The emergence of digital technology was supposed to reduce the need for paper. Instead, paper has seemed to multiply. We squeeze it into filing cabinets, pile it on our desks and jam it into drawers. Going paperless might seem like an impossible dream, but recently our office decided to take on that challenge. The following is a description of what we did and how we did it.
-Commissioner Sidney Linden
Having a paperless office does not mean there is no paper. There is always paper.
It means that all business records, including case records, are kept in digital form, which is considered the authoritative form of the record.
It means that business records made or received in paper form are converted to digital form.
It means that print-outs of digital records, or paper originals, are considered transitory.
It means that digital business records are organized and disoverable within a logical and controlled filing scheme.
It means that all digital business records observe a standard naming convention and that no central paper filing system is maintained or purported to be maintained.
It means, basically, that the official record of the organization is digital.
And it means all this must be done legally and properly.
The COIC Information Renewal Project realized this vision of the paperless office.
The project was driven by the office being designated in 2013 as a public body under the Archives and Recordkeeping Act and by the simple fact that we were running out of space for our paper case files.
We needed expert help, so we recruited a practicum student from the University of Toronto School of Information Sciences. And of course we worked closely with Archives of Ontario.
First, we needed to develop archival records series for the office. We had already adopted the common records series for such things as policy, administration and communications. But we also needed agency-specific records series, in particular for case files which documented our core business function.
Our practicum student developed records series using Archives templates, for our digital case file documents, for case file data, for commissioner engagements (not covered by the common series), and, perhaps most importantly, for source documents.
While digitized originals can be treated as transitory, Archives advised that best practice is to have a source document records series dealing specifically with paper records that are digitized. The series authorizes destruction after the record has been scanned and a quality control check performed.
So now, case files do not have to be kept in paper form. All records relating to a case are stored in the shared directory. Case records made or received in paper form (usually just case notes and signed letters) are scanned and do not have to be retained.
You may ask: But the commissioner is a statutory decision-maker. What if someone appeals one of your decisions? What about the best evidence rule that says a paper original has greater probative value than a copy?
That’s not much of an issue. Recent changes to the Evidence Act mean that a print-out has the same weight as a paper original, as long as the integrity of your electronic records system can be demonstrated if the record is challenged.
All our records series were submitted to Archives for review and approval. They had to be approved by the Archivist before we could dispose of any of our case records.
Now, there is no use doing any of this, that is to say, making digital records authoritative, if they are disorganized and hard to find. This is no better than having a disorganized paper filing system.
So we got up to speed on functional classification, which enables you to classify digital records according to the functions and activities they support, which is better than doing so by, say, subject, or creator name, or project name, or just ad hoc.
In a series of workshops, we established the main functions of the organization and their constituent activities. The shared drive was reorganized accordingly. Scope notes were prepared describing the contents of activity folders and related records series. A file naming convention was adopted. Function and activity folders cannot be created or modified without formal approval.
Finally, a set of concise information management policies was written to formalize all of this, and to ensure the office can demonstrate system integrity if a print-out is ever challenged in court.
Before we could start destroying paper case files, we had to make sure the digital version of a file in the database was complete. So, our practicum student reviewed all paper case files going back to the beginning of the office, and made sure the entire contents of these files were mirrored in the digital case folder.
All this in place, we could now legally shred all the paper files that had accumulated over 10 years, as well as case files from the predecessor, part-time commissioner prior to the establishment of the office. Every destruction event was meticulously documented by a Record of Destruction signed by the Executive Director.
About 25 linear feet of paper files were thus eliminated. Two large filing cabinets were emptied, liberating about 450 cubic feet of space for other uses.
I have often dreamt about being able to implement a records rationalization project, including something radical like going genuinely paperless. It is often hard to do so because of competing priorities, resource constraints, internal dynamics, and management hesitancy. So this was great.
The project could not have succeeded without the support of Commissioner Linden, who, despite his quite healthy concerns about going paperless, embraced the project enthusiastically, but also the support and encouragement of our Executive Director, Derek Lett, and legal counsel, Daman Thable.
I also wish to acknowledge the excellent work of our UofT practicum student, Peter Murray, and the generous guidance and encouragement of Minaz Dharssi of the Archives of Ontario.
James De Monte
Senior Policy Advisor