Digitizing Records: The Importance of Validation

This is the fifth in a series of posts supporting the publication of 36 CFR section 1236 subpart E – Digitizing Permanent Records. All of the posts have been collected under the 36 CFR Section 1236 category.

In this post, we discuss validation and its importance in the digitization process.

36 CFR 1236 Subpart E includes the requirement that agencies validate their digital records. Simply put, validation is the process where agencies formally declare that their digital records are complete, accurate, comply with the standards in the regulations, and can be used for the same business purposes as the source records. 

Validation is different from quality management. Quality management occurs throughout the digitization process and involves the inspection of the various parameters of each image such as their file format, resolution, and metadata. Validation is a higher level review of an agency’s digital records and the process that were used to create them. Validation occurs when digitization is complete and must be conducted by staff that were not involved in the quality control inspections conducted during the digitization process. 

So who in an agency is responsible for validation? Due to the wide disparity in size and staffing across federal agencies, NARA does not specify one position that should be responsible for validation. NARA does suggest that Senior Agency Officials for Records Management (SAORM), agency records officers, and general counsel staff should be involved in identifying an appropriate position and developing a validation process. This process should be informed by a review of the standards in the regulation and other supporting guidance. The process should also verify that digital records were created for all of the source records and that they can be used for the same purposes as the originals.    

Once validated, the digital copies become permanent records while the source records become temporary records that can be disposed of according to GRS 4.5. The now-permanent digital records inherit the disposition of the source records and will be transferred to NARA according to the records schedule.

Validation is a key step in the digitization process. It allows agencies to affirm the quality and completeness of their digitization work, and to move to the disposition of the source records and the digital records they have created.