Preservation Manager: role and responsibilities
Anyone who has ever had to deal with the issues of records management and document preservation has certainly heard of the Preservation Manager. In both the public and private sectors, the role of the Preservation Manager is essential, and the Italian legislation requires that each company or institution appoint a person to hold this position.
The new AgID Guidelines, which have just come into force, have brought attention to this role and its characteristics. However, for non-experts who want to understand this role, there are many questions: Who is the Preservation Manager? What does he or she do and what skills must he or she have? That’s why we thought we’d gather some of these questions and try to provide the right answers.
Who is the Preservation Manager?
The person in charge of preservation was already foreseen in our legal system by the Technical Rules for the preservation of electronic documents contained in the DPCM of December 3, 2013 and has been reconfirmed by the new Guidelines, with very few changes.
This role can only be held by a physical person, never by a legal person: therefore, each company or entity must identify a person to be appointed for this position. The new Guidelines, however, have made it clear that private companies can choose whether to appoint an internal or external person, such as a consultant or professional. For public administrations, however, this must be an internal role. The Preservation Manager should have legal, information technology, and archival skills.
If you select this individual from within your organization, it is best to appoint a person who has the appropriate skills and a degree of decision-making power within the firm, such as the CEO, managing director, or other similar person. In fact, as we will discuss later, the Preservation Manager retains legal responsibility for the firm’s records, and this responsibility should be matched by appropriate skills and responsibilities.
What are the duties?
In summary, the chief objective of the Preservation Manager is to ensure that the company’s records undergo an appropriate preservation process, taking into account industry regulations. First and foremost, the Preservation Manager’s attention should be focused on documents that the business is legally required to retain for a period of time: primarily, invoices, ledgers, financial statements, contracts, and generally any document that has relevance from a business, tax, or fiscal point of view.
In addition, there may be other documents that a company is required to keep that are related to its business activities and to the sector where it operates: think, for example, of consents to privacy, or health documents for a health company, or others.
Finally, there may be documents that the company is not obliged to keep by law, but that it may be useful to keep, related to specific business purposes, in order to plan future strategic choices or also to protect one’s own business memory in the form of a real business archive. In fact, many companies have decided to exploit the asset represented by their corporate memory and archives in marketing activities in order to make the brand and the company’s history known through specially designed exhibitions and events. This is the case, for example, of large fashion or automotive companies, which have made their history a distinctive branding element.
The Preservation Manager should consider all of these different needs, in accordance with the firm’s intentions, and manage the management and preservation of business records accordingly.
The duties of the Preservation Manager are detailed in the Guidelines, in section 4.5. These duties include, for example, defining preservation policies and functional requirements for the preservation system; monitoring activities; generating and signing the archival package; generating and signing the submission report and the dissemination package; readability checks; drafting the preservation manual; and much more.
The list is very detailed and, at first glance, may create some agitation among companies and their managers, but, as we will see later, there is no reason to be alarmed, since most of these tasks can be easily delegated to a specialized Preservation Service who can support companies in these delicate activities.
One manager or many managers?
Another element that should be clarified is the following question: is there only one Preservation Manager, or can a company appoint more than one, to manage a specific category of documents, for example?
The rule is very clear and leaves no room for interpretation:there is only one Preservation Manager, and this role retains legal responsibility for all company records affected by preservation activities. It is therefore not possible to give this responsibility to more than one person at the same time.
However, the Preservation Manager may delegate some or most of his or her duties to others.
In the most common scenario, digital preservation is outsourced to specialized preservationists. The Preservation Manager may delegate most of his or her activities to the chosen preservationist, who is responsible for managing the preservation process. More specifically, specialized preservationists include the Manager of the Preservation Service, who receives the necessary delegation of authority from client companies and their Preservation Managers.
The Preservation Manual
Of all the tasks that fall to the Preservation Manager, the only one that can no longer be outsourced is the preparation of the preservation manual. Under the previous Technical Rules, this activity could also be delegated to a person or the chosen registrar, but the new Guidelines have changed this.
As a result, the preparation of the preservation manual remains the responsibility of the company’s Preservation Manager, who must also update it when necessary.
The purpose of the preservation manual is to provide a detailed description of the preservation process and the roles involved in the various phases of the activities, describing the infrastructure and the hardware and software architectures used.
At the same time, specialized Preservation Service Providers must also prepare their own preservation manual, describing the characteristics of their infrastructure and processes.
Therefore, when digital preservation services are outsourced, companies can use the information provided by the Conservator to prepare the preservation manual. In particular, the Preservation Manager can refer to the preservation manual prepared by the registrar in the company’s manual, or he or she can insert cross-references.
In addition, most Preservation Service Providers offer consulting services that can support their clients’ managers and provide support, where necessary, in drafting the preservation manual.
Why focus on the Preservation Manager?
As we have seen, the Italian legislature and the Agency for Digital Italy consider this role to be of central importance and attribute to it a series of well-defined obligations and responsibilities.
The protection of electronic documents is fundamental for every company. For both analog and paper records, preservation can be considered a relatively straightforward task. A few basic measures can be sufficient to ensure that analog records make it through the preservation phase unscathed, especially when they are not historical or public records that must be preserved for a potentially infinite amount of time, but rather records, such as those of private companies, that in most cases can be disposed of after a relatively short period of time. In these cases, providing suitable storage facilities and carrying out routine maintenance is often sufficient.
But computer documents, as we all know, are subject to many more risks and ensuring their integrity and authenticity over time is not a given. Hence the need for a set of rules and procedures to secure electronic documents and their legal value. The preservation of electronic documents is never a static activity. It requires structured processes, ongoing monitoring, readability checks, and transfer activities that can carry electronic documents and their value through the years.
This underscores the importance of the Preservation Manager, who is charged with presiding over and coordinating this complex process. But this task is also shared by preservation service providers who have been doing this for years and who undergo thorough checks and audits to continue to provide high quality services and offer the right support to businesses.
