Mitigating Risk and Increasing Transparency, Securely and Globally

By Andrea Donohue and Nicolette Lodico

Managing records for a global organization is complex, especially as we shift into an exclusively digital records environment and generate increasing amounts of files and data. Many organizations place compliance and risk mitigation at the fore of their records management programs and focus on properly disposing of records or locking down records they retain in perpetuity. Still, other organizations are committed to preserving a faithful record to share with the global community even though their  work receives varying degrees of scrutiny and opposition, depending on the local context. 

Such is the case at the Ford Foundation. Finding the right balance is critical for protecting our grantees, who work with those closest to the problems the foundation is committed to addressing (often marginalized voices). By blending policy, procedure, training, and outreach, we work with our staff to understand what they find archivally valuable and what security concerns they have about making those archival records available over time. With that understanding, we develop mechanisms to account for the various security and privacy issues inherent in all records and archives programs. The work and balancing act is never-ending! 

“We place the subject matter experts at the center, empowering them to be the curators of their own legacy.”

Here are four principles that guide our work in sustaining a legally compliant and security-minded records and archives management program—one that protects our grantees and partners while fostering transparency and continuous learning.

1. Context is everything

This balance cannot exist without understanding the legal and geopolitical contexts in which grantees and foundation staff work. The context is not the same everywhere, so our treatment of the record cannot be uniform.

Ford’s Information Management (IM) team works with legal experts to ensure a legally compliant records and archives program in all jurisdictions where we have offices. This program goes a step further: we must also consider the cultural and geopolitical requirements that are not typically as overt as the legislation is. Doing so enables us to create compliant retention periods and handling instructions beyond the letter of local law.

2. Not all records are created equal

Not all record material is appropriate for external use. We employ three overarching records dispositions, which enable the Ford Foundation to be as transparent as possible while managing unnecessary risk and mitigating the security concerns of the at-risk populations we serve.

  • Temporary Records have no archival value but may have legal retention requirements. We destroy or delete these at the proper times.
  • Archival Records are appropriate for external use. We send them to our external archival repository for public service.
  • Archival-Closed Records are permanent records that are not suitable for external use. We preserve these records internally.

3. The embargo period is our friend

The IM team works closely with General Counsel to develop internal and external embargo periods for all archival records. These periods range from records made available immediately to those that remain closed for 25 years. The practice serves several purposes. First, it allows information that is sensitive, in the present, to become less sensitive and more appropriate for sharing over time. It also provides much-needed perspective and enables researchers to use foundation records in a more informed context. Finally, our embargo policy provides us the flexibility to extend restrictions for certain records should the need arise—e.g., with the benefit of hindsight or as political and social contexts shift over time.

4. Managing records is everyone’s responsibility

It would be impossible for the foundation to satisfy these commitments without fostering a culture that supports our records’ rigorous management. 

At Ford, records management training is mandatory for all staff to ensure they understand the policies and their responsibilities to those policies. We place the subject matter experts at the center, empowering them to be the curators of their own legacy. That is, they are empowered to both identify what is archivally valuable and what is not appropriate for external use or too sensitive for consumption. We place restrictions on such records and revisit those restrictions over time as global circumstances change. The goal is to safeguard restricted material until the organization feels the records no longer pose a risk, after which the restriction is lifted. 

There are many ways organizations can balance their desire to manage their records, preserve their legacy, and ensure sensitive information is protected, all while telling the story of those often marginalized voices doing the work. At Ford, we have found that a combination of sound, enterprise-wide policies; an organizational culture that understands the value of archival records; and putting subject matter experts at the center allows us to maintain the right balance between being transparent and mitigating risks to the organization and the people we support.

Andrea Donohue is the Senior Manager, Global Records and Archives at the Ford Foundation in New York, N.Y. where she has worked on the digital transformation of the foundation, its policies, procedures, and systems. Andrea has also developed and manages a globally compliant records and archives management program designed to mitigate risk while preserving organizational history and increasing access to information. Andrea has a Master’s Degree in Library Science and holds certifications as a Records Manager (CRM), an Information Governance Professional (IGP), and a Federal Records Manager. She serves as a member of several international records organizations and believes in freely sharing her work to contribute to the record and archive profession’s body of knowledge.

Nicolette Lodico is the Director of Global Information and Knowledge Management at the Ford Foundation in NYC, where she leads foundation-wide programs in records, archives, and knowledge management. Her work focuses on establishing practices to increase transparency, preserve institutional memory, and contribute to historical scholarship and public discourse through the responsible management of institutional records. She also is president of the Technology Association of Grantmakers, a non-profit organization that cultivates the strategic, equitable, and innovative use of technology to advance philanthropy. Nicki is passionate about minimizing barriers to sharing and finding information and to analyzing information to reveal new insights. Her current interests include ontologies, digital curation, metadata, and machine learning. She earned her M.L.S. from the State University of New York at Buffalo.