. It wasn’t known whether a similar battle box exists offsite for use in the event of a disaster at 70 Pine St.

Recommendations

27. Until a document management system can be acquired and installed, emphasize the importance of file integrity in shared drives through the use of version control, standard naming conventions and controlled deletion.

How to use version numbering and standard naming conventions should be a key message in the shared drive etiquette training recommended above. Establishing this process now will establish more effective document creation habits and improve the integrity of records in the short term, but it will also make it easier to identify final document versions and duplicates when the EDRMS is implemented. At a minimum, users must understand that documents should not be deleted, moved or renamed in the shared drive by anyone other than the person who originally saved the document. Even then, it is advisable to do so with caution if there is a possibility that other staff refer to the document and will expect to find it using the same name a directory path they have used previously. For folders where file integrity and inappropriate deletion is of greater concern, the right to delete documents should be restricted by IT permissions.

28. Create a workflow to track incoming correspondence and documents while they are being processed.

Not all correspondence or documents received at the District need to be tracked. For those processes where it is important to either identify when a document was received and to ensure that it is circulated to the correct staff for action and follow-up, a workflow documenting the circulation and action required should be created and documented. This workflow can then be incorporated into and automated by an EDRMS.

29. Create a series of security designations for record series and link them directly to the corporate classification scheme.

A security designation is used to clearly identify how access should be restricted to records for each corporate classification scheme category. Security restrictions can easily be captured by adding a column to the classification structure document where the categories and scope notes identifying the content of the category are already defined. Designating records as Public



(releasable to individuals who are not District staff), Internal (access available to District staff only) and Confidential (access available to a limited group of District staff) is usually sufficient. This model for security designations assumes that the right to see information is generally accepted within the organization unless there is a specific reason not to. Where records are deemed to be confidential, permission groups can be used to define who has access.

In addition to the security designation, the District should identify whether the category contains a Personal Information Bank (PIB). This will make it easier to make a PIB registry available and to respond to requests made under the Municipal Freedom of Information and Protection of Privacy Act. It will also help to ensure that personal information is not inadvertently provided to someone through voluntary disclosure.

30. When Active Directory is implemented, link the access level of users to the security of the records through the use of groups linked to the functional responsibilities.

Assigning information access permissions based on staff responsibilities/position rather than an individual’s name will significantly reduce the time required to administer security protocols for electronic records when staff join the District, move from one position to another, or are no longer employed by the District.

31. Identify the records required to perform essential services and assign a vital records designation to them in the classification scheme.

The first step in disaster recovery and business continuity planning (BCP) is the identification of which records are vital. It is also important to identify at what part in the document life cycle this is the case. For example, a certain court document may be considered vital until the case has been settled. Once settlement has been reached the document is probably no longer vital. The corporate classification structure category where vital documents are found should be noted in the classification. However, it is important to understand that not all records in the category may be vital. The precise document type(s) that must be preserved should be identified.

32. Ensure that vital records are current, protected and available as part of the BCP.

Once the vital records are identified, the District will be able to ensure their protection and ongoing availability. For electronic records, ensuring protection may be to simply continue the electronic backups that are already being done. However, there are some records that are stored in paper or have not yet been captured in an electronic format. Protection plans should be developed to ensure that these records continue to be available as necessary in the event of a disaster. A key component for protection will be to ensure that the most current or relevant information is being preserved and will be available. For example, a workflow should be developed to ensure that passwords, contact calling trees and crash binders are maintained current and stored in multiple locations including offsite locations so that they will be available when needed, even if access to the District office is not possible. The same would apply to “battle boxes” created by the departments.



8. TECHNOLOGY USE

Best Practice

Information technology is a key tool in achieving best practice for records and information governance and control while meeting user access needs. It allows the automation and simplification of many processes, thereby reducing direct user involvement and increasing accuracy of information capture. This is achieved through functionality such as assisted classification and the automatic assignment of approved retention rules. In order to achieve these benefits, an enterprise wide architecture for information repositories is the norm. This includes the ability to capture records regardless of where they are created, especially from email, collaborative sites and social media systems that are quickly becoming the platform for business development, decision making and approvals. Technology solutions also provide the ability to integrate and connect related content, regardless of the media or location in which it is stored through the use of federated search tools and the like.

Current Situation

Technology Infrastructure

Shared drives are used extensively for the creation, capture and storage of information at the District. iCompass is the only centralized electronic document management repository or system to capture corporate records and information. Applications are catalogued and approved for use (where applicable). Licenses, along with other relevant metadata are kept with IT Services using an internally developed “application portal”. Provincial Offences Administration is completed on Ministry of the Attorney General owned servers and applications. Although the server is housed at the District, technology support and help desk is provided by the Ministry, not the District. Although records are most often created in electronic format, paper is still often used as the official version of the document. The District departments are working in a hybrid environment where information can reside on paper, in multiple electronic repositories, or in both electronic and physical formats.

Email

Email is used extensively within the District for business discussions, decision making and approvals. Staff have not been given any training on email best practices, resulting in inconsistent and ineffective capture and use of the information. Some users are saving emails in electronic format to their shared drives but this process is cumbersome at best. In some areas, users are printing relevant emails and filing them in physical files. More often, the information is simply retained in a user’s inbox/email folders. Users who have a large number of emails will create .PST files to “archive” their email holdings. A number of users indicated that they had between 15,000 and 30,000 emails in their email inbox and folders. IT is considering establishing a quota to force users to reduce the storage size of their inbox. Typically with a quota system in place, users who are running out of space either begin deleting emails based on personal parameters (i.e.: emails with the large attachments, emails from certain people, emails older than a certain date, everything in the inbox, everything in the sent box, and so on). Although creating .PST files reduces the space used on the email server, it increases the space used for document storage on other servers.



Neither ad hoc destruction nor .PST files reflect good records management practices. Ad hoc destruction ignores the probability that emails may contain business records. The Microsoft .PST file format is essentially a blob file containing a large number of emails from one individual’s email box. There is no way to classify this file according to the functional Classification Structure because the content relates to multiple activities or may not be a record at all. Retaining emails within a person’s email box creates a silo of information that is accessible to only the individual who has access to the email account. A significant portion of the business records that are created using Email are not captured and are not available as the basis for future decision making. When a staff member leaves the District IT is required to search their email accounts to determine if any relevant documents exist.

Recommendations

33. Proceed as soon as possible with the development of system requirements for a comprehensive Electronic Document and Records Management System (EDRMS).

As previously noted, using shared drives is an effective first step towards capturing and sharing documents within an organization. However, over the longer term, staff are looking for the functionality, security and controls that only a fully functional EDRMS can provide. The District has indicated its intent to purchase an EDRMS. The functional system requirements that are to be provided as phase 4 of this project should be developed as soon as possible to ensure that preparations for EDRMS implementation and software acquisition can proceed without delay.

There are two major types of software that the District might consider when looking at an EDRMS. They can generally be labelled as Records Management Software (RMS) or Electronic Document and Records Management Software (EDRMS). There is also a very basic type of RM software that concentrates mostly on physical records but it is not considered a viable option for the District's RIM program.

RMS products have a full set of features for managing both physical and electronic records. They are all based on using a standard classification structure that is tied directly to retention periods. Some of the more prominent features are:

• Full circulation history for boxes, folders and documents; • Application of security settings to boxes, folders and documents when conducting

searches (non-permitted results are not displayed) or when requesting access to physical files;

• Charge-out of physical records and automatic reminder when an item is "out" for more than the allotted timeframe;

• Use of barcode technology for all movement of physical records; • Printing of lists of records to be moved to inactive storage (physical records) or to be

destroyed/transferred to an archival facility; • Managing HOLDS for access, modification and destruction of records during litigation or

MFIPPA requests; • Tracking of protection methods for vital records; and • Ability to print colour-coded labels for both top-tab and end-tab folders

The RMS products also offer basic workflow functionality which can be used for correspondence tracking, bring forwards and other serial business processes.



Based on 500 users, the cost for RMS software will be in the range of $125,000 to $200,000 with annual maintenance usually set at 20% of the original purchase price. Vendors often offer a payment of the license fee over the first 3 years of the software implementation. Examples of this type of software are GimmalSoft, LaserFiche, FileTrail and TabFusion. Costs for hardware such as an additional server would be extra and probably in the neighbourhood of $50,000. EDRMS products include all of the features found in a RMS but they add a number of features that can significantly improve the way in which a company conducts its business and how it applies the RIM principles. Some of the features can:

• Automatically assign version control by type of record and, when the record attains "final" status it can be set to delete or retain all previous versions or retain a defined number of them;

• Create complex workflows that can automatically be assigned to a document type when it is received or saved into the repository. The workflows can include many parameters that can automatically notify staff when deadlines are approaching and required activities have not been completed;

• Significantly enhance collaboration between departments, project teams and external vendors/affected parties;

• Through the use of Application Programming Interfaces (APIs), access and synchronize data between applications. This creates an enterprise system where some applications are designated as the "masters" for certain record types and other applications (slaves) access the data from the master when it is required;

• Seamlessly integrate email into the main record repository; • Apply RIM principles such as retention periods or HOLDS to data in other applications

that can be accessed through APIs; • Apply the classification scheme and all related RIM principles automatically based on

the type of document being used; and • Provide full audit trails of all actions performed on any document.

Their use results in a much more profound and aggressive improvement in the authenticity, integrity, reliability, standard governance across the entire organization and usability of information. They are truly transformational, allowing staff to conduct their tasks in a much more efficient and effective manner. Products in this category include OpenText, Documentum, FileNexus and SharePoint in either their native format or by using one of the RMS products as a third party add-on. Costs would be in the range of $500,000 to $650,000 including hardware and professional services.

34. Include seamless integration between Outlook and the EDRMS in the requirements so that users can use "drag and drop" capability to move emails from Outlook to the EDRMS.

Having “drag and drop” functionality will streamline the capture of emails into the official corporate repository.

35. Provide email use training to all staff and discourage the use of .PST files for long term record storage.



As part of the user training on email best practices, staff must be made aware of the access issues that result when information relating to corporate decisions is retained in an individual’s email folders and .PST files. Teaching them to manage their inboxes and email folders more effectively may reduce total email volume and the need for .PST files.

36. When the EDRMS is in place, implement a 45 to 60 day limit on the age of emails in Outlook.

Establishing a limit on the length of time an email can be retained in Outlook will reinforce the preceding recommendation that email is a records delivery system and not a records repository. Users will be forced to save emails into the EDRMS corporate repository.

9. MONITORING: COMPLIANCE & QUALITY

Best Practice

Compliance with corporate records and information management policies and procedures that reflect the legislative and business use requirements of an organization is important for good information governance and ongoing information access. Being able to show in a court of law that policies and procedures identifying the expectations of an organization are available and that all staff are complying with those expectations is essential for meeting the Evidence Act requirement that records were “created in the normal and ordinary course of business” and that they were relied upon for business decision making purposes. Compliance helps to establish the authenticity, integrity and reliability of records that is required to successfully defend the District’s position in legal proceedings. To ensure that consistency in records capture and maintenance is maintained, the organization must monitor how recordkeeping activities are carried out.

Current Situation

At this point, the District of Muskoka does not have a defined, enterprise wide Records Management program. The Provincial Offences Administration department is subject to monitoring by the Ministry of the Attorney General. Procedural audits are supposed to be carried out every two years, although the District’s last audit was in 2005. The Consultants have been engaged to identify a strategy and action plan for putting such a program in place. Without an enterprise wide program, Muskoka is not in a position to formally monitor compliance at this time.

Recommendation

37. Conduct regular reviews for compliance with the RIM program policies and procedures once they are established and users are trained.

The cliché that “what gets measured gets done” is generally accurate in the development and implementation of a Records Management Program. Ongoing monitoring for compliance will be an important activity once the classification structure and bylaw have been finalized and training has been completed. This will help to identify where additional training and support is needed. It will also provide an opportunity to identify potential enhancements that can improve and mature the records management program over time, as staff become accustomed to the new way of organizing and managing their information.



Monitoring criteria and compliance expectations should be documented by the Records Manager and conveyed to the Records Liaisons in each department. Alternatively, the consultants are available to develop the monitoring and compliance program for the District to use.

INFORMATION GOVERNANCE MATURITY

The ARMA International Information Governance Maturity Model1 provides a useful tool for evaluating an organization’s current recordkeeping practices. It can also be used as a benchmark for measuring progress in the development of a records and information program that meets industry best practices. Generally speaking, the District’s enterprise wide Records Management Program is in its infancy. Core records management elements including a records classification structure, retention schedule, shared drive directory structures, inactive record storage and vital records identification are being developed. To date, implementation of these program elements has been localized in certain departments or to certain types of records, rather than at the enterprise level. In order to establish an effective and mature information governance approach, these core program components need to be systematically rolled out at the enterprise level. The eight principles that form the framework for a mature program along with the District’s current Maturity Rating are identified below. The Maturity Rating assessment has been completed by 25 Ontario municipalities. The average of their scores is provided below for comparison.

Principle of Accountability

“A senior executive (or person of comparable authority) oversees the recordkeeping program and delegates program responsibility to appropriate individuals. The organization adopts policies and procedures to guide personnel, and ensure the program can be audited.”

The District is approaching a level 4 for maturity on the principle of accountability (average 3.58). There is some executive awareness of records management initiatives. The role of Records Manager has not been specifically defined or assigned although the District Clerk has taken on some of the responsibilities and there is some assignment of responsibilities on a strictly departmental level. For the most part, ultimate responsibility for records and information lies in the local departments. Departmental managers have full control and accountability, although they may not be aware of what this can entail. In order to establish an effective and mature records and information management program that addresses all enterprise records, regardless of the media in which they are captured and stored, the District will need to formally assign and delegate records and information management responsibility at various staffing levels throughout the organization. Establishing approved Policies and Procedures that reflect an enterprise wide scope will provide a framework for defining corporate expectations.

1 Detailed information regarding the Information Governance Maturity Model can be found at http://www.arma.org/r2/generally-accepted-br-recordkeeping-principles


http://www.arma.org/r2/generally-accepted-br-recordkeeping-principles


Principle of Transparency

“The processes and activities of an organization’s recordkeeping program are documented in a manner that is open and verifiable and is available to all personnel and appropriate interested parties.”

The District is at a level 1 for transparency (average 1.67). The development and documentation of the recordkeeping program is just beginning. The District strives towards routine information disclosure and requests under the Freedom of Information Act are limited to 12 – 15 per year. Training is limited. As a public body, external transparency is of great importance for the District. Record access is critical when responding to Freedom of Information requests and voluntarily or routinely disclosing information. Perhaps more significant is the need to improve transparency in order to facilitate information access and sharing between internal staff and departments. The District should strive for a moderate increase in its level of performance relating to the principle of transparency. Documenting its policies and procedures is an important component of this transparency.

Principle of Integrity

“A recordkeeping program shall be constructed so the records and information generated or managed by or for the organization have a reasonable and suitable guarantee of authenticity and reliability.”

The District is at a level 1 in terms of records and information integrity (average 1.96). In order to ensure integrity within an organization, information and records must be managed at an enterprise level. Chain-of-custody and control processes need to exist to ensure that content is identified through the use of enterprise wide classification structures and metadata definitions. The accuracy of the content and the document version need to be easily identified. The District’s current records management practices are very localized, and there is no standard classification structure in place at this time as a first step towards increasing the controls required to establish records integrity. In order to establish an effective and mature records and information management program that ensures access to accurate information over time to all potential users, the District will need to increase its level of performance relating to the principle of integrity. This will be especially critical for records that may be required for legal discovery and those relating to public infrastructure such as roads, bridges or lagoons that are used/maintained for a long time or may have long term environmental impacts.

Principle of Protection

“A recordkeeping program shall be constructed to ensure a reasonable level of protection to records and information that are private, confidential, privileged, secret, or essential to business continuity.”

The District is approaching a level 1 in terms of information protection (average 2.28). There is some recognition for the need to protect information relating to subjects such as employee personal information, Community Services clients, corporate governance and financial position.



In order to establish an effective and mature records and information management program that provides adequate protection of records, the District needs to implement a security classification for its records. Establishing an enterprise content classification structure will improve its ability to accurately apply the security classification according to document content. Both physical and electronic records protection should be enhanced to provide adequate protection.

Principle of Compliance

“The recordkeeping program shall be constructed to comply with applicable laws and other binding authorities, as well as the organization’s policies.”

The District is at a level 1 for compliance (average 2.48). The development and documentation of the recordkeeping program is just beginning. Compliance is also closely linked to the Principle of Protection and the application of security classifications to all records and information. A more mature RIM Program and implementation of core program elements with an enterprise wide scope is required in order for the compliance rating to increase. The District should strive for a significant increase in its level of performance relating to the principle of compliance. An important element of demonstrating compliance should be regular monitoring to ensure that approved policies and procedures are being followed in all user areas.

Principle of Availability

“An organization shall maintain records in a manner that ensures timely, efficient, and accurate retrieval of needed information.”

The District is approaching a level 1 in terms of records and information availability (average 2.50). Policies and standards such as the records classification structure are in the process of being developed but there is no consistency in how records are captured and managed throughout the life cycle. Records retrieval and sharing continues to be a challenge. Department staff or primary records creator knowledge of records, repositories and record processes are required to find the information necessary to complete day to day work. In order to establish an effective and mature records and information management program that ensures that records are appropriately managed throughout the information lifecycle, the District will need to significantly increase its focus on the application of content classification to all information and records at an enterprise level.

Principle of Retention

“An organization shall maintain its records and information for an appropriate time, taking into account legal, regulatory, fiscal, operational, and historical requirements.”

The District is at a level 2 in terms of retention (average 4.33). The retention Bylaw was last updated in 1977 and does not reflect current record holdings or legislation. No procedures exist and the need to apply the stated retention periods consistently and across all media is not the norm.



In order to establish a records and information management program that ensures that records are appropriately managed throughout the information lifecycle, the District will need to significantly increase its focus on the consistent application of the records retention schedule to all physical and electronic information and records at an enterprise level.

Principle of Disposition

“An organization shall provide secure and appropriate disposition for records that are no longer required to be maintained by applicable laws and the organization’s policies.”

The District is approaching level 1 in terms of information disposition (average 1.60). Policies do not exist for the secure transfer and destruction of records, although procedures are being put into place to ensure the documentation of destruction that takes place from the records storage facility. However, procedures do not exist for the suspension of destruction if necessary for legal or audit reasons. Process documentation and training are ad hoc and departmentally focused. Confidential records are collected separately and shredded under monitored conditions. In order to establish a records and information management program that ensures that records are appropriately managed throughout the information lifecycle, the District will need to increase its focus on consistently applying disposition processes and documenting the records that are destroyed for information and records at an enterprise level. The adherence to a methodology for suspending all destruction in the event of a legal, audit or access proceeding must be established.



STRATEGIC PLAN

Overview

Although there are many recommendations in this report, implementation of them must also accommodate other tasks and District projects which are occupying the limited time that staff has available. The initial timeframe for this project, as stated in the initial Request for Proposals (RFP), was over two years to accommodate other duties and to fit within the longer-term budget. The strategy which follows has taken into consideration these realities and has been structured to devote most of 2014 to developing, approving and implementing the foundational elements of the policy, the District classification scheme and the accompanying retention schedule. Additional program components such as an RFP for an RMS/EDRMS and hiring a Records Manager are planned to begin in the last quarter of 2014 or the first quarter of 2015. This will allow for sufficient time to ensure that the foundational elements are well established and any adjustments have been completed before proceeding with the other elements. Note: a detailed project plan depicting timelines and resources is attached as Appendix A.

RIM Program Policy Development

Many Ontario municipalities have developed their corporate policy for Records and Information Management. The Clerk will solicit samples from municipalities to use as a template for developing one that is specific to the District. The Clerk will then compile a draft District policy which will be distributed to SMT for comments. After completing any required revisions, the policy will be submitted to SMT for approval.

Classification Scheme and Retention Schedule

There have been several meetings in which the Deputy Clerk has worked with Administrative Support Staff to derive a consensus on a corporate classification scheme. The consultants have provided reviews and feedback on the various draft versions and have researched the legal retention requirements for the record series and applied the research to the record series. Unfortunately, this process of review and updates can continue almost indefinitely. By definition, a corporate classification scheme is never "cast in concrete". It must be dynamic and its effectiveness can only be determined once it is in use. It is quite normal to have to make modifications to the scheme as it is implemented and beyond. When the next round of review is completed the draft classification scheme should be submitted to SMT for approval. The retention schedule will require approval from the District's auditors but this should not be conducted until the classification scheme has been approved. When the policy, classification scheme and retention schedule have received SMT approval they can be submitted to Council for approval.



Destruction and Hold Policy & Data Asset Inventory

Before implementation training can begin it will be necessary to develop and approve a policy and procedure for destruction of both physical and electronic records that have exceeded their retention period. Implementing this procedure will be an important part of the initial implementation plan described below. Although a policy and procedure for initiating and controlling holds on destruction for litigation of MFIPPA requests are not required for this initial phase of implementation, they do tie directly to destruction. This is an optimum time to develop and approve the hold policies and procedures. The consultant will develop the draft policies and procedures and submit them to the Clerk for processing. When approved, they will form part of the implementation training. The Data Asset inventory provides a more detailed view of how the records noted in the classification scheme are distributed throughout the District. It is a key piece of data in identifying areas where duplication is most likely. The consultant will complete the data asset inventory and add it to the classification scheme prior to commencing the implementation training.

Implementation Training

The implementation of the classification scheme should begin as soon as possible after the policy, classification scheme and retention By-law have been approved. This is a key activity in demonstrating the benefits of having these 3 components structured on a District level. The process will be labour intensive but the results will be very noticeable within the volume of physical records. Reductions of between 33% and 50% are not unusual. It will also provide a good test of the classification scheme and will point to areas where some adjustments may be required. Implementation of the classification and retention to electronic records will be somewhat more complicated. Our recommendations 18 to 21 inclusive are still the recommended approach but, as stated previously, this will have to be coordinated with and confirmed by IT. The consultant will develop and deliver implementation training for Administration Support Staff and other departmental personnel who will be involved in the initial implementation. The training will include:

• An overview of the RIM policy, its scope and objectives; • How to set priorities on which folders should be addressed first and which ones can be

addressed using a "date forward and as touched" methodology; • How to determine the proper classification code for each folder; • Determining whether or not the file can be destroyed; • Preparing lists of files to be converted to the new classification scheme and those eligible for

destruction; and • Using the approved methodology for implementation using the shared drives.

The training will be conducted in small groups, ideally including one department. This will allow the examples to be relevant to the attendees so that they can apply the training to their departmental situation. They will be encouraged to bring a few sample files with them that can be used in the session.



Electronic Document & Records Management System (EDRMS)

Recommendations 34 to 36 relate to the implementation of an EDRMS. We have outlined some of the features that should be included and have suggested that the District explores the possible acquisition of an EDRMS that includes several features which provide solid governance for the District's information resource and which can significantly transform the way in which business is conducted within the District and between the lower tiers and other external agencies/business partners. This would, however, involve a more in-depth sharing of IT and RIM resources that currently exists. Given other internal initiatives such as the Services Review and the fact that this is an election year for the lower tiers it has been decided to take a multi-stage process in acquiring an EDRMS. This would consist of acquiring records management software that provides all of the governance requirements for both physical and electronic records and which can be used as a platform if and when the District is ready to implement the business improvement features. The steps in this process are:

• Develop a set of system requirements for an RMS which is focused more on the management of physical and electronic records (see recommendation 34);

• Include in the requirements the capability to expand the system to a full EDRMS; • Issue an RFI to obtain budget information for both types of software (RMS & EDRMS); • Compile and issue an RFP for the RMS; • Develop User Case Scenarios that vendor will use for their product demonstrations; • Evaluate responses and create a short list of ideally not more than 3 or 4 vendors who will be

invited to provide onsite product demonstrations; • Evaluate the vendor demonstrations and select a vendor; • Implement the RMS in all departments;

If a decision is made to proceed with a full EDRMS:

• Develop the remaining system requirements for the EDRMS; • Compile and issue an RFP for the EDRMS; • Evaluate responses and create a short list of ideally not more than 3 or 4 vendors who will be

invited to provide onsite product demonstrations; • Evaluate the vendor demonstrations and select a vendor; and • Implement the EDRMS in all departments.

We are still recommending that a demonstration of both an RMS and an EDRMS is given to SMT. This should be scheduled prior to the RFI for the RMS/EDRMS is issued so that SMT has a frame of reference to assess the responses.

Records Manager Job Description

The position of Records Manager is crucial to the success of the entire program. As we have mentioned many times, the RIM program cannot be static. It must be developed and implemented on a District-wide basis and it must encompass all District records. The program will require periodic review and enhancements to reflect changing needs and new tools that will become available. The program that we have outlined will be effective but it will incur considerable investment of both staff time and budget



dollars. If there is to be a continuing ROI, sufficient and qualified resources must be assigned to the RIM program. Hiring a Records Manager early in the program development phase will reduce the dependency on and cost of consulting services. We have identified $27,500 of potential consulting costs which could easily be assigned to the Records Manager. Early hiring will also ensure that the program bears the "signature" of the person most involved in maintaining it. It will also provide an excellent opportunity to have the Records Manager learn the program and its tools "from the ground up". A very important aspect of creating a job description for the new FTE is to ensure that the qualifications required are in line with the type of program and the level of sophistication of the tools that will be used. Although the type and complexity of the RMS or EDRMS is not yet known it is advisable to scope the position for the full EDRMS rather than having to reassess it later. We have no doubt that the District will eventually implement EDRMS within the next 2 to 5 years. Having someone on staff with knowledge of and experience in that type of system will be invaluable in developing the system requirements and in choosing the correct vendor for both the RMS and EDRMS. It is recommended that the position description for the Records Manager is developed as soon as possible and that the position is budgeted and filled prior to developing the RFI for the RMS/EDRMS. The development of the job description is part of the budgeted and allocated project cost.


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