ISO 15489 Records Management –

its development and significance

SUSAN HEALY

Abstract
This article describes the process of producing ISO 15489 Records Management,
and explores some of the professional and other issues that arose for considera-
tion at an international level. It concludes by identifying some of the benefits of
the Standard for records management in the UK.

Introduction

In this article I shall describe the process of developing the international

standard ISO 154891 and its associated Technical Report, and some of
their contents and assess the Standard’s significance for records manage-
ment in the United Kingdom2.

First, an explanation of the abbreviations and acronyms I shall use. ISO

stands for International Standards Organisation, a body based in
Geneva that oversees the issue of international Standards. The British
Standards Institution (BSI) is the UK NMB (National Member Body of
ISO). The ISO Technical Committee under whose auspices we worked is
TC 46 and its Records Management Sub-committee is SC 11, hence the
reference to TC 46/SC 11. The BSI counterparts are IDT 2 at the
Committee level (standing for Information Documentation Terminology)
and Sub-committee 17, hence IDT 2/17. Key stages in development of a
Standard are production of a Committee Draft (CD), a Draft International
Standard (DIS) and a Final Draft International Standard (FDIS). Finally,
the sections making up a Standard are called clauses.

Development of ISO 15489

My involvement in ISO 15489 started in July 1997 when I attended a

meeting at the BSI offices in Chiswick. The purpose of the meeting was

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to discuss future action on internationalising the pioneering Australian

Standard AS 43903, Records Management. This Standard had been
developed in Australia in the early 1990s in response to the quality
Standard ISO 9000. ISO 9000 refers to the need for “quality records” to
show the operation of a quality system but does not expand on what
makes up a quality record. Australian records managers made the con-
nection between ISO 9000 accreditation and good records management
and set out to fill the gap, producing what Standards Australia has
described as one of its best sellers.

AS 4390 had recently been through an ISO balloting process for issue as
it stood but sufficient reservations had been expressed by NMBs for ISO
to decide that a re-think was necessary. So, a group of records profes-
sionals and Standards experts from the UK, Australia, USA, France and
Sweden met and concluded that ISO should be asked to set up a new
sub-committee to develop AS 4390 into an ISO Standard. This was the
start of what was to prove a fascinating if often frustrating project.

ISO approved the recommendation and TC 46/SC 11 met for the first
time in Athens in May 1998, with the chair (David Moldrich) and secre-
tary (Peter Treseder) provided by Australia. The UK was represented by
Philip Jones and me at this and subsequent meetings; Bob McLean
joined the delegation in May 20004. Other countries represented at the
meetings were Australia and New Zealand, the USA, Canada, France,
Sweden, Germany, the Netherlands, Ireland and Denmark. We were
joined also by observers from the International Council on Archives and
the International Records Management Trust.

The UK was represented at the Athens meeting because BSI had decid-
ed to contribute to this work and had established IDT 2/17 to shadow
TC 46/SC 11, with me in the chair. IDT 2/17 was and is a healthy mix

A working break, Berlin May 2000. From left to right: Michael Wettengel
(Germany), Barbara Reed (Australia), Pierre Fuzean (France).

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of those who practice records management in both public and private

sectors, those who oversee it in government and those who teach it,
together with representatives of other interested organisations.

TC 46/SC 11’s activity has not been confined to its six-monthly meetings.
Much of its work has been done electronically, using email and a ded-
icated mailing list and discussion database, and the meetings were less
for drafting than for negotiation.

It soon became clear that different national professional and juridical

traditions led to very different views of what the Standard should cover
and contain. These differences persisted throughout and it is remarkable
that we were able to reach consensus without losing the utility of the fin-
ished Standard. What sort of issues caused difficulties? Here are some of
them.

Scope

Scoping the Standard was an initial and recurring problem. Some coun-
tries do not distinguish between records and archives and were unhappy
with a time-limited concept of records management. They had real diffi-
culties with the idea that we should focus only on the management of
records in their originating organisation, with no coverage of the man-
agement of those selected for permanent preservation and archived,
either in-house or in an external archives institution. This issue mattered
to the UK delegation because other BSI sub-committees work on aspects
of archives administration, such as the BS 54545 sub-committee, and we
needed to avoid encroaching on their territory.

TC 46/SC 11 managed to reach agreement and ISO 15489 does not

extend to archives administration. This is stated explicitly in clause 1,
Scope, in the following terms

“This International Standard provides guidance on managing records

of originating organizations, public or private, for internal and exter-
nal clients. ... [It] does not include the management of archival
records within archival institutions”

while footnote 1 explains:

“In some countries, the management of records also applies to

archives management. Archives management is not covered in this
Standard.”

As for what records management encompasses, the Standard adopts an

holistic approach. The definition of records management in clause 3 is

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“field of management responsible for the efficient and systematic con-

trol of the creation, receipt, maintenance, use and disposition of
records, including processes for capturing and maintaining evidence
of and information about business activities and transactions in the
form of records”.

Status

There was some debate concerning whether the Standard should be a

voluntary code of practice, i.e. a statement of recommendations, or a
compliance Standard, i.e. a statement of requirements. The decision had
to be made because of the effect on terminology, on which ISO has rules.
The verb ‘must’ and others with a mandatory connotation can be used
with compliance Standards only; for recommendatory Standards
‘should’ and equivalents is the accepted term. We decided that a compli-
ance Standard would be premature and self-defeating; most organisa-
tions need urging towards best practice and would not respond to a
document purporting to set mandatory requirements. Furthermore,
without enforcement powers and mechanisms it would be futile.

Audience

Terminology also affected our decision on whether the Standard should

be aimed at records practitioners or general managers and company sec-
retaries. AS 4390 is aimed at both: Part 1 is a high level summary of the
other parts which is intended to be read by the managers who seek ISO
9000 accreditation and control the funding of records management,
while Parts 2-6 provide operational details suitable for practitioners. We
had already agreed not to replicate the AS 4390 division into parts so
that option was not open to us. We decided that the Standard should be
intelligible to non-specialists but useful for records professionals; it
remains to be seen whether we succeeded. The Technical Report, on the
other hand, is intended to be read and used by records practitioners.

Structure

The structure of the Standard changed frequently in the course of devel-

opment (one cause of the frustration alluded to above). The major
change was the decision in May 1999 to divide the text into two docu-
ments, a Standard focusing on principles and outcomes (the what and
the why) and a Technical Report (TR) providing procedural guidance,
thereby providing an aid to understanding and implementing the
Standard (the how). In the event we ended up with a TR that expands
clauses in the Standard selectively.

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The clauses in the Standard indicating and the corresponding clauses in

the TR (as indicated) are as follows:

1 Scope (TR clause 1)6

2 Normative references

3 Terms and definitions

4 Benefits of records management

5 Regulatory environment

6 Policy and responsibilities (TR clause 2)

7 Records management requirements

8 Design and implementation of a records system (TR clause 3)

9 Records management process and controls (TR clause 4)

10 Monitoring and auditing (TR clause 5)

11 Training (TR clause 6)

The TR also contains a bibliography and two appendices that link the
clauses in the Standard to the corresponding clauses in the TR and vice
versa. An index is also planned.

The two clauses expanded most in the TR are clause 8 (as clause 3,

Working on the Technical Report, May 1999. From left to right round the
table: Frank Upward (Australia), Philippe Barbat (France), Anki Steen
(Sweden), Ruth Kappel (Germany), Piers Cain (IRMT) and Susan Healy
(UK).)
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Strategies, design and implementation) and clause 9 (as clause 4,

Records processes and controls). TR clause 3 contains a detailed expla-
nation of the DIRKS (Designing and Implementing RecordKeeping
Systems) methodology developed by the National Archives of Australia7.
TR clause 4 contains text on (i) the instruments required for RM opera-
tions, e.g. business classification scheme, disposal schedules (called
disposition authorities), security and access classification schemes and
vocabulary controls; and (ii) processes using these instruments, e.g. cap-
ture, registration, classification, access and security classification, dispos-
al, storage and use and tracking.

Annexes to the Technical Report

We liked the idea of including annexes and contributions were received.

For example the UK supplied some model policy documents and dis-
posal schedules. Two factors led to a decision to omit them. The first was
the number of additional pages they would involve and the resulting
increase in the sale price of the TR. A rough reckoning is £1 for each
page of a Standard or TR and if the TR was to be affordable, especially
to developing countries, it had to be cut. The second factor was that we
could not agree on what was appropriate to an international document
that would be translated into other languages. In the end it was decided
to leave it to NMBs to add annexes if they wish. BSI has agreed to do
this and the UK edition of the TR will include a couple of annexes.

Record-ness

There was continuing debate about when a record is a record – or per-

haps when a document or information becomes a record. Professional
theory concerning capture and registration collided with the reality that
the courts in some countries accept as records what records managers
might refer to as documents. The Standard represents a workable com-
promise in setting out the characteristics that records and records sys-
tems should possess without overtly contradicting national legal systems.
So, records are defined as “information created, received, and main-
tained as evidence and information by an organization or person, in pur-
suance of legal obligations or in the transaction of business”.
Authoritative records, however, are those with certain characteristics:
authenticity, reliability, integrity and usability (clause 7.2) and the
records systems supporting them have the complementary characteristics
of reliability, integrity, compliance, comprehensiveness and systematic
(clause 8.2).

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Terminology

ISO Standards are supposed to use authorised terminology where this

exists and depart from it only when absolutely necessary. Records man-
agement terms are included in ISO 51278 but TC 46/SC 11 found it could
not accept all its definitions. So, clause 3 contains some variant defini-
tions on which we were, eventually, able to reach agreement.

Appraisal

The word ‘appraisal’ does not appear anywhere in the Standard or the
Technical Report. This is because we could not agree what it is or who
can do it – a good example of differing national traditions. One strong-
ly held view was that appraisal is the assessment of the value of records
(or functions) for historical research with a view to determining which
should be preserved permanently. Another equally strongly held view
was that it is an assessment of the value of records (or functions) for
operational and archival purposes with a view to determining which
records should be created and, once created, for how long they should
be retained (which might be one or many years or even permanently as
archives). The solution: describe the concept and omit the word. So,
clause 9.1 (Determining documents to be captured into a records system)
and clause 9.2 (Determining how long to retain records) together contain
useful and acceptable text without mentioning the term. It was only
some months after the text of the Standard had been agreed that we
realised some of us meant different things by the word ‘retention’ … .

Having achieved consensus on the Standard at our meeting in Berlin in

May 2000 we were able to submit it to formal voting by NMBs as a DIS.
To our relief it achieved a 100% ‘yes’ vote, albeit with comments seeking
some changes. ISO rules allow a chair to omit circulation of a revised
Standard as a FDIS and to proceed directly to publication if a DIS has
received a 100% “yes” vote. The chair of TC 46/SC 11 decided to follow
this route and at the time of writing (in August 2001) the Standard is
being prepared for publication. A formal launch ceremony will take
place at the ARMA conference in Montreal on 3 October 2001.(Editor’s
note – The launch did take place with a live link to the UK PRO confer-
ence at Stratford upon Avon.) The TR achieved consensus at the
Stockholm meeting in November 2000 and, with some agreed revisions,
was issued for voting by NMBs in 2001. This was successful and, all
going well, the TR will be published towards the end of 2001.

BSI will publish the UK edition as BSI ISO 15489 later this year. The
TR will be published also, and UK purchasers will have the benefit of
some useful appendices – model policy statements – omitted from the
ISO edition. (Editors note: the Standard and TR have now been published).

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BSI will be publishing also some guides in its DISC series. Three are in
hand already, dealing with business benefits of records management (writ-
ten by David Best), performance measurement (written by Sandra Parker),
and a guide to implementation (written by Julie McLeod). Others may
follow, for example a workbook has been suggested.

The significance of ISO 15489

In one sense, the contents of ISO 15489 are less important than its exis-
tence. The fact that records managers can point to an ISO/BSI Standard
for their discipline can be used to improve the image and status of
records management in the eyes of those who know little or nothing of
the subject. So, buy it and cite it for that reason if no other.

But the Standard deserves respect for its contents as well as its existence.
It is a statement of good practice in records management which records
managers should find useful, however qualified and experienced they are.
It is also something that can be passed to professionals in other fields
when working on projects together, for example ICT professionals when
developing new records systems.

I think the Standard improves on AS 4390 in two ways in particular.

First, the internationalising process has made the Standard more suitable
than AS 4390 for the UK environment (Editor’s note: and on the same
basis potentially for other countries). The use of ‘records management’
rather than ‘recordkeeping’ as the key term enables a strengthening of
the alignment of records management with management rather than with
filing. This fits well with the conception of records management impart-
ed in current university courses and reflected in the draft code of prac-
tice under section 46 of the Freedom of Information Act 2000. In
addition, the change from the records as evidence basis of AS 4390 to
allow also for records as information works better in the UK, where
there is a general acceptance that records have value not only to provide
evidence of past decisions and actions but also to inform current and
future decisions and actions. This is now accommodated.

The second area in which AS 4390 has been improved is the teasing out
of separate characteristics for authoritative records and for record sys-
tems. This should make the text much more useful to those seeking to
develop systems with authoritative records.

Conclusion

In setting out some of the areas of disagreement above I have tried to

give a sense of what is involved in developing an ISO Standard and to

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describe its contents in general terms. Achieving consensus required

compromise by all involved but I believe it has been to the benefit of the
finished documents.

What is needed now is implementation of the Standard, assisted by the

TR and the BSI DISC booklets, to test its utility. ISO Standards are
reviewed every five years so there will be an opportunity to improve or
update it if necessary. Use it, and if you identify gaps in the present ver-
sion, or areas for updating, be prepared to inform BSI when the review
begins.

References

1. BS ISO 15489-1: Information and documentation – Records man-

agement – Part 1: General. BSI, 2001 and PD ISO/TR 15489-2:
Information and documentation – Records management – Part 2:
Guidelines. BSI, 2001.

2. In describing the Standard’s development I have drawn on reports I

prepared for BSI on successive meetings of ISO TC 46/SC 11. The
views expressed in this article are mine and not those of BSI or mem-
bers of IDT 2/17.

3. AS 4390: Records management – Parts 1-6. Standards Australia,

1996.

4. Athens was the first of a series of six-monthly meetings in such envi-

able locations as Washington DC, Paris, Melbourne, Berlin and
Stockholm.

5. BS 5454 Recommendations for the storage and exhibition of

archival documents. BSI, 2000.

6. Clauses 1-3 are common to all ISO Standards

7. DIRKS manual is available at www.naa.gov.au/recordkeeping/dirks/

dirksman/dirks.html [10 October 2001]

8. ISO 5127 Part 1: Documentation and information — Vocabulary —

Part 1: Basic concepts. ISO, 1983.

9 Draft Code of Practice on the discharge of the functions of public

authorities under Part I of the Freedom of Information Act 2000
available at http://www.lcd.gov.uk/foi/dftcp00.htm

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Author

Susan Healy has worked in the Public Record Office since 1985, for much of that
time in the Records Management Department. Before that she worked for ten
years in the National Archives of Australia in Canberra. She chaired BSI IDT
2/17 and led the UK delegation to ISO TC 46/SC 11 throughout development of
the Standard and Technical Report.

Susan Healy, Head of Information Legislation Unit, Public Record Office, Public
Record Office, Kew, Richmond, Surrey TW9 4DU. Email: susan.healy@pro.gov.uk

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