IV. Managing the Risks of Moving to Electronic Records
Preserve and/or Prepare for Migration
Too often systems are built with the faulty expectation that they will last
forever. In reality, systems go through a life cycle, which ends in their complete
redesign or retirement from service. The need or requirement to retain accessible
and useable electronic records may exceed the life of the system that created them.
Electronic records created by one system may need to be moved or migrated to another
system. System migrations are extremely complex and should be planned for and
accomplished before the original system becomes obsolete and inoperable. Migration
should be implemented incrementally along with periodic system and software upgrades
and should include quality control checks. While migration has become common, it is
still fraught with danger. For example in one case involving FDA-mandated records of
drug testing, blood pressure numbers were randomly off by up to 8 digits following
data transfer from UNIX platforms to Windows NT operating systems.8
The least complex form of migration is simple data migration where the data is
pumped from the old system into the new system. For low risk electronic records this
may be sufficient to retain them in a useable form. However, even such a seemingly
simple task could be problematic depending on the complexity of data structures and
the use of proprietary formats. Furthermore, a successful migration of high-risk
records will require that information in addition to the informational content of
the records be migrated to ensure their integrity and reliability. Information
relative to the electronic record’s creation and use such as metadata,
audit trails, authoritative controls, and documentation need to be migrated to the
new system and maintained for the same retention period as the records. In other
words, it is not enough that the content or data of the records be migrated to the
new system. The context in which the records were created and their structure needs
to be maintained for the life of the records as well. The migration of this
additional information could be extremely difficult and will involve additional
planning and resources.
Most installed technology involves proprietary systems and formats. Proprietary
data formats can greatly complicate migrations and jeopardize the accessibility of
electronic records. Technology policies should strive to establish standard formats
for electronic records. Since software is subject to change – either by
the implementation of new releases, by changes to operating systems, or changes in
hardware requirements, the use of non-proprietary formats is strongly recommended.
Regardless of the medium on which a record is stored the use of non-proprietary
formats will minimize the long-term costs associated with maintaining the
reliability of and migrating records. The use of widely adopted standard formats
(relational databases, ASCII, SGML, etc.) can help reduce the rate of technological
obsolescence and the frequency of migrations, as well as facilitate migrations. Be
aware, however, that standards change or are replaced over time and must be
monitored. The National Institute of Standards and Technology (NIST) is exploring
the use of standard e-records storage formats.
Although not a permanent solution, migration is the primary solution for retaining
electronic records over extended periods of time, especially if there is a need to
retain the records’ original functionality. However, other possible
solutions to long-term retention are also being explored including:
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Encapsulation: Encapsulation refers to a method of capturing the look
and feel of the original record along with any required metadata as a
single digital object in a portable format. In some ways, encapsulation
combines system migration with use of standard formats. Encapsulation
strategies are just beginning to be investigated.
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Emulating obsolete technology: Emulation consists of using hardware
and software to allow one computer technology to act as if it were
another technology. This solution allows e-records to remain in their
original file formats while the hardware and software change. Emulation
is complicated and expensive to achieve for any sophisticated system.
Research on emulation solutions is ongoing.
If loss of a record series would place an agency at significant
risk, exporting the records to a technologically neutral, durable media such as
computer output microfilm or paper as insurance against unforeseen migration
problems. Because export will result in a loss of system functionality, this option
is unattractive and clearly reserved only for records of extraordinary value. In
some instances, it may be possible to export a subset of the essential information.
A hybrid approach that preserves the records in both electronic and durable formats
can offer functionality and confidence of preservation.
Export to physical media requires the preservation of sufficient context and
structure to ensure that the records are acceptable as evidence. This information
may be appended as a header or footer, although some can be translated back into the
media’s physical characteristics. For example, a message digest used to
demonstrate the record’s integrity is of no further value because the
content is fixed on film or paper and subject to traditional forensics tests for
altered documents. However, the process of exporting records should verify the
message digest as part of the export process so that the records can be certified as
authentic.
8
Business Week April 20, 1998
