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Accountability in archival science Parkinson, Jane 1993

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ACCOUNTABILITY IN ARCHIVAL SCIENCEbyJANE PARKINSONB.Sc., The University of Toronto, 1983Post-Baccalaureate Diploma in Public History,Simon Fraser University, 1989A THESIS SUBMITTED IN PARTIAL FULFILLMENT OFTHE REQUIREMENTS FOR THE DEGREE OFMASTER OF ARCHIVAL STUDIESinTHE FACULTY OF GRADUATE STUDIESSCHOOL OF LIBRARY, ARCHIVAL AND INFORMATION STUDIESWe accept this thesis as conformingto the required standardTHE UNIVERSITY OF BRITISH COLUMBIAMarch 1993© Jane Parkinson, 1993In presenting this thesis in partial fulfilment of the requirements for an advanceddegree at the University of British Columbia, I agree that the Library shall make itfreely available for reference and study. I further agree that permission for extensivecopying of this thesis for scholarly purposes may be granted by the head of mydepartment or by his or her representatives. It is understood that copying orpublication of this thesis for financial gain shall not be allowed without my writtenpermission.(Signature) School of Library, Archival andInformation btudies^The University of British ColumbiaVancouver, CanadaDate April 19, 1993DE-6 (2/88)ABSTRACTLaws proclaiming freedom of information have beenintroduced in many countries in the past twenty years, creatingfamiliarity with the idea that governments can achieveaccountability by providing public access to current records.Some archivists hold the view that the preservation andaccessibility of non-current records in archival repositories issimilarly related to the principle of accountability; howeverthis idea is not widely diffused and even less accepted,primarily because the concept of accountability is imprecise andhas not been integrated into archival theory.This thesis analyses the concept of accountability anddemonstrates its relevance in the context of archival science.It provides an explanation of the relationship betweenaccountability and recordkeeping, which is found in an agent'sobligation to create, preserve and provide access to records inorder to account to the source of authority for the actionsdocumented by the records. Also, it shows the connection betweenthe concept of accountability and other administrative, legal,political and ethical values, a connection which is found in thecomplex and sometimes abstract social relationships that involvedelegation of authority. Then, the thesis proceeds to examinethe appearance of the concept of accountability in archivalliterature on issues of preservation, ownership, accessibilityand management of records, and analyses it in relation toarchival as well as administrative, political or legal concerns.Finally, the accountability owed by archivists is examined,iithrough analysis of the claims made by repositories, users andthe archival profession for authority over archives and theircare. The thesis proposes that recognition of the importance forarchives of meeting accountability obligations depends on thegeneral understanding of records as evidence of actions, andacknowledgement of an organizational and public interest in theirpreservation.iiiTABLE OF CONTENTSABSTRACT  ^iiINTRODUCTION  ^1Chapter1. THE CONCEPT OF ACCOUNTABILITY AND RECORDKEEPING ^62. ACCOUNTABILITY AND ARCHIVAL THEORY  ^32Records as Evidence of AdministrativeActivity  ^32Scholarship versus Efficiency  ^55Historical Accountability  ^82The Rediscovery of Accountability inAdministration^ 903. THE ACCOUNTABILITY OF ARCHIVISTS ^ 101CONCLUSION ^  124BIBLIOGRAPHY  132ivINTRODUCTIONFreedom of information initiatives, along with concernsabout the power of information technology and communicationsindustries, have given a high profile to issues of disclosure,particularly to questions of what information should beaccessible to the people and what should not. Much of thelimited publicity archival repositories receive follows on therelease of previously unavailable material or the discovery ofhistorical sources that shed new light on events and individualsin the public memory. Debate on issues of disclosure has helpedto define new social convictions about rights to personal privacyand to information. As information professionals, archivistssupport the public's right to know. In fact, they trace theorigin of modern archival repositories to the French Revolution,which made available to citizens the records of the recentlytoppled establishment for the first time in Europe.However, archival material is not open to the public in thesame manner as library material, which patrons expect to usefreely. On the contrary, the use, availability and evenexistence of records are controlled and limited. This is due tothe nature of archival material, rather than the ideology of thepeople who manage archival repositories. Library material isdestined for public consumption, if only by a limited segment ofthe population, and owes its existence to a desire to communicatewidely. Records, on the other hand, are rarely created forpublic dissemination. They arise from a person's need to1communicate with other persons or to document actions.' Thegreat value of records derives from the impartiality of theirunself-conscious authors. 2 But because records have been createdwithout expectation of disclosure, or fear of the public eye, itis not a straightforward matter to subsequently place them in it.Availability of records for public access is challenged byother imperatives, such as the need to protect unique documentsfrom unauthorized removal or fragile ones from damage; to protectsensitive information for reasons of personal privacy,proprietary rights or the maintenance of order and security; orto provide access only for certain uses of the information.Archivists confront problems in storing, handling and makingintellectually and physically accessible the enormous volume ofpaper records that individuals and organizations accumulate,while on the other hand they are faced with transient andmachine-readable documentation stored on magnetic or electronicmedia. As well, they must try to determine whether particularrecords are, or will be, of interest to the public, and weighttheir value against the resources available to deal with them.The archivists' attempts to resolve these obstacles to publicaccess to records are guided by archival theory, which provides acoherent conceptualization of the nature and value of archives1 In archival terminology, a person may be either a human being (a physical person) or anentity, such as an organization, which has the capacity to act legally (a juridical person).2 Archives are by-products of the conduct of affairs, rather than conscious creations byauthors, because records are created as a means of carrying out practical activities and not asends in themselves. As a result of this circumstance of their creation, archives are impartial,that is, inherently capable of revealing the truth about those activities.2and general principles for their management.In their discussions and writings on problems of modernarchives, archivists have drawn upon the concept ofaccountability to assert the importance of the right toinformation, and to highlight, as a consequence, certainprinciples of archival theory. Despite these persistentattempts, there is no identifiable body of thought on the subjectof accountability, and authors do not even cite each other withregard to it. Generally, the term is used without an explanationof its intended meaning or of its connection to archives, perhapson the assumption that such things are already understood, butmore probably because they are difficult to articulate. Suchexplanation cannot be found in disciplines such as law, publicadministration or political science, because they use the termaccountability without reference to records, a connection that iscrucial to the archival discipline. Yet accountability withinthe archival context appears to be more than popular jargon thathas been adopted by archivists, for the term has been appliedwith conviction to a variety of archival concerns such as thepurpose and value of archives, records management, appraisal,access rules and electronic records, while it is rarely used inconnection with historical or library concerns.This thesis explores the meaning of the term accountabilityas it relates to archives and archivists, traces the significanceof the concept in the different areas of archival theory, andlinks the archival concerns involving accountability to largeradministrative, political, legal and ethical issues. While the3primary focus of the thesis is accountability in the archivalcontext, archivists did not coin the term, therefore its generalmeaning and role are identified and described. In particular,the concept is distinguished from other related but distinctideas, such as liability, responsiveness and responsibility andthe nature of the concept and its place in political, legal andmoral thought are investigated. Since accountability is not apurely contemporary phenomenon, it is examined in a broadhistorical perspective to reveal its enduring aspects. This isappropriate in an archival inquiry into the subject, for whilemodern public repositories date from the French Revolution,archives themselves are as ancient as the history they document.Archival theory has both borrowed and diverged from otherintellectual disciplines. For the concept of accountability tobe central to it, it must be related to records. Thisrelationship has rarely been explained thoroughly, and the thesiswill demonstrate it through examples. The analysis then proceedsto address the role of the concept of accountability in thepublished literature in which archival principles and conceptsare expressed. Most of the writings that mention accountabilityoriginate in the United States, therefore the literature of thatcountry dominates this study. Only recently have archivists inCanada, Australia and elsewhere begun to express and disseminatetheir thoughts on this matter.Archival literature reflects the changing circumstances andinterests of the working archivists who author it. The contextin which archival ideas have developed is highlighted in this4analysis. In particular, the use of the concept ofaccountability has changed over time, and reasons for thesechanges are identified. While they are partly found in theimmediate concerns of the archival discipline, externalcircumstances have also been influential. The historicalapproach allows a broader view of the significance of the conceptof accountability, free from the contemporary preoccupations thatladen even theoretical writings.Throughout this thesis, accountability is examined as aconcept and a principle rather than a method aimed to achievecertain pragmatic ends. However, principles are meant to guidebehaviour and are articulated to persuade thought and inspireaction. The significance of examining the concept ofaccountability in archival theory is that, were it not arecognized principle, archival repositories might fail to supportwhatever rights to information it entails. This study assumesthat archivists are aware of the implications of their work andare thoughtful in bearing responsibility for the records that areor shall be in the public domain.5CHAPTER 1THE CONCEPT OF ACCOUNTABILITY AND RECORDKEEPINGRead this letter many times and keep it very safe,that you and we may use it as evidence to seewhether you have or have not acted in accordancewith what is written in it - missi of emperorCharlemagne to counts, 806 AD'A conceptual analysis of accountability needs to be basedon two presuppositions. First, there is a difference between theabstract idea or concept of accountability used for reasoning anddiscourse, and the mechanism or system which is put into place toattempt to guarantee accountability. 2 In fact, while the latteris dependent on the specific circumstances, the former is not,and can only be understood by comparing its aspects in differentcontexts and determining which are the common, essentialelements. This is a philosophical method and also a scientificone, for in order to understand gravity the effects of frictionmust be discounted. Accountability cannot exist independently ofa context, but it can be discussed that way.Secondly, there is a difference between the concept ofaccountability and the various uses of the term, since languageis often imprecise and more variable than ideas.Most words that have been used for any length of time ina language have acquired a long and sometimes intricateseries of significations, as the primitive sense has beengradually extended to include allied or associate ideas,or transferred boldly to figurative or analogical uses. 31 P.D. King Charlemaane: Translated Sources (Lancaster: King, 1987), 259.2 This thesis does not deal with mechanisms and systems, only with the records that are acommon instrument in such systems.3 The Oxford Pnalish Dictionary vol. I, x6The term accountability is used in a number of academicdisciplines with regard to a variety of concerns aboutrelationships, authority and responsibility. For example, inconstitutional law the term has been used to describe theconventions and procedures that govern the relations betweenpeople and their representatives, representatives and theirdelegates. 4 In public administration, which has been influencedmore by management disciplines than political science or law,accountability is used to mean systems for efficient, effective,responsive and responsible decision-making. Concern forprofessionalism has created an emphasis on the 'internal norms'associated with accountability of public officials. 5 Accounting,as its name suggests, was historically associated withaccountability but theories in the last century have emphasizedaccounting as provision of information for decision-making ratherthan for stewardship. However, writings on the evolving role ofpublic auditors use the term accountability to describe theirfunction. 6 The literature on educational accountability isspecifically concerned with the source of the authority for4 British authors Ian Harden, Patrick Birkinshaw and Norman Lewis have written a number ofmonographs on this theme since the mid-eighties. For a general discussion of it, see ColinTurpin, British Government and the Constitution: Text - . Cases and Materials (London: Weidenfeld &Nicolson, 1990), 75-79. See also, Ian Thynne and John Goldring Accountability and Control:  v- i -4^ I-^• ••^(Sydney: Law Book Company Limited, 1987).5 Ledivinia V. Carino, 'Administrative Accountability: A Review of the Evolution, Meaning andOperationalization of a Key Concept in Public Administration ' ^P. -Administration 27 (1983): 118-148, links the use of the term with changes in the orientation ofthe discipline.6 The classic work is E. Leslie Normanton, 'Public Accountability and Audit: AReconnaissance,  in The Dilemma of Accountability in Modern Government; Independence versusControl, ed. Bruce L.R. Smith and D.C. Hague (London: Macmillan, 1971), 311-345.7public education and the assignment of responsibility for itsresults, as well as the extent and nature of professional rightsand duties. 7 Also, literature on corporate, political or moralresponsibility sometimes uses the term accountability, giving toit various meanings. 8 Not only is the term used to describe suchdiverse issues, but authors have a tendency to distinguish amongand categorise different kinds of accountability, such as'legal', 'fiscal', 'program', 'process', 'moral' and'professional', rather than analyse the concept itself. 9 As aresult, the concept is associated with ambiguity and confusion.'°To understand the concept of accountability, it isnecessary to resolve the ambiguity, focussing as closely aspossible on identifying what accountability is and what it isnot. Rather than relying on the various uses of the term weshould begin by examining its etymology, that is, its origin andevolution. Etymology can explain how different definitions, and7 Maurice Kogan, Education Acco ntability: An Analytical Overview (London: Hutchinson, 1986),17-18.8 James T. Brummer A• ••^Z- ••l^• 40^•^"..t00(New York: Greenwood Press, 1991); Rob Gray, et al. Corporate Social Reporting: Accounting and Accountability (London: Prentice Hall International, 1987); Charles E. Gilbert, "The Framework ofAdministrative Responsibility," Journal of Politics 21 (1959): 373-407.9 This approach originated with David Robinson, "Government Contracting for AcademicResearch: Accountability in the American Experience," in The Dilemma of Accountability ed. Smithand Hague, 108-111, with his distinction of program, process and fiscal accountability.Administrative, legal, political, professional and moral are the five kinds identified in O.P.Dwivedi and Joseph G. Jabbra, "Public Service Responsibility and Accountability," in Public Service Accountability: A Comparative Perspective ed. Joseph G. Jabbra and O.P Dwevidi(Hartford, Conn: Kumarian Press, Inc., 1988), 5-7; while John Glynn lists 9 categories in Public Sector Financial Control and Accountability (Oxford: Basil Blackwell, 1987), 18.10 Robert Wagner, tc(New York: Routledge,0^0^•0^4 *0^• oomp-• 0•1989), 1; Patricia Day and Rudolph Klein, Accountabilities: Five Public Services (London:Tavistock Publications Ltd., 1987), 1.8hence different uses of the term, came about. The recently-coined noun accountability derives from the verb to account,which has its origins in the French conter: to count as well asto tell. In the fourteenth century, to account meant to reckonfor moneys given or received, to render or receive an account.Since the seventeenth century it has also meant to answer for thedischarge of duty or conduct." There are two more recent andsomewhat different meanings of the verb: to give a satisfactoryreason for, to explain, used in phrases such as to account for;and to estimate, to consider, as in to take account of.It can be seen that one of the original meanings of theverb to account, to give an account of one's actions, stillexists, and has been extended by analogy to mean to give reasonsfor any fact, act or event. But the other original meaning, toreceive an account, exemplified in Matthew 18:28, "therefore isthe Kingdom of Heaven likened unto a certain king, which wouldtake account of his servants", has been lost, although ananalogous meaning of the verb exists, as considering something.Instead of using the verb, we speak of calling to account.Calling to account should be distinguished from holdingaccountable, a phrase with wide connotations includingcontrolling, blaming and punishing, with or without a calling toaccount. "It is not possible to hold an institution accountablewithout knowledge of what it is doing" is a common observationthat makes little sense if 'holding accountable' were understood11 Words are defined by means of other words. The verb answer for means to respond tocharges, or generally; to render is to produce for inspection, submit, present, send in.9to mean 'receiving an account'. 12 For the purpose of conceptualclarity, we must distinguish accountability not only from thesystem to guarantee it, but also from the effort to enforce,compel observance, or act on it by whoever is holding someone toit. The latter is difficult to characterize abstractly, since itdepends entirely on the tactics of those with power. That thereare persons with the power to hold other persons accountable isall that can be implied by the concept of accountability.Accountability, then, is a condition attached to the personwho is to give account, not the person calling for it. GeraldCaiden has summarized the nuances conveyed by the term: "To beaccountable is to answer for one's responsibilities, to report,to explain, to give reasons, to respond, to assume obligations,to render a reckoning and to submit to an outside or externaljudgment." 13As Caiden himself, and the Oxford English Dictionary note,in common speech, accountability has become a synonym for otherterms which represent different concepts. One of these is beingamenable, meaning being subject to legal jurisdiction andreferring to the formal process of laying a charge. Another is12 Law Reform Commission,^and Adm'^v- 4!- cie (Toronto, 1982), 121.Stewart distinguishes 'the need for information, including the right to question and debate thatinformation as a basis for forming judgements, which we shall call the element of account" from'the judgement, and the action taken on the basis of that judgement-which is an exercise ofpower-we shall call the element of holding to account,' in J.D. Stewart, "The Role of Informationin Public Accountability," in Issues in Public Sector Accounting ed. Anthony Hopwood and CyrilTomkins (Oxford: Philip Allan, 1984), 15. Brummer notes these senses of the phrase 'holdingaccountable', in   so^-  esoons'b'^15.13 Gerald Caiden, 'The Problem of Ensuring the Accountability of Public Officials," in PublicService Accountability 25.10being liable, that is, "the duty of making good, to restore, tocompensate, to recompense for wrongdoing or poor judgement. 1114The status of being amenable or liable is what lawyers usuallymean when they speak of accountability. But accountability canexist without legal action or the duty of redress, as when, forexample, ministers are obliged to answer questions and explaintheir actions to Parliament. Or, there may be redress without agiving of account, as when a suit is uncontested or settled outof court. Finally, the term accountability is often attributedthe meaning of responsibility, a very complex notion. Therelationship between these two terms will be discussed further,below.While it is important to distinguish all the above conceptsin order to understand accountability, the related terms areinterchanged in common usage because the circumstances that giverise to them have many similarities. For example, legal actionsare sometimes brought against accountable persons; legalprocedures include some requirements to answer and to explain;and the notion of passing judgement is very close toaccountability. However, these similarities should not lead tothe assumption that accountability is embodied by legalinstitutions, since other elements of the judicial system, suchas the right to remain silent and the requirement that there be a14 Ibid.11substantial allegation of misconduct, are at odds with theconcept of accountability. 15As stated earlier, the term accountability means theobligation to render an account or answer for discharge of dutiesor conduct. However, the definition of the term is notsufficient to explain the concept because, for example, it doesnot say why such an obligation should exist. The conceptcharacterizes an element in human relationships which is not anobservable thing but is a state thought to exist in certaincircumstances. Few analyses of accountability have examined whatthose circumstances are, while most tend to believe that theperception of the existence of the obligation creates it, aswhen, for example, those affected by an action demand anexplanation. 16 There may be good moral, social or politicalgrounds for a requirement to explain actions to others, but it isalso understood that free persons need not justify their actions,unless they are prohibited or interfere with the rights of15 Wagner notes the distinction in Accountability in Education, 84-5. The primary role ofthe courts is "to provide a fair and just resolution of the various problems and conflicts thatare brought before them' (Gerald Gall,^ 3rd ed., [Toronto: Carswell,1990], 136). Their jurisdiction has been property and civil rights, and only very recently andin limited circumstances have administrative cases been heard. Because it is here argued thataccountability is fundamentally administrative, it should not be surprising that it is not foundin the legal system. The exception is the old action for account, which, from the thirteenthcentury could be taken by an estate owner against a bailiff who refused to render an account andallowed the sheriff to arrest the man and hold him until the account was heard by auditors. SeeChristopher Noke, 'Accounting for Bailiffship in Thirteenth Century England," Accounting andBusiness Research (Spring 1981): 137-151. See also Ian Harden and Norman Lewis The Noble Lie: The British Constitution and the Rule of taw (London: Hutchinson, 1986), 35-39, re: the absensein common law of a general duty to give reasons for administrative decisions. The courtsthemselves are scrupulous in giving reasons for decisions. 16 Robert B. Wagner, 47; Brummer, Corporate Responsibility 32-0^I!^• 044.12others, in which case what is demanded is apology, punishment orredress, rather than simply explanation. Stewart suggests wedistinguish links of account, or general duties to give reasonsfor our actions, from the stronger bonds of accountability. 17His proposal presents accountability as a relationship, and thisis incorrect because accountability is the condition of beingunder an obligation. However, it is true that accountabilityarises out of a relationship, that of delegation. 18The delegation of authority and resources for the purposeof accomplishing actions is fundamental to organized social lifeand forms the basis for the administration of affairs. 19Authority is the legitimate capacity, or the right to perform anaction and can be distinguished from power which is the means todo it, whether financial, psychological or physical. 20 There aresome actions which persons can only do themselves, but those inauthority often accomplish their purposes through deputies. Agroup of people usually finds it more convenient to select one of17 Stewart, The Role of Information," 16. Wagner also distinguishes between accounting, theprovision of explanations to others, and being obliged to account (Accountability in Education14), but he includes moral and ethical considerations as grounds for such an obligation. Thedifficulty is that obligations cannot be enforced in the absense of authority structures.18 S.S. Khera discusses this in Government in Business, rev. ed. (New Dehli: NationalPublishing House, 1977), 372, 383.19 To delegate, according to the OED is 'to commit [authority, powers, etc.] to agent.'Weber, from a sociological point of view, observed that 'every domination both expresses itselfand functions through administration. Every administration, on the other hand, needs domination,because it is always necessary that some powers of command be in the hands of somebody' (MaxWeber, Economy and Society ed. Guenther Roth and Claus Wittich, vol. 3 [New York: BedminsterPress, 1968], 948).20 Hanna Pitkin (quoting Hobbes), in The Concept of Representation (Berkeley: University ofCalifornia Press, 1967), 17. Hereafter the term 'authority' shall be used to mean both the rightand the means to do something. One must have the authority to use another's money, for example.13their number to act for them all. The search for efficiencyfinds that similar and routine tasks can be accomplished by oneperson instead of many. Or persons with wealth want someone withskill and creativity to increase it for them. All thesesituations involve delegation, which can be distinguished fromthe granting of authority or the giving of resources, as when alandowner grants permission to hunt on his land instead ofemploying the hunter. The delegate must use the authority to actfor the delegator (or principal), whose will causes the act andwho is therefore its author. The delegated person is asubstitute, charged with tasks or, in an ongoing relationship,with functions, who must not act according to his or her personalpreference but under some form of discipline. 21 Such disciplinemay be imposed from outside, or be self-imposed.A regulator may make the actual command which should becomplied with, or provide the regulated with options foraction, through the issuance of general guidelines forwhat action is expected or how a particular result may begenerated. Or instead of issuing rules, the regulatormay depend on one's value commitments (ethical,professional or similar rules) to get the desiredresult. 22These rules constitute the bounds within which delegatedactions take place. Whether they are set strictly or looselydepends on the degree of discretion given to the delegate, that21 Various terms are used to describe the accountable person, based on analogies with knowncircumstances: delegate, deputy, steward, trustee, servant or, for an organizational body,agency. The whole of the tasks is known as the competence of the agent. The authority isconferred and the tasks specified in a mandate. Pitkin discusses the notion of acting foranother, in The Concept of Renresentation, 118-9. Note that discipline means behaviour accordingto established rules.22 Carino, 'Administrative Accountability,' 133. Precedents often provide important guidesfor action and agents must have good reason for ignoring them.14is, the liberty of deciding as one thinks fit, absolutely orwithin limits. In delegation, discretion arises from trustingthe judgement (the discretion) of the delegated person and makesthe difference between a servant and an agent. But some code ofconduct, formal or informal, written or implicit, exists to guidethe agent and keep the actions from being simply arbitrary. Theform and nature of this code varies according to the individualsinvolved, their capacity, the nature of the actions to beaccomplished, and the social context, but its existence impliessubsequent evaluation, a comparison of the actions with thestandard.A person who has delegated authority to an agent has theright, and usually the interest, to know what has been done withit and to judge the action, because the delegator has caused itand its effects. Only in the delegation relationship is there abond of accountability, where the authority of the principalcreates the obligation of the agent to act according tostandards, and the entitlement of the principal to judge theaction. 23 Accountability has been associated with learningcapacity, 24 because the principal acquires knowledge derivingfrom both the receipt of information and its evaluation.Subsequent to receiving the account and evaluating it, aprincipal may take various measures: recovering the resources23 Norman Lewis suggests that, in modern society, all large enterprises acting in the publicsphere are, in effect, acting with delegated public authority and are therefore accountable("Corporatism and Accountability,  in^,st 4 0.1 .b*^, ed. Colin Crouch and RonaldDove, [Oxford: Clarendon, 1990], 80).24 Ibid.15that are due or forgiving the debt; punishing, disgracing ordismissing; rewarding; debating, revising standards ordetermining future tasks; or simply accepting, depending on thespecific circumstances. For example, Khera argues, "unless erroris in bad faith and unless it is too often repeated, delegationmust be accompanied with support for error" as a risk that shouldbe recognized. 25Where there is no discretion given to the delegated person,there is little need for accountability, since the delegate ismerely an instrument for actions determined by the principal.Notwithstanding the fact that the term accountability is oftenused in relation to oversight or control, as the opposite ofautonomy, there are ways other than calling to account toexercise these powers. Swearing of oaths, signing of contracts,direct supervision, coercion, bribes, spying or the ferreting outof facts through torture or detective work are all means ofexercising control, particularly over those who are not trusted.But allowing for discretion requires trust, and trust must besustained by rendering proof that it has not been abused. Anindividual is not accountable unless he or she acknowledges theobligation to give an account of actions. This is whyaccountability is usually associated with responsibility.The concept of responsibility has been traced to therecognition of oneself as a creative agent who is capable of25 Khera, Government in Business 381.16making a difference by one's actions. 26 This links severalmeanings attributed to the term: causing something, tasks to beaccomplished and a sense of the need to take care in one'sactions. Granting discretion means trusting that the agentrecognizes his or her responsibility, and accountability is theobligation to demonstrate that one does. Kogan writes that"accountability and authority are responsibility and powerconverted into institutional entities." 27An agent may be accountable for actions, for example bybeing required to show what expenditures were made; or for theextent to which the procedures used to carry out the actionsconform to standards, for example by being required to show thatbids were first obtained to get the lowest price. The differentkinds of accountability discussed in the literature of variousdisciplines correspond to the different standards used to judgeactions: legality, efficiency, morality, political worthiness,and so forth. While it can be argued that no one is accountablefor what he or she thinks (since we cannot think for someoneelse), one may be accountable for one's expressions, because manyactions, such as contracts or teaching, are accomplished by meansof verbal or written words. As well, an agent, who has beengiven discretion, may be accountable for the foreseeable resultsof an action and thus must be prepared not only to explain but26 Irell Jenkins, Social Order and the Limits of Taw (Princeton, N.J.: Princeton UniversityPress, 1980), 40.27 Kogan,  ^ o 4   o^30. 'Accountability assumes institutional authority tocall an individual or group to account for their actions. It is to be contrasted with'responsibility' which is the moral sense of duty to perform appropriately' (26).17also justify it, because people are "capable of knowing not onlywhat they wish to bring about but also why they wish to do so. n28The potential for accountability exists wherever there isdelegation of authority and of resources, and thereforeadministration, but the forms and degrees of its enforcementdepend on the social context and the institutions and individualsinvolved. As Harden and Lewis put it, "cogent ideas relating toorder, rule-governed behaviour, opposition to arbitrariness,looser or stronger version of accountability gain expressions indifferent ways and conjure up different expectations at differenttimes."29 In ancient Athens, officials were required to reporton their activities ten times annually to the council and weresubject to a strict judicial scrutiny every year. 3° In moderntimes, the societal right to subject government actions to publicreview was asserted in 1789, in Article 15 of the Declaration ofthe Rights of Mann, not only in order to watch over theexpenditure of tax money but because28 F.M. Barnard Self Direction and Political i&,.aitimacv: Rousseau and Herder  (Oxford:Clarendon Press, 1988), 69.29 Harden and Lewis, The Noble Tie 26.30 Robert J. Bonner, Aspects of Athenian Democracy (New York: Russell and Russell, 1933), 14-15.31 'La societe a le droit de demander compte a tout agent public de son administration' (Les Declarations de Droits de l'Homme de 1789 Textes reunis et presentes par Christine Faure [Paris:Editions Payot, 1988], 13).18a society has the right, by virtue of its sovereignty, todelegate to whom it chooses the powers it possesses.Thus, all who have been invested with any authoritywhatever, cannot be considered but as agents. 32In eighteenth-century England, Burke argued that governingauthority did not derive from the public but from ancient socialarrangements. Therefore, while the East India Company must beaccountable to Parliament, the King, Lords and Commons, "in theirseveral public capacities can never be called to an account fortheir conduct." 33 This was not because Burke's government was'unaccountable' but becauseParliament is not a congress of ambassadors fromdifferent and hostile interests; which interests eachmust maintain, as an agent and advocate...Parliament is adeliberative assembly of one nation, with one interest,that of the whole.He regarded the relationship between government and governed asone of trusteeship, not delegation, and so did not acknowledge itas one which gave rise to accountability. 34Discussion (rather than application) of the concept ofaccountability is quite recent, and is associated with itsemergence as a problem that requires conceptualization to discussand solve. The first collection of essays on the subjectreflected concern about the extent of government contracting to32 Gouges-Cartou, "Project de Declaration de Droits," (1789) in ibid., 210. Translated bythe author.33 Quoted in Pitkin, The Concept of Representation 129 & n.34 From'Speech to the Electors of Bristol,' in Hanna Fenichel Pitkin, ed. .Representation(New York: Atherton Press, 1969), 173. In Burke's moral political theory, governors who abusetheir trust are accountable to God. In a modern comparison of styles of government, Hugh Heclowrites that in Britain, 'broad areas of discretion are granted and the trustee is called toaccount for the ultimate results of his stewardship,' in 'Whitehall and Washington Revisited: AnEssay in Constitutional Lore' Politics in Britain and the United States ComparativePerspectives (Durham, N.C.: Duke University Press, 1986), 107.19quasi-independent agencies, and the difficulty of assertingcontrol in such an arms-length delegation. 35 Another concernderives from the fact that assertions of professional autonomyconflict with the idea that an accounting is owed byprofessionals and self-governing professional bodies. As well,the size and complexity of modern governments and the scope oftheir intervention in society appear to outstrip the machineryfor accountability. The variety of approaches in the literaturespring from different views about the kind of accountabilitythese circumstances warrant.However, the resolution of these problems is inhibited bythe conceptual confusion described earlier. Demands foraccountability often come from authors who are less interested inthe obligation to render an account than in making people andorganizations act as if they were going to be called to account,that is, responsively and responsibly. 36 In the field of publicadministration, accountability is considered to be "a strategy tosecure compliance with accepted standards and a means to minimizethe abuse of power and authority," that is, a technique to asserta barely acknowledged relationship of delegation. 37 Viewed thisway, accountability appears less a matter of giving an account ofactions than of behaving according to prescribed rules.35 Bruce L. Smith, 'Accountability and Independence in the Modern State,  in Dilemma ofAccountability, ed. Smith and Hague, 53.36 Pitkin, The Concept of Accountability 57-58 and 119.37^ ved  Dwii and Jabbra, 'Public Service Responsibility,' 5.20Similarly, when writers use the term to mean holding accountable,the account becomes secondary or irrelevant.For many, accountability appears to have no purpose exceptto hinder action, create unnecessary paperwork and imposeunreasonable control. Also, it is often evoked where otherconcepts might be more appropriate. For example, in theliterature that discusses educational accountability, it is notargued that parents delegate their authority to educate theirchildren and therefore are entitled to accountability in return.While taxpayers who fund the system are entitled to receive anaccounting from school boards, education professionals seem to bedebating the need to be responsive to parents, which means totake heed of them and defer to their demands, pressure, orinfluence. In another example found in literature on this topic,the submission by all citizens of an annual financial report tothe federal government should not be regarded as accountabilityfor financial activities but as the provision of information forthe purpose of computing the tax. The tax audit is to determinethe accuracy of this information, not to receive justification orexplanation for its contents. 38Conceptualization of accountability is further clouded bythe emphasis in the past on accounting for the expenditure offunds, which reflected a foremost respect for property andefficiency. This has been balanced by the articulation of new38 Wagner uses tax returns as an example of accountability (Accounylitv in Education 9)although he himself notes that the vast literature on education accountability suffers from afailure to understand the concept and its implications.21political or moral standards for action which are lesssusceptible to easy reckoning. The first of a series ofcommittees that addressed accountability in Commonwealthgovernments set a tone in trying to quantify accountable actionsand measure the unmeasurable.Accountable management means holding individuals andunits responsible for performance measured as objectivelyas possible. Its achievement depends upon identifying orestablishing accountable units...where output can bemeasured against costs or other criteria, and whereindividuals can be held personally responsible for theirperformance. 39In addition to the difficulty, or relevance, of measuringperformance, this approach has come under criticism from somepolitical scientists for its emphasis on the personal culpabilityof administrators, when what is needed is to make "questions ofpublic importance and interest... as open as possible toelectoral influence."" In Sutherland's view, accountability"should be addressed by strengthening the role of politicalideas" rather than designing systems to identify personalfailures in the civil service. 41 A recent reviewer complainedthat "the idea of accountability only as a matter of finding theappropriate scapegoat for a manifest failure is itself far too39 United Kingdom 'Fulton committee' (1964-66), quoted in Dwivedi and Jabbra, "Public ServiceResponsibility," 8.40 S.L. Sutherland, "Responsible Government and Ministerial Responsibility: Every Reform IsIts Own Problem " Canadian Journal of Political Science 24 (1991): 120.41 Ibid. Sutherland argues that under the system of ministerial responsibility, the currentminister is 'legally' accountable for any act of the crown, past or present, because that is theperson to whom grievances should be addressed, from whom explanations should issue and whoseexplanations will be judged.22narrow: most of what accountability is about is simply the rightto know what is going on." 42The difficulties in dealing with the concept ofaccountability seem to arise from the fact that it is beingarticulated in relation to rather abstract entities: officesrather than officers, functions and programs rather than tasks,constituencies rather than principals, not to mention 'thestate', 'the people' and 'society', all far removed from themaster-servant relationship. Institutional arrangements in thepublic realm are contrived to embody broad and general conceptssuch as justice, equality and democracy. Although it is a lessknown concept, accountability has a similar, metaphoricaldimension. It affirms that government consists ofrepresentation, that authority derives from a sovereign and self-determining people, and that good government does not depend on"the discovery of some device for inducing into the masses arespect for their superiors and persuading them not to use thepower of the majority to overthrow law and order." 43 In thissense accountability is asserted as a 'value' or ideal which mustbe instilled not only in government machinery but in the minds ofall who are involved. Thus, it is understood that "publicaccountability is based on the belief that the taxpayer has a'right to know', a right to receive openly declared facts thatmay lead to public debate by the citizens and their elected42 Jack Waterford, "A Bottom Line on Public Service Accountability " Australian Journal ofPublic Administration 50 (1991): 416.43 Walter Bagehot, paraphrased in Harden and Lewis, The Noble Tie 30.23representatives." 44 It then becomes less significant as a devicefor discovery and assigning blame for this or that instance ofmaladministration than as a means of supplying legitimacy andconfidence to public institutions, to "transform arbitrary actioninto the legitimate exercise of governmental power." 45 As Pitkinsays of representation, it is not the accounting for any singleaction but the overall structure and functioning of the systemthat makes accountability. 46Jean Jacques Rousseau was primarily interested in thisaspect of accountability when he warned about the appropriationof authority that accompanies the growth of representativegovernment.Imperceptibly the commissioners form a body which isalways active. A body which is always active cannot givean account of every single deed; it gives an account onlyof the principal ones; and soon it gives an account ofnone at all.'"Rather than just identifying who has done a thing and why,procedures and rules for accountability constitute a statementthat the public good is government's highest authority, and actagainst the tendency of those with power to forget, or to delude44 Government Accounting Standards Board, quoted by Robert Berne, 'Accounting for PublicPrograms,  in Handbook of Public Administration, ed. James L. Perry (San Francisco: Jossey Bass,1989), 306.45 Stewart, 'The Role of Information,  13.46 Pitkin, The Concept of Representation 221.47 From 'Letters from the Mountain' (1764). Translated in Andrew Likierman and PaulineCreasy, 'Objectives and Entitlements to Rights in Government Information   Financial Accountability and Management 1 (Summer 1985), 48.24themselves that their own interests are a sufficientjustification for their actions. 48The principle that underlies the concept of accountabilityin both its self-evident or more abstract form, that those whohave delegated their authority or resources have the right toknow what has been done with them and why, is linked to theconveying and evaluation of information. "The nature andusefulness of the information provided-its honesty and accuracy,completeness, specificity, relevance, adequacy and timeliness-have always been critical attributes of accountability." 49 Theaccount that the agent must be prepared to give, in person or inwriting, is a statement, report or description that shows, orexplains, or justifies action or inaction, and may give reasonsfor decisions and the facts taken 'into account'. The form theaccounting takes, its frequency, whether it is received by theprincipal or by another delegate, whether it involves questioningthe agent, are all variables dependent on the particularrelationship of delegation and the trust residing in it, just asdoes the form of the instructions given to an agent. For ongoingbodies, accountability required the development and refinement ofprocedures for carrying out actions and documenting them, "toensure that everything was done according to rule and in proper48 Barnard, Self Direction 70-71. Other authors on the subject conclude: 'accountabilitymust be seen in terms not of individual institutions but as a system which is woven into thefabric of political and social life as a whole...Why not concentrate less on formal links orinstitutions and engage more in civic dialogue..." (Day and Klein, Accountabilities 249).49 Frederick C. Mosher, The GAO: The Ouest for AccountabiliYit in American Government (Boulder, Colorado: Westview Press, 1979), 234.25sequence, so that administrators could account...at any timeprecisely for anything that had been done." 5°Effective institutional accountability has thereforedepended on record-making, record-keeping and access to records,and it has influenced the procedures and timing of theircreation, their form, their maintenance, their accessibility andtheir centralization. In the ancient world, 'commentarii' or thedaybooks of official activity, as well as annual accounts, weredisplayed publicly after a term of office, and remained availablein archives. 51 In Rome, Cato took steps to prevent fraud byensuring "that his subordinates recorded their financialactivities accurately, such matters as were too often permittedby other magistrates to take their course.^When literacyrevived under Charlemagne in the eighth century, he exercisedauthority over his territories by sending correspondence andinstructions out and receiving reports back. 53 European estatemanagement, whether by kings or other landowners, required theuse and preservation of records. Functionaries "centralized thescattered revenues of their territories and made them availableto their masters. In doing this, they had to keep some sort of50 E.N. Gladden, A History of puhlis, Asiministration, vol. 2 (London: Frank Cass, 1972), 75.Writing itself may have originated from the need for accountability: As levels of accountabilityfor administrative transactions were recorded with ever greater precision...writing principleswere developed to enable such precision.' M.W. Green, 'Early Cuniform,' in The origins ofWriting ed. Wayne M. Senner (Lincoln, Nebraska: University of Nebraska Press, 1989), 56.51 Ernst Posner, Archives and the Ancient World (Cambridge, Mass.: Harvard University Press,1972), 140.52 Gladden, A History of Public Adminstration vol. 1, 258.53 King, Charlemagne 27.26records and subject themselves to some sort of accounting." 54 Aswell "exact accounting required not only accurate reporting bysheriffs, but also a careful record and precise formulation ofthe orders that authorized the sheriffs to pay out certain sumsor to receive credit." 55The development of state bureaucracies in the eighteenthcentury was associated with writings that particularly emphasizedthe importance of records, in a manner that seems pedantic tothose for whom recordkeeping is so routine as to be uninspiring.Yet,praise and prescription of records, inspection andreporting as instruments of control are to be encounteredin nearly all eighteenth-century writings onadministration...The purpose of most of these devices wasto provide the managers or directors of an organizationwith information about their subordinates' behaviour andits results. 56Jeremy Bentham wrote in great detail about the kinds of books andrecords that must be kept in effective management, and "theresponsibility to prepare and publish reports or to allow openaccess to certain documents was a common feature of most of hisschemes." 57 J.S. Mill similarly insisted that the machinery ofgood government should require that "a correct and intelligible54 Joseph R. Strayer, so o- w-o -^   ^ ^o -^ (Princeton, NJ: PrincetonUniversity Press, 1970), 29. As historians of accounting have noted, such records did not allowestate owners to determine the profitability of their enterprise or the costs associated with anyparticular activity (Nokes, "Accounting for Bailiffship,' 147-149).55 Strayer, Medieval Origins, 41.56 L.J. Hume, Bentham and Bureaucracy (Cambridge: Cambridge University Press, 1981), 50.57 Ibid., 151.27record" of its actions be kept58 and wrote elsewhere thata security against bad measures worth all others puttogether, and essential to the complete efficacy of everyother, is the obligation of writing down the reasons ofwhatever is done. Our vast empire in India is governedupon this system. 59Of course, the Indian government prepared such documents for "thecontrolling authorities in England" rather than the Indianpeople.When the British House of Commons sought to exercisesystematically its authority over the administration ofgovernment, it found it was necessary to reform the record-keeping and audit machinery so that accounts could be "producedto the public with details intelligible by all. .60 The reformsincluded abolishing the old system whereby officials wererequired to account personally to the Exchequer for sums receivedand in which accounts might remain unheard for thirty years ormore. 61 Parliament desired a view of government expenditure on aregular basis, so it insisted that accounts and records betreated as public property, not as the personal effects of58 J.S. Mill, 'Considerations on Representative Government" (1861), in Collected Works vol19, Essays on Politics and Society ed. J.M. Robson (Toronto: University of Toronto Press, 1977),391.59 Mill, "Taylor's Statesman,' Essays 628.60 George Rose (1806), quoted in J.E.D. Binney British Public Finance and Administration1774-92 (Oxford: Clarendon Press, 1958), 254.61 Basil Chubb I'^• I^• 0 • • a a o^ •-Commons (Oxford: Clarendon Press, 1952), 15; Binney, British Public Finance 246. The problem ofthe delay in accounting determined reforms in France in the period leading up to the revolution.See J.F. Bosher, "French Administration and Public Finance in their European Setting,' in The NewCambridge Modern History vol 8, ed. A. Goodwin (Cambridge: Cambridge University Press, 1965),589.28officers to be taken with them wherever they went, and that therebe "Order and Regularity in making them up, and keeping them,which should be strictly adhered to in every Office ofAccount."62 The position of Comptroller and Auditor General wascreated with access to departmental accounts and the right toquestion officials, and who reported the findings of the audit tothe House. Eventually, the form of the accounts wasstandardized, and information recorded in such a way as tofacilitate accountability for funds voted by Parliament ratherthan for sums given to individuals. So, wooden tally sticks wereabolished and expenditures were assigned subjectively to'votes'. 63 It also became standard practice for departments topublish narrative reports to Parliament, and reports such asthose of the factory inspectors were printed and circulated."However, these measures towards the accountability of theadministration to Parliament and the public were countered bygovernment secrecy, enforced by the Official Secrets Act. 65 Onlyrecently has this secrecy been undermined by access toinformation legislation that allows the general public, and not62 Great Britain. Parliament. House of Commons. "Fifth Report of the CommissionersAppointed to Examine, Take and State the Public Accounts of the Kingdom' (1781), in House of -^ 0,^ .0-^t^of -- 0 0 -0 .^vol. 41, ed. Sheila Lambert (Wilmington,Delaware: Scholarly Resources Inc., 1975), 15. When the Commission tried to draw up a view ofthe finances it was sorely inconvenienced by dispersal of records throughout the country with thevarious officials.63 Chubb, The Control of Public Expenditure 44.64 Patrick Birkinshaw, Freedom of Tnforma: The Law. the Practice and the Ideal (London:Weidenfeld and Nicolson, 1988), 69.65 Ibid., 71-75.29just the Auditor General (or more recently, the Ombudsman) toinvestigate government activities through scrutiny of records.Freedom of information initiatives have other purposes thanaccountability, such as allowing those with grievances to preparea case. But it has also been argued that access to informationlegislation will encourage more accountable government."Records made in the course of activities, rather than thoseproduced specifically to report, are recognized as valuable forall accountability purposes because of their impartiality andvalue as evidence, and because they allow every transaction to beshown and explained. As well, auditors are familiar with the wayin which procedures are documented in records.Tests of compliance or accuracy involve inspection of theevidential documents for signatures, initials, auditstamp or similar indications to determine who performedthe procedure and to evaluate whether such performancewas properly authorized. 67While there has been a great deal of attention givenrecently to obtaining simple access to records of publicorganizations, the need to prepare, organize and preserveoperational records in order to facilitate accountability hasbeen almost unrecognized. For example, judicial reviewmechanisms in the United States require courts to wade through alarge body of not entirely relevant materials collected together66 One American author has pointed out that in general, information access is tied toprivate rights rather than to the public role...Individual liberty rather than public sovereigntyis the constitutional basis for access to information' (David Sadofsky Knowledge as Power: Po]itical and Legal Control of Tnformatton [New York: Praeger, 1990], 43).67 Elise G. Jancura, 'Electronic Data Processing and State Audit,' in State Audit: Developments in Public Accountability ed. B. Geist (New York: Holmes Meier Publishers, 1981),242.30by the agency to prove that its decisions were made on a soundbasis. Yet few have argued with William Pedersen that proceduresare needed for "compiling an informal rule-making record prior tothe adoption of the rule that will also be the record forjudicial review." 68Doreen Wheeler has noted "there are many informationhandlers who do not appreciate the evidentiary value ofrecords," 69 although this is what is essential foraccountability. In particular, designers of managementinformation systems seem to conceive the role of records in thesame way as Louis XIV did, "if only the government machine couldsupply the exact information, the royal common sense could bedepended upon to do what was needed." Butthis doctrine cannot appear other than naive, for evenwhen the initial complexities of administering have beenbrushed aside, as they have so often been by pundits,there is still the problem of ensuring that execution isboth expeditious and in conformity with the decisionsreached at the top. 7°Records are an important instrument of the 'account' thatfulfills accountability and on which knowledge and evaluation ofthe performance of our delegates can be made. Therefore, it isimportant to examine the relationship between the concept ofaccountability, records, and archival theory.68 William F. Pedersen, "Formal Records and Informal Rulemaking " YaJe Law Journal 85 (1975),88.69 Doreen Wheeler, review of Management of Recorded Information in Archives and Manuscrints18 (1991), 263.70 Gladden, A History of Public Administration vol. 2, 150.31CHAPTER 2ACCOUNTABILITY AND ARCHIVAL THEORYRecords as Evidence of Administrative ActivityRecordkeeping is an important means of meeting anobligation of accountability because records are evidence, or an'outward sign', of the performance of the actions for which anaccount is owed. Records do not merely provide information,which may be available from many other sources; they are also atangible trace of the transactions they were created toaccomplish, and, when set aside for preservation, they constitutean agent's written memory and first-hand account. Records arecreated in accordance with procedures and forms which testify tothe relationship of delegation, reinforce the standards whichapply to the agent's actions, or acknowledge the successfuldischarge of an accountability obligation. An obvious example isoffered by financial records, which have always served a strictaccountability. Information about the activity may be summarizedin a narrative or statistical account, but the original documentswhich authorized and accomplished each transaction, and fromwhich the information has been drawn, must be preserved to allowfor potential review. Individuals acting in a delegated capacityare usually reluctant to destroy evidence of their activities(unless of course, there is something they would like toconceal), because the actions, and their consequences, may bequestioned. 11 Laws that require the preservation of records for a limited period of time are usually seenas important because they also authorize destruction of records.32The complexity of twentieth century bureaucraticorganization, and modern values such as individualism oftenundermine awareness of accountability and the recordkeeping thatsupports it. For archivists, responsible for the preservation ordestruction, concentration, arrangement and description, andprovision of access to archival documents, the concept ofaccountability can help in understanding the context in whichrecords are created, their evidential qualities, and their roleand value in administration and society. The use of the conceptin archival theory has, quite naturally, reflected the extent towhich it has been part of the administrative or social thoughtand practice of the day. But its employment has also beenlimited to writings which emphasize the importance of records asproducts of administration rather than as sources for scholarlyresearch.Archivists often regard archives almost exclusively assources for the study of history, rather than as instruments ofadministrative action and the foundation of accountabilitysystems. The creativity and intellectual effort of scholarshipare more highly esteemed than a successfully functioningbureaucracy. As well, records creators instinctively regardtheir affairs as confidential, so that making even very oldrecords publicly available may require, as Hugh Taylor put it,sundering them from their roots and labelling them 'historical'. 2Archival theory since the nineteenth century has wrestled with2 Hugh Taylor, 'Information Ecology in the 1980's ' Archivaria 18 (Summer 1984): 26.33the metamorphic character of records, not for intellectualstimulus, but to enable archivists to treat appropriately thematerial in their care. Nineteenth century European repositoriesoften tried to meet the needs of their scholarly clients byadopting library techniques and classifying archival items bysubject, until an archival theory emerged which opposed thispractice, on the grounds that archives are groups of relatedrecords which, unlike other documents such as books, have anintegrity as the evidence of activity preserved by thoseresponsible for that activity. 3 As Ernst Posner observed, thetwo fundamental principles of archival science, respect des fondsand original order, stress the primacy of the administrativeorigins of records over their scholarly uses. 4 In fact, theformer requires archivists to focus on the structure andresponsibilities of the agency that created the records and thefunctions which they served, rather than on their subject contentor possible historical uses; while the latter protects theadministrative filing system, designed by the organization toserve its own structure and functions, against the varioussubject arrangements that historians might prefer.3 Evidence is discussed in Heather Heywood, Aooraisina Leaal Value: Contents and Issues (Master of Archival Studies thesis, University of British Columbia, 1990), 53; with regard to thereliability of accountable records creators, 61-63. On the German debate about whether archivesshould be allied with libraries or registries, and the status of history in the nineteenthcentury, see Richard Klumpenhauwer, Contents of Value in the Archival Aonraisal Literature: An(Master of Archival Studies thesis, University of BritishColumbia, 1988), 24-5, 36-41.4 Ernst Posner, 'Some Aspects of Archival Development from the French Revolution," inArchives and the Public Interest, ed. Ken Munden (Washington: Public Affairs Press, 1967), 32.I34While Hilary Jenkinson argued that, by conserving theevidential qualities of records, archivists were also protectingtheir value to scholars, Muller, Feith and Fruin seem hardly toacknowledge the interest of scholarship at all. Fruin isreported to have said that, "archives are designed in the firstplace to clarify the administrative activities of governmentagencies." 5 Neither Jenkinson's, nor the Dutch archivistsmanuals, 6 refer to the concept of accountability by name, howeverits features, as well as the principles essential to itsmaintenance in practice, can be recognized in references theymake to the administrative context of records creation andpreservation. For example, in attempting to resolve the questionof what constitutes a fonds, the Dutch archivists argued that thedecision-making independence of the record creator should be themain criterion, because those who are independent preserve theirown body of records for their own reference, while subordinatecommittees and officials create records for the information andcontrol purposes of the larger administration.' Thus asubordinate committee will not keep resolutions or minutes, whichconstitute the backbone of a fonds, but will produce reports forthe accounting it owes to the superior agency. Such reports will5 Quoted in T.R. Schellenberg Modern Archives. Principles and Techniaues (Chicago:University of Chicago Press, 1956), 189.6 Hilary Jenkinson, A Manual_sj Archive Administration (London: Percy, Lund, Humphries, andCo. Ltd, 1937); S. Muller, J.A. Feith and R. Fruin Manual for the Arrangement and Description ofArchives (New York: H.W. Wilson Company, 1968). Muller, Feith and Fruin will hereinafter bereferred to in the text as the Dutch archivists'.7 Muller, Feith and Fruin, Manual, 57, 135-6.35only be preserved as incoming documents in the fonds of thesuperior body. 8In another example, the Dutch manual refers to theimportance of understanding accounting records and procedures:"The closing of an account is a double transaction; theaccountant renders an account to his superior and is at the sametime relieved of responsibility for it; both parties thereforeneed to be put in possession of a copy of it." 9 Journals ordaybooks which served as the basis for the account were rarelypreserved "because they had lost their significance after theclosing of the account" and because they were considered privatepapers of the accountant. The same Manual also observes that thedocumentary form of minutes is a feature of accountablegovernance. Such records became common after 1795 when "the mencalled to the government by popular choice attached importance tohaving their words in the transactions of their boardrecorded. "10Hilary Jenkinson, in his Manual for Archive Administration,particularly stressed the concept of records as evidence, and heonce defined the 'archivists creed' as "the sanctity of theevidence." 11 Archival documents accumulate because of the needfor executive or administrative control and are therefore8 Ibid., 137-9. Complex hierarchies have resulted in fonds within fonds.9 Ibid., 202.10 Ibid., 197.11 Hilary Jenkinson,  British Archives and the War   American Archivist 7 (1944): 16.36impartial, authentic and unique evidence of the activities of thecreating agency. An understanding of the records creator and thepurposes the documents served is necessary to the protection oftheir archival characteristics. Jenkinson observed that alladministrators preserve firstly, originals of writteninstructions or information received; secondly, copies of similardocuments issued; and thirdly, memoranda or diaries of their ownproceedings. However, he insisted that such archives were purelya "convenient form of artificial memory" on which anadministrator "relies for the support of his authorityun ratherthan also for support of accountability. But his own example of'the archive history of the Exchequer of Receipt' revealed thatofficials have always preserved records partly to meetaccountability obligations to others in their own administration:When [the Exchequer] paid out it kept the King's writwhich had authorized the payment. These foils and breviawere its Archives, and could be produced for thesatisfaction either of itself or of the scaccarium attimes of audit. 13Jenkinson believed that archives are unbiased because archivemakers are indifferent to the judgement of 'posterity'. Butaccountability necessarily creates awareness of the potentialjudgement of others. In the second edition of the Manual,Jenkinson acknowledged as a problem the anticipation by officialsof criticism of "the conduct or views which the writing reveals."Not only does such self-consciousness threaten the impartiality12 Jenkinson, yanual 23.13 Ibid., 226.37of the records, "we have to recognize the possibility that theactually responsible administrator may seek refuge in methods ofcommunication (there are now plenty at his disposal) which leaveno written remains. ..14 The possibility of 'gaps' in thehistorical record because of a fear of criticism has beenlamented by historians and archivists ever since. It is aconsequence of the fact that, in the twentieth century, recordsare used for accountability in politics. 15European archival theory, by stressing that archives mustbe understood as products of administration, encouraged anawareness of the accountability that naturally results from thedelegation of authority and of the use of records in achievingit. In applying this perspective to their work of arrangementand description, North American archivists have also used theconcept, without articulating it, to interpret the purpose,significance and provenance of the records in their care. 1614 Ibid., 154-5.15 The use is particularly related to the competition for power and the spoils of power thatconstitutes modern political life. Those who have confidence in the rightness of their views orlegitimacy of their actions do not fear criticism.16 Examples abound in published archival studies of records: "The Governor was required tomake all his records and correspondence available for the inspection of the General Assembly,'Robert W. Scott, 'Governors Records: Public Records," American Archivist 33 (1970): 7; Agents ofthe Canadian Immigration Branch "were required to keep a log, showing inquiries received andaction taken, and every few months they were required to submit extensive reports to theMinister..." Patrick A. Dunae, 'Promoting the Dominion: Records and the Canadian ImmigrationCampaign, 1872-1915 ' Archivaria 19 (Winter 1984-85): 77. Two very interesting articles that donot discuss so much as reveal the complexity and various forms of recordkeeping foraccountability are Bill Russell, 'The White Man's Paper Burden: Aspects of Record Keeping in theDepartment of Indian Affairs, 1860-1914,' Archivaria 19 (Winter 1984-5): 50-72; Peter J. Wosh,'Bibles, Benevolence, and Bureaucracy: The Changing Nature of Nineteenth Century ReligiousRecords,' American Archivist 52 (1989): 166-178.38Some North American writers on archival practice adoptedthe European theories in the twentieth century, and turned theirfocus to the administrative role of records. Margaret CrossNorton explained the value of government records in terms oftheir administrative context and legal importance: they are "usedto justify an official action, to record proceedings, to explainand record policy decisions, and to establish rights under thelaw." 17 She insisted that archivists should not be scholars, butpublic officials "bound by law to protect the integrity of thoserecords in such a manner that their value to the individual andgovernment shall not be impaired." 'Historical' archives mayappear to have no value for current affairs, but "that is notrecognized by law and does not release the custodian from hislegal and moral responsibilities. 1118Among those responsibilities is the preservation ofevidence of the functioning of agencies. The concept ofaccountability entered Norton's writing through her discoverythat agency officials tended to think only of their own personalreputation when setting aside records for preservation, so thatdetailed financial records were kept but not materials such ascorrespondence and memoranda which often contain "too muchdangerously controversial material." 19 Norton saw that democracyhad implications for the care of public records, though this was17 Margaret C. Norton, Norton on Archives: The Writings of M.C. Norton, ed. Thornton W.Mitchell (Carbondale: Southern Illinois University Press, 1975), 56.18 Ibid., 2619 Ibid., 9.39largely a matter of ownership:In a monarchy or totalitarian system of government thepeople are creatures of the state, and the records ofgovernment belong to the rulers not to the people. In ademocracy on the other hand, the people delegate thefunctions of government to their officials who do not ownthe records which result from their activities but merelyact as custodians. 2°Only democratically elected representatives could authorize thedestruction of public records and they must be "open to anyperson applying to see them...except where the law specificallyexempts certain records from public inspection as being of aconfidential nature." 21While the concept of accountability can only be glimpsedthrough Norton's writings on the administrative and societalcontext of American public records, the idea was taken up andextended by archivists within the United States NationalArchives, who dominated North American archival theory until the1960s. At its founding, the priority of the National Archiveswas to serve the administrative and legal needs of the federalgovernment: "In determining what records it should accession andpreserve, its primary consideration is their value to theGovernment. Any other consideration is secondary andincidental. u22 In writing his annual reports to Congress, the20 Ibid., 135.21 Margaret C. Norton, 'Some Legal Aspects of Archives' American Archivist 8 (1945): 7. Shealso wrote that 'the knowledge that information can be obtained only by going through certainformalities also acts as a definite check to sensation mongers' (7).22 National Archives of the United States, Annual Report 3 (1936), 5. While the distinctionbetween 'primary' and 'secondary' persisted with reference to values, it has not with referenceto priorities.40National Archivist presented a grand and optimistic evaluation ofarchives as "preserving the record of human progress," but henoted at the same time that records "account for the expenditureof billions of dollars, document the rights and privileges andobligations of millions of people, show how a mightyadministrative machine works, and record for the impartialjudgment of history the aspirations, failures and successes ofthe nation."23 The U.S. federal government rapidly expandedduring the 1930s and 1940s and records proliferated. Archivistssought to encourage better recordkeeping and to reduce the volumeof records, both endeavours requiring a focus on theiradministrative context. Solon Buck argued that "the NationalArchives must inevitably be concerned with the creation,arrangement and administration as well as with the appraisal,disposal, and preservation of Government records. 1124 The RecordsAdministration Program was an important initiative of the early1940s, and archivists such as Helen Chatfield of the UnitedStates Treasury became specialists in the field. Chatfieldtaught courses to National Archives staff on "The Role of Recordsin Administration" and "Principles of Records Administration," 256.23 Annual Report 11 (1944),24 Annual Report 7 (1940), 1.25 Donald McCoy The National Archives: America's Ministry of Documents, 1934-1968 (ChapelHill: University of North Carolina Press, 1978), 100.41combining the archival theory of records as evidence with thescience of public administration. 26At the same time as archivists were developing an interestin records administration, accountability became an explicitissue of American public administration, and therefore ofarchival theory about records as evidence of public actions. Therapid expansion and decentralization of government that createdchallenges for the National Archives was an even greater problemfor President Roosevelt, and he appointed a Committee onAdministrative Management in 1937. The public administrators whoformulated the 'Brownlow Report' identified "rapid institutionalfragmentation coupled with confused lines of authority" as thesource of difficulties, and advocated, in addition to efficiencyand economy, "genuine accountability of the Executive Office tothe Congress through adequate audit and thorough generalsupervision of broad policies of fiscal and otheradministration." 27 The report advocated a strong, centralized,active but responsible government. "The times demand bettergovernmental organization, staffed with more competent publicservants, more free to do their best, and coordinated by anExecutive accountable to the Congress... "28 Rooseveltenthusiastically endorsed the report and the Bureau of the Budget26 A published example of this is Helen Chatfield, The Problem of Records from theStandpoint of Management ' American Archivist 3 (1940): 93-101.27 United States. President's Committee on Administrative Management geport of theCommittee (Washington, 1937), 52.28 Ibid., 53.42in the Executive Office of the President became a central agencyfor achieving both control over administration and accountabilityto Congress.The Second World War provided another impetus to bring theconcept of accountability into archival thought. As Donald McCoyexplains it, the American Historical Society in 1942 sponsored aconferenceof the scholars and government officials most interestedin recording the nation's war effort. Word of thismeeting reached President Roosevelt, who enthusiasticallyrequested the Budget Bureau on 4 March to establish 'acommittee on records of war administration' withrepresentatives from scholarly societies and federalagencies. Roosevelt hoped that such a committee wouldstrengthen the Budget Bureau's endeavors both inimproving public administration and in 'preserving forthose who come after us an accurate and objective accountof our present experience.' He also urged war agencyofficials to cooperate in this venture and to keep theirrecords systematically. 29The committee included historians, political scientists andpublic administration scholars and had as one of its goals "toencourage federal agencies to 'maintain records of how they aredischarging their wartime duties." 3° Of course, the committeeworked closely with the National Archives.The connection between these initiatives and archivaltheory can be seen in a paper by Fritz Morstein Marx, a political29 McCoy, National Archives 135.30 Ibid.^Canada attempted a similar program after the Second World War, and the firstorganized records management by the federal government was also associated with the preparationof accounts of wartime activities of departments and agencies. See W.E.D. Halliday, The PublicRecords of Canada: Recent Developments in Control and Management " American Archivist 13 (1950):105.43scientist who joined the Bureau of the Budget during the war. 31Morstein Marx's essay on "The Role of Records in Administration"was presented at the Society of American Archivists (SAA) meetingin 1946, and published in the American Archivist. It reflectedthe concern among the public administrators who had worked in theBureau of the Budget for securing administrative and politicalresponsibility as required by the Brownlow Report, 32 but it alsospecifically focussed on the use of records:In any organization governed by the principle ofresponsibility, both planning and action must be a matterof record. This is axiomatic. Unless there is a way ofreconstructing the genesis of past deliberations anddeterminations, responsibility may exist in name but isnot insured in fact...Only by preservation of asatisfactory record of the events and considerations thatled up to a given decision can those sharing in it bemade to answer for their actions. A complete record isthe most objective reporter, and hence the most effectivemeans of exacting responsibility. This is also attestedby the fact that the simplest maneuver to escaperesponsibility has always been the manipulation or evendestruction of the record.To put it differently, one of the essentials ofresponsible administration is transparency of theadministrative process in terms of both what is going ontoday and what has gone on before. In the realm ofgovernment, the requirement of transparency relates topolitical as well as managerial needs. 33Representative democracy depends on various mechanisms to secureopen government and public participation, including31 Significantly, Morstein Marx, like Ernst Posner, was a European intellectual whointroduced "broader European attitudes and perspectives into American political science" (RichardJ. Stillman, "Changing Patterns of Public Administration Theory in America," in Public  v-, ed. Joseph A. Uveges, Jr. [NewLOU I^.t^ ! .010.^O-0^I^ 4 - WeeYork: Marcel Dekker Inc., 1982], 25).32 See in particular Fritz Morstein Marx, ed., Elements of Public Administratiorl (New York:Prentice-Hall Inc., 1946).33 Fritz Morstein Marx, "The Role of Records in Administration   American Archivist 10(1947): 241.44"accountability of the executive branch" through "a minimum ofreasonably well-understood procedures for drawing specificinformation from governmental officials." Such information mustbe based on records, since,it would amount to a defeat of legislative inquiry shouldthey be free to make up their stories as they saw fit.If they could not be pinned down to incontrovertiblefacts, their explanations would be of little value. Thusthe state of administrative records is of vastsignificance to the efficacy of democratic control. 34Accountability was also an administrative necessity.Morstein Marx argued that the ability to make informed decisionsalso requires a record system that supplies complete, timely andaccurate internal information. Accountability is blocked by alack of established routines or procedures for creating records,or by "the reluctance of policy-determining officials, especiallypolitical appointees who come and go, to allow all of theevidence of their own activity to become part of their agency'srecord system."35 Morstein Marx suggested records officers setdocumentation standards and provide reference services to policymakers because they are important "custodians of the evidence oftheir agency's thought and action." 36Echoes of these ideas can be found in other literature ofthe same period. Phillip Brooks wrote in 1949,34 Ibid., 242.35 Ibid., 244-5.36 Ibid., 247-8.45records are the means by which public officials in ademocracy are accountable to the people. They are toolsof administration, the memory of an organization, theembodiment of experience, protectors of legal rights andsources of many kinds of information,and "they merit real attention if good government is to berealized." 37 The National Archivist Wayne Grover, in a 1950speech to the American Historical Association, used the term toreassure the audience that the federal government had the mostliberal access provisions in the world, arguing "we have aGovernment that is accountable to a free and democratic peopleand is reluctant to cherish secrets beyond the bounds ofnecessity and propriety." 38 The notion that archives servepublic accountability also appeared in the work of a 1952committee of the National Archives, whose report identifiedmodern archives as source materials for "regulating the activityof government officials and agencies." 39The concept of accountability and role of records thatMorstein Marx introduced are most evident in the work of TheodoreSchellenberg, whose writings still form the basis of NorthAmerican archival theory.^Schellenberg promoted the scholarlyand research purposes of archival repositories but he alsoidentified "the importance of public records in defining varioussocial, economic, and political relationships...public records37 Phillip Brooks, Public Records Management (Chicago: Public Administration Service, 1949),1; Morstein Marx and Brooks were quoted extensively by Pernendu Basu in 'Why Preserve Records?'Tn.dian Archives 3 (1949): 88-95, republished in V-^:- •^Wi.^- ,-^(New Dehli,National Archives of India, 1960), 16-25.38 Wayne C. Grover, The National Archives and the Scholar,' yilitary Affairs 15 (1951): 10.39 Cited in Schellenberg, Modern Archives 116.46obviously define the relations of the government to thegoverned. i 40 While this referred mainly to protection of therights and privileges of citizenship, elsewhere in ModernArchives there are references to the accountability that showsthat rights and privileges of government have not been abused.Schellenberg relied on European theory to explain thedifference between library and archival materials: "archivesmust have been produced or accumulated in direct connection withthe functional activities of some government agency or otherorganization...Their cultural values are incidental... 41 Archivalmethods must preserve the integrity and evidential value ofrecords, by maintaining their provenance and original order andproviding the basic information on the administrative andfunctional origins of the records that is necessary to revealtheir significance. 42 Often their origin resides inaccountability. In an example of archival description,Schellenberg cited a National Archives Guide entry which began,"the consular posts are usually represented by such items asinstructions from the Department, instructions from thesupervising post, and copies of despatches and reports tothem."43 He also discussed the accountability function of recordsdirectly, noting that they are "needed to transmit from above the40 Ibid., 9.41 Ibid., 17.42 Ibid., 187-8, 206.43 Ibid., 207.47policies and procedures that are to be followed, and from belowthe reports of accomplishment and performance, and to record allphases of the government's dealings with the particular partiesinvolved. H44Having been created and preserved partly to meetaccountability in the administration of public business, thevalue of archives stems in part from the continuing requirementfor accountability of government to the public. Schellenbergargued that records providing evidence on past "organization,functions, activities, and methods of procedure are indispensableto the government itself and to students of government" for,among other reasons, "they contain the proof of each agency'sfaithful stewardship of the responsibilities delegated to it andthe accounting that every public official owes to the people whomhe serves." 45 Therefore, "no archivist is likely to questionthat evidence of every agency's organization and functioningshould be preserved" and appropriate records should be kept"regardless of whether there is an immediate or even a forseeablespecific use for them.i 46 Particular categories of records thathe identified as important were policy records, which constitutethe authority and procedural guidelines by which theresponsibilities of the agency were defined and directed, andreports. With respect to the bulky operating records, he44 Ibid., 38.45 Ibid., 140.46 Ibid., 140-1.48believed that few of them needed to be preserved foraccountability: "Normally most of the significant evidencerelative to the operations of an agency is relayed upward throughstatistical or narrative reports, through correspondence andmemoranda, and other summary records." 47 However, he elsewhereinsisted that "periodic reports...are an important but aninadequate record of accomplishment" being a too brief anduncritical account of highlights, similar to officialhistories. 48 The distinction he was making, though he did notaddress it directly, was between the completeness and reliabilityof internal reports, produced to meet administrative ormanagerial accountability, and reports on the direction and theexecution of the whole agency and its major programs, created forpolitical accountability.Schellenberg pointed out that those in the lower levels ofan administrative hierarchy are subject to fairly stringent,procedurally defined accountability as part of routinemanagement. Firstly, their activities are usually "conducted inaccordance with orders, regulations, manuals of procedure, andother directives." Secondly, as Schellenberg quoted PhilipBauer, "significant variations of policy, methods, or procedureand notable occurrences usually manage to get themselves relayedupward through reports, correspondence, and complaints or else47 Ibid., 146.48 Ibid., 246-7.49fail to get into the records of the subordinate office." 49 In anorganization with an adequate and effective reporting system,"performance will be recorded in narrative and statisticalreports for administrative purposes-to evaluate progress, toformulate or revise policies and procedures and the like." Sincemanagement created a reliable reporting system to supply theinformation necessary to its work, archivists and subsequentusers can rely on it as well and "such reports often serve as anadequate substitute for vast quantities of detailed records onroutine operations." 50Schellenberg's argument implies that archivists ought toevaluate the adequacy and effectiveness of an agency's internalreporting system before destroying the operating records. Thisargument was well expressed in an article by Robert Shiff on therole of records management in business, published in the sameyear as Schellenberg's Modern Archives and "The Appraisal ofModern Records." Shiff referred to the accountability role ofrecords and linked it to their quantity:[They] must provide a complete record of manytransactions, and they must provide strict accountabilityfor all phases of an operation. Unlike belles-lettres orprivate records, business papers must encompass a vastamount of detail on a daily operating basis. 51Routines and procedures are necessary to ensure accountability in49 T.R. Schellenberg, 'The Appraisal of Modern Public Records " national Archives Bulletin 8(Washington: National Archives and Records Service, 1956), 253.50 Ibid., 252.51 Robert A. Shiff, "The Archivist's Role in Records Management^American Archivist 19(1956): 116.50agencies with a large volume of transactions and 'armies ofpersonnel'. Minutes, memoranda and reports provideaccountability for decisions while elaborate accountingprocedures have evolved for financial planning and auditing. Thebulk of these records have only short-term value, however thepreservation of an archival core is important to document andprove the value and legitimacy of business in society. 52Executive government officials, while theoreticallyaccountable to the public or its representatives, are often freefrom the routine scrutiny that characterizes administration.Management actions, being general and discretionary, are lessamenable to rules and procedures of accountability than arespecific and routine operating transactions. As well, reportsfrom this level are for political and public relations purposesand may suffer in accuracy and completeness. But the degree ofaccountability of the office depends on the degree ofresponsibility, so that senior officials are in fact under agreater and longer-term obligation to account for their actionsthan those lower on the hierarchy, and treatment of their recordsought to reflect this. This was clearly understood bySchellenberg, who explained that the evidential values of publicrecords "largely depends on the position of the office thatproduced them in the administrative hierarchy," and the degree ofdelegation of responsibility in the agency. 53 The importance of52 Ibid., 115-116.53 Schellenberg, 'Appraisal,' 249.51the records as evidence is a direct reflection of the importanceof the responsibilities they document. "Of fundamentalimportance to the archivist are the records produced in theadministrative and staff offices of the agency where the policy,procedural, and organizational decisions are made, by which it isgoverned. H 5 4 Thus, archivists should assess the discretionaryand decision-making responsibility of those who created therecords, and they should preserve evidence with theadministrative level it documents rather than the one it reportedto. 55 The particular forms of records that provide evidence ofexecutive actions may include correspondence, minutes, officialdiaries, memoranda and directives. 56One problem for the preservation of such records,identified by Schellenberg, was the tendency of senior officialsto remove them when they leave office, even if only "as aprotection against possible attacks on their reputations or theirwork." 57 His comment reflects a general concern of the time.Frederick W. Ford, a lawyer with the Department of Justice,discussed it in similar terms in a paper to the SAA meeting in1956. "Public officers usually sincerely believe that thepolicies they follow and the actions they take are sensible andhonest," but from fear of criticism they take with them "a fairly54 Schellenberg, Modern Archives 142.55 Ibid., 142-46.56 Schellenberg, 'Appraisal,' 250.57 Schellenberg, Modern Archives 123-4.52complete record of their action in office" as a potentialdefense. 58 The government needs to keep such records in its ownpossession because, for one reason, it "owes to the people arecognition of their right to be fully informed concerning itsconduct." Certain matters must be kept temporarily confidentialbecause of security or privacy considerations, but government ina democracy has a fundamental duty "to make available to anyinterested citizen the record of its activities. More isinvolved in this function than satisfying the needs ofhistorians."59In an interesting sidelight to this issue, Donald McCoyreports that in 1947 President Truman, "believed that governmentofficials [particularly Presidential appointees] should see to itthat a full record be made of their operations, that the recordshould not be destroyed, and that they should not take with themupon leaving office anything but personal papers and extracopies... 60 However a draft presidential directive to this effectwas quashed by the Justice Department. Truman himself, ratherironically, "claimed almost all White House records as personalproperty. " 61Schellenberg did not address the issue of ownership ofpublic records in the strong terms Ford used, but he did insist58 Frederick W. Ford, Some Legal Problems in Preserving Records for Public Use ' AmericanArchivist 20 (1957): 41-42.59 Ibid., 42.60 McCoy, The National Archives 204.61 Ibid., 205.53that access policies acknowledge accountability:Records on the official activities of public servants, asdistinct from records dealing with their personal lives,should not be withheld on the ground that access to themmight hurt their reputations; for public servants,whether in the military, diplomatic, or civilian service,are not a privileged class and owe an accounting to thepeople they serve. 62Similarly, records that concern military strategy and tacticsshould not be shielded "even if the information contained in themmay reflect adversely on the valor of an army, the strategy of acampaign, or the tactics of a battle."They are proper subjects of study and criticism forpolitical leaders and the public in a democracy. If agovernment is responsible to the people for its conductin the area of defense, the record of its defenseactivity needs to be as freely open to examination as thenecessities of defense will permit. 63He observed that after the first World War many governments gaveunprecedented access to prewar archives in order to defend theirown conduct or cast blame on previous governments. However, hedid not believe that the democratic right of citizens to knowtheir government's "major objectives in the conduct of foreignaffairs" extended to "making every delicate move in these affairsa matter of public debate. " 64 He trod a similarly fine line inhis attitude towards political accountability:62 Schellenberg, Modern Archives 231.63 Ibid., 227.64 Ibid., 228, 227.54[The archivist] believes that in most circumstances thepublic interest is served best by making known the truthabout matters...he is not a gravedigger who disinters thebones of rottenness and holds them up to public view. 65Scholarship versus EfficiencyIt seems reasonable to suppose that awareness of theconcept of accountability and its relation to archival ideas andproblems would continue to develop through dissemination ofSchellenberg's text. However it appears that other of his ideasproved more influential and actually undermined the role andsignificance of the concept of accountability in archival theory.Schellenberg used the definition formulated for the 1943United States Disposal Act to describe records as documentspreserved by the creating agency or its legitimate successoreither as evidence of its activities or because of the value ofthe information they contain." However, to promote the culturalidentity of archival repositories and the importance ofarchivists as appraisers of records, he insisted that archives"must be preserved for reasons other than those for which theywere created or accumulated" and "are kept for the use of othersthan those that created them." 67 This argument represented adeparture from earlier attitudes at the National Archives thatthe needs of the government were paramount and those of scholars65 Ibid., 226.66 According to McCoy (The National Archives 150-155), the Disposal Act was drafted byNational Archives staff with limited input from the Bureau of the Budget. It is not clear who inparticular created the definition, which introduced for the first time the concept of records as'evidence or information.'67 Schellenberg Modern Archives, 13.55incidental. It also undermined the concept of archives asrecords preserved as evidence by the agency that created them.Schellenberg equated the primary value of records, that is,their value to the creator, with current administrative, legal,and fiscal uses. 68 While records officers "are mainlyresponsible for judging the primary values," archivists shouldhave responsibility for judging secondary values, that is, thevalue of records to people other than the creator. 69 These'secondary' values were as evidence or information. Despite theDisposal Act definition of records as evidence preserved by thecreating agency, and despite the obvious use of records asevidence for fiscal and legal purposes, 'evidential value' wasdiscussed as an exclusive concern of secondary users:A record officer can provide helpful information for theappraisal of records that should be preserved for theevidence they contain...However, his attention isnormally focussed by reason of his official duties on theprimary value of records. 7°Further, an agency and its records officer cannot be trusted topreserve reliable and useful evidence, unlike the archivist, whois not an interested party with respect to thepreservation of evidence, whether favourable orunfavourable to an agency's administration. He will notjudge of its partiality, he is interested only inpreserving all the important evidence. 71Schellenberg's distinction of primary and secondary values echoed68 Ibid., 133.69 Ibid., 28, 30.70 Schellenberg, Modern Archives 29.71 Ibid.56that of Phillip Brooks in a 1943 comment on "RecordsAdministration", that records officers should know "how toevaluate records from the legal and administrative point of view,depending on archivists to define research uses." 72 However,Brooks had added that records officers could ensure "an adequate,well arranged record of the agency's war operations would bekept" and that both wartime historical programs and recordsadministration were "designed to preserve evidence of theorganization and activities of agencies engaged in the wareffort."73 In Shellenberg's Modern Archives, on the other hand,records managersmust preserve records until their value to the governmenthas been exhausted, or nearly exhausted. And when thatvalue has been exhausted, they must dispose of therecords lest they get under foot and hamper the conductof current business. 74The change in characterization was undoubtedly due tochanges in the field of records administration since the end ofthe war. Emmett J. Leahy sold what he had renamed 'recordsmanagement' to the Hoover Commission in 1949 as a cost savingmeasure, using the warning that "modern recordmaking is in adangerous flood stage" 75 and that records management was an72 Phillip Brooks, 'Records Administration,' American Archivist 6 (1943): 162.73 Ibid., 162-3.74 Schellenberg, Modern Archives 29.75 Emmett J. Leahy, 'Modern Records Management,' American Archivist 12 (1949): 231. Leahywrote that the purpose of records management is to reduce the mass to the small and manageableportion that 'comprises our essential recorded experience' (234). There is some evidence Leahyunderstood the concept of accountability when he was records officer in the Department of theNavy, however his explanation is obscure. He wrote: 'objectives we have at the management57efficiency technique to dispose of the unnecessary paper burden.The review of Leahy's ideas in the American Archivist complainedthat his emphasis on physical and financial costs ofrecordkeeping ignored the quality of records and of the systemsthat generated and preserved them. 76 The stress on recordsdestruction also seemed to threaten future archives. OliverWendell Holmes cited the historical accountability thatarchivists were concerned to provide but that records managersneglected: "The power to say what may be destroyed is the powerto say what shall be kept-to determine the content of the recordsto be available for the future for the people's audit, throughtheir scholars, of the activities of their government." 77Records management discourse seems barely to acknowledgeadministrative accountability, much less the concepts of publicor historical accountability. 78 By distinguishing records andarchives, and primary and secondary values, Shellenberg was ableto establish a boundary between records managers and archivists,which had became a wall by the 1960s. Records managers werelevel [are] in clarifying lines of authority, increasing clear-cut delegation of authority,and tightening up accountability for performance. It remains for records management staff...topool their talents and influence in pursuit of such objectives' in 'The Navy's 'record' in theSecond World War," American Archivist 8 (1945): 240. McCoy (The National Archive^220-229),unravels the complex story of the Hoover Commission and the National Archives.76 Martin P. Clausen, review of gecords Management in the United States Government. a Reportwith Recommendations, in ArnericanAmchlvist 12 (1949) : 287.77 O.W. Holmes, 'National Archives at a Turn in the Road,' American Archivist 12 (1949): 351.78 For example, a common justification for a records management program is its ability toreduce 'legal exposure through routine identification and destruction of records...if the recordsno longer exist, the enterprise has no legal obligation to produce the information' (Fred V.Diers, The Bankruptcy of Records Retention Schedules,' gecords Management Ouarterlv, 26 [April1992]: 6).58driven by the imperative of efficiency, archivists turned theirattention to serving scholarship. Although both professionsdealt with the same material, their different perspectives seemedto renew the categorical distinction between an agency's recordsand 'historical' archives, which archival theory of the previous100 years had been attempting to bridge.Another reason why the concept of accountability seems tohave disappeared from archival theory is that, while Schellenbergwas well acquainted with the concerns of public administration inthe 1930s and 1940s that had introduced the concept into archivalthought, the North American archivists who interpreted his workwere not. American public administration theory during the NewDeal era and Second World War emphasized formal and institutionalelements of organization and administration. This was swept awayby an empirical, realistic orientation, heavily influenced bybehaviour science and nurtured in the university, that wasprocess-oriented and descriptive rather than action-oriented andprescriptive, and "focussed on the complex interplay of interestgroups involved in the formation of public policy." It was alsocontemptuous of "the old, pious, prewar platitudes" and "by 1949Yale Professor James W. Fesler wondered, in print, if nothingthat had been learned about administration in the last generationwas still usable." 79 The new school of thought was preoccupiedwith decision-making as the analysable result of negotiation andstrategy. Accountability, which occurs after the decision has79 Stillman, "Changing Patterns of Public Administration,' 25-7.59been acted on and therefore seems unable to affect it directly,was simply irrelevant. As well, leading organizationalbehaviourists, "by substituting interaction for formalorganization, dissolved the very object of their study...anddrifted away on a Sargasso sea of wheeling, dealing, bargainingand fixing." 8° Organization, the social sciences asserted, was asocial phenomenon, and formal elements such as authority, andtherefore accountability, were purely symbolic.An excellent illustration of the difficulty archivists havein applying this approach to their own field can be found inMichael Lutzker's article, "Max Weber and the Analysis of ModernBureaucratic Organizations." Lutzker suggested, quitereasonably, that archivists might be able to use the insights ofdisciplines concerned with administration and organization "inorder to understand more fully the inner dynamics of theinstitutions or agencies that create records and the variouspurposes of records creation." 81 He reviewed the formalistanalyses of Weber, whose focus on structure and authority clearlyidentified the importance of accountability and records:Decisions are made on the basis of the writtenregulations. The files documenting thesedecisions...record actions and decisions taken. Theserecords provide a mechanism for monitoring anindividual's performance and set precedents for futureactions. 8280 P.M. Strong and R.W.J. Dingwall, 'The Limits of Negotiation in Formal Organizations,' inAccounts and Action: Surrey Conferences on Socioloaical Theory and Method I ed. G. Nigel Gilbertand Peter Abell (Aldershott, England: Gower Publishing Co., 1983), 114.81^ Michael A. Lutzker, 'Max Weber and the Analysis of Modern Bureaucratic Organization: Notestowards a Theory of Appraisal ' American Archivist 45 (1982): 12082 Ibid., 124.60Then Lutzker drew on the more recent behaviourist literature onhuman relations, conflict theory and power structures. Sincethey deny the reality of formal organization, his attentionbecame necessarily focussed on "the informal structures within anorganization that never appear on an organization chart and maynot be clear from the records," and he discovered "theorganization's own archival records may represent misperceptionsof the real world."3 Traditional archival theory, which isbased on concepts of structure, authority and competence,provides no explicit guidance on the relationship between recordsand informal aspects of organizations; therefore, Lutzkerassumed, archivists need a new theory. "The general principleswill emerge gradually from the working models we construct whileapplying the knowledge of our sister disciplines to the processof records creation. " 84However, the fact that post-war organizational andadministrative theories have rejected formalist concepts andembraced logical positivism is not sufficient reason forarchivists to do the same. The organizations and administrativepractices that produce archives have not substantially changed,only the way that academics study them. Archival records areproducts of administration and not of scholarly research aboutit. Secondly, there is every reason to believe that positivismhas not eternally triumphed over normative rationalism, even in83 Ibid., 126.84 Ibid., 129.61the university. There is a small but growing body of literaturethat defends the "old political, legal and administrativedoctrines" because "most of the important things in life cannotbe empirically verified. That does not make them less real,although it may call to mind their problematic nature." 85 Somesociologists have argued that there should be recognition of thedifference between the social phenomenon of organization and theinstitutional entities called organizations.In addition to formal goals, formal organizations mayalso possess a variety of formal organizing devices:formal or written rules; the possession of a formalname...the vesting in certain positions or groups of thepower to review, revise and superintend the workings ofthe rules; the formalization of membership...and finally,formal means of reward."Recordkeeping supports these formal elements, and as theseauthors point out, often distinguishes formal from informalorganizations."Nonetheless, by the 1960s, public administration, recordsmanagement and Schellenberg's theory indicated to archivists thatthere was no long-term or larger sense in which agencies mightvalue their own records. Only archivists are concerned to select85 Richard T. Green, 'Constitutional Jurisprudence: Reviving Praxis in PublicAdministration,' Administration and Society 24 (1992): 9, 17.86 Strong and Dingwall, 'The Limits of Negotiation,' 105-6.87 Ibid., 107. Elsewhere, the authors state that 'the availability of written documents isimportant in distinguishing categories of occupations and organizations, as in modern societiesboth are ultimately legal formations with a basis in statute. They exist through a framework oflegality that regulates their goals and procedures and confers legitimacy on their actions'(Robert Dingwall and Phil M. Strong, The Interactional Study of Organizations: A Critique andReformulation,' Urban Jcife 14 [July 1985]: 217). In their ethnographic study of organizations,an 'account' is a verbal or documented reconciliation of individual action with formalorganizational goals (219).62the records that serve as evidence of agency actions, and theyshould do so in accordance with the needs of scholarship. AsSchellenberg put it, archivists, trained as historians, are theimpartial judges who will "preserve records containing evidenceof the development of the government and the nation that isvaluable for historical research."" He did not contemplate howthe selection of records for primarily cultural purposes mightaffect their evidential value or their connection with theircontext. In his bulletin he indicated that archivists shouldferret out material that might otherwise be neglected, because"the story of these initial efforts often contains the mostimportant lesson for posterity;"" they should attempt todocument "actions that represent significant deviations from thenorm, if not recorded at the policy level," by preserving aselection of operating records "as evidence of policy andprocedure." 9° Aside from requiring more knowledge and time thanmost archivists can master, the prescription to document theagency as a historical topic was vulnerable to charges ofirrelevance for, as Schellenberg acknowledged, historians hadlost interest in the traditional study of government and politicsthat such evidence would directly serve. 9188 Schellenberg, Modern Archives 30.89 Schellenberg, "Appraisal," 245.90 Ibid., 253.91 Ibid., 270.63Thus, another legacy of Schellenberg's work is an emphasison the 'informational value' of records which has threatened toeclipse their identity as evidence. After the war, the patrioticenthusiasm for documenting government administration was replacedby concerns for other types of research that required new data.Schellenberg wrote:the greater proportion of modern public records preservedin an archival institution are valued less for theevidence they contain of government action than for theinformation they contain about particular persons,situations, events, conditions.... 92But while a researcher may value the information in records forits usefulness to his or her research project, this does notalter the nature of the records as evidence of governmentactions; and while a researcher can find another source for theinformation, whether archival or not, and can fit the researchproject to the data available, the recorded evidence of activityneeded for accountability cannot be substituted. The 'primary'and 'secondary' value distinction emphasized by Schellenbergreally only applies to the use of information in records, sincean agency's interest in data for operational purposes is specificand limited in time, whereas the evidence of its activities ispreserved for general, continuing and unforseen purposes. ^Inassessing informational value, the criterium to be applied is'importance to whom and for what purpose', whereas the appraisalof evidence is based on the question, 'importance of what?'.While the latter can be determined within the values of the92 Ibid., 254.64organization and society, the former is, as Schellenberg wrote,'imponderable' because it depends on the individual user. 93The new orientation towards administration, recordsmanagement and archives largely excluded from archival theory theconcept that records are valued as evidence for accountability byboth the accountable creator and those to whom accountability isowed. Only a few references to the idea can be found in NorthAmerican archival literature in the two decades immediatelyfollowing publication of Schellenberg's work.The Chief of the Bureau of Records Management in New YorkState, Vernon B. Santen, referred to it in an address to the SAAin 1969. In his view, the obligations of accountability createdobstacles to the efficient disposal of unnecessary records andwas an unfortunate reality that had to be acknowledged in publicrecords management practices. Financial records are created andmaintained in great quantities by public administrations becausethey areaccountable for their expenditures and for the manner inwhich they exercise their duties as agents for thegeneral public. Multiple legal safeguards existrequiring these records to be available for specific timeperiods as evidence that the public trust assigned hasbeen properly executed, with honesty and integrity. 94However, the appraisal of these records for scheduling is a majorproblem because of "the fears and suspicions of the personscreating these records and of those auditing them, and the93 Ibid., 257. Post-war Americans had great faith in the capacity of information andresearch to solve social, political and economic problems, which may explain this archivalallegiance to the researcher and to secondary values.94 Vernon B. Santen, 'Appraisal of Financial Records   American Archivist 32 (1969): 358.65public's lack of confidence in the integrity of elected andappointed public officers.u 95 Accountability becomes anexcessive preoccupation if the program has a high politicalprofile. Fear of public criticism or of court review frequentlyleads operating personnel to retain records longer than the legalstatutes require. Administrative and political officials "arereluctant to take even minimal calculated risks, and they protecttheir personal and political futures by insisting on unjustified,lengthy retention programs." 96Scheduling records in this environment, Santen explained,requires detailed knowledge of the administrative context of thefinancial records, including the legislative authority andsignificance of the transactions, and the recording andaccountability procedures.^If formal procedures have beenfollowed through, "the audit trail is long and the transactionsuch that it will be subject to multiple review at numerouslevels" and the records of individual transactions can bescheduled for destruction. Without criticizing the predominantrecords management philosophy, Santen did point out that becauseof public and government demands for accountability, a hard-linerecords management approach of short and rigidly enforcedretention periods was often not possible. 9795 Ibid., 357.96 Ibid., 360-1.97 Ibid., 360.66H.G. Jones, in his 1969 monograph on the history and lossof independence of the National Archives, drew from Schellenbergin citing accountability as a metaphorical role for archives:"The records of the federal agencies, selected and preserved bythe Archivist of the United States, must, in a larger sense,constitute the evidence by means of which the people can judgethe performance of public officials and agencies." 98 But thereis no indication that he or archivists at the National Archiveswere interested in exploring the concept further, perhaps becausethis 'larger sense' provided very little guidance for thepractical matter of justifying the preservation of particularrecords against the pressures to destroy them. In the 1960s and1970s, the United States General Accounting Office criticizedagencies and the National Archives for failing to dispose ofrecords promptly, citing the millions of cubic feet of paper ingovernment possession and the cost of its storage. 99Justification for preservation focussed on the value of theinformation in records for independent research.^Martin Elzytitled his 1974 article for the general public "Scholarshipversus Economy", characterizing the predicament that facedappraisal archivists: "Scholars and genealogists require thatgovernment records useful for their research be preserved;government cost analysts require rapid disposal of records that98 H.C. JonesAtheneum, 1969), 257. e (New York:I- I^It •99 Martin I. Elzy, 'Scholarship versus Economy: Records Appraisal at the National Archives,'Proloaue (1974): 187.67are no longer of use to the agency of origin. "loo Because of theimpossibility of reconciling these demands, the appraisal officehad been divided into a 'Records Disposition Division', which hadthe primary function "to reduce government records holdings asspeedily as possible in order to limit storage costs," and areview division to identify permanently valuable records. "Theseconflicting responsibilities require that appraisal archivists befirmly dedicated to preserving the nation's historical resourceswhile remaining alert to the budgetary implications of theirdecisions. "101While this may have been the practical reality for thearchivists in government institutions, the profession did notembrace it as an appealing theoretical position. Archivistswithin manuscript libraries or research institutions, who came todominate the profession's discourse after the 1950s, did notrespond to the argument for efficiency, and preferred a loftierview of the role of archives and archivists, such as thatproposed by Maynard Britchford:as the servant of truth and change, the archivist is nolonger expected to be an anonymous public servant. Hehas one obligation: to lay the documentary foundation forhumanistic and scientific research that will lead to adeeper understanding of man. 102This perspective can be seen in Britchford's 1977 Manual onAppraisal, which was based on Schellenberg's prescriptions but100 Ibid., 183.101 Ibid., 187-8.102 Maynard Britchford, "Informing the Government about its Archives   American Archivist 30(1967): 566.68did not include his references to the concept of accountability.In light of the obvious lack of scholarly interest in governmentinstitutions, Britchford interpreted Schellenberg's emphasis onevidential value as being the result of his own need tounderstand the administrative context of records creation.Although "the archivist's professional bias has producedmisunderstandings among researchers more interested in economicdevelopment, social change, and the dynamic of interinstitutionalrelationships than organization, function, procedure, andauthority," he or she has a "special obligation to promote theserious study of institutional records [which] makes thearchivist an advocate of institutional history. u103 The interestof the general public in archival records was presumed byBritchford to be limited to the self-interest of genealogists orthose concerned with documentation of their personal citizenshipand property rights. 104 He urged archivists to identify closelywith historians, because this would enable them to reach decisons"concerning the future usefulness of records." He cited thecommonly accepted view that voluminous series preserved for theirevidential value could be reduced by means of statisticalsampling, to 'represent' or 'illustrate' agency activity,obviously for the use of scholars, since a random sample willonly provide random accountability. 10103 Maynard Britchford, Archives and Manuscripts: Appraisal and Accessionina (Chicago:Society of American Archivists, 1979), 9-10. Michael Cook has repeated this point in lagyanaaement of Tnformation from Archives (London: Gower Publishing, 1986), 71.104 Britchford, Appraisal 10.105 Ibid., 13, 17.69Preoccupied as they were with their role as servants ofhistory and with a view of archives as records which no longerhad value to those who had created them, archivists were caughtby surprise by the freedom of information movement, which gaineda public profile in the 1970s. In the United States, extensivesecurity classification of records had begun during the SecondWorld War, and administrators were empowered by law to withholdinformation for vaguely defined reasons of 'secrecy in the publicinterest' or 'confidentiality for good cause' or 'internalmanagement'. As one commentator put it, "officials just did notbelieve in a public need to know about mistakes ormismanagement." The 1966 United States Freedom of InformationAct attempted to reverse the government's policy by proclaimingthat "administrative actions, procedures, and related records arelegitimately in the public domain and should not be shielded frompublic view. Hio6 Bureaucratic resistence and the events of theVietnam War and Watergate kept the issue in the public eye andthe law was strengthened in 1974. The American example wascopied elsewhere in the late 1970s and in the 1980s.Archivists did not at first feel that the legislationconcerned them, since it appeared to be about 'current' recordsand not the 'historical' materials in archival repositories. InCanada, Wilfred Smith, the Dominion Archivist, urged in 1978 that106 William H. Harader, 'Need to Know-An Attitude on Public Access ' Government PublicationsReview 10 (1983): 444.70freedom of information legislation is based on the needsof the general public for current information and thechief concern of archivists and their patrons is thatthere be adequate provision in the legislation forliberalization of access to records in the archives,primarily for a variety of research purposes. 1"Archivists sought equitable access based on uniform restrictionperiods of, commonly, 30 years. But when they expressed a strongopinion on more recent materials, it was usually to disparagedemands for access as interfering with the honesty and franknessof the records, thus impoverishing their future historical value.Schellenberg had expressed an opinion commonly held by archivistsfor a long time afterwards that,the shortening of the time period during which recordsare withheld from the critical scrutiny of scholars mayhave an adverse effect on the quality of public recordsthat are produced. If they know that what they writewill be used shortly, perhaps within their lifetime, forhistorical purposes, public officials may produce recordswith an eye to history. They may put into theirdocuments what they believe will reflect creditably uponthem or the administration with which they areassociated...By being too hasty in opening records forpublic use the archivist and, parenthetically, thehistorian may defeat their purpose of promoting objectiveresearch. 108According to the historian Arthur Schlesinger, the choice isbetween an honest and revealing record available in ten years anda distorted one available tomorrow. 109 The argument ignores thefact that the size and complexity of bureaucratic operationsrequires that actions be accurately committed to paper. As well,107 Wilfred Smith, 'Accessibility and Archives: A Response ' Archivaria, 7 (winter 1978):146.108 Schellenberg, Modern Archives 226.109 Anna Kasten Nelson, ed., The Records of Federal Officials: A Selection of Materials fromthe National Study Commision on Records and Documents of Federal Officials  (New York: GarlandPublishing, Inc., 1978), 69.71the demand for administrative accountability usually outweighsconcerns about publicity. As one White House staff person putit, "writing memos is one way that officials protectthemselves. ono Nor did archivists and historians mean to arguethat officials should be left to engage in corrupt activitiesbecause it makes for better history, but that is how suchstatements could be read. Attitudes changed, both about the needfor a process of public scrutiny of government and about thepublic's right to knowledge taking precedence over the demands ofhistorians on behalf of 'objective research'. 111 And not allhistorians recognized the primacy of the rich historical recordor the clear distinction between current and historicalmaterials. As one claimed, "the distinction between politics andhistory [is] one of academic convenience rather than ofactuality. u112At the same time as the freedom of information movementaddressed accountability of the administration, there weredemands for accountability of public officials throughpreservation of and access to their documents. The establishment110 Ibid., 41. Trudy Huskamp Peterson noted, with regard to the freedom of information'seffect on documentation, "it is impossible to manage large federal agencies without issuingwritten instructions and documenting decisions and reporting on programs and problems" ('AfterFive Years: an Assessment of the Amended U.S. Freedom of Information Act ' American Archivist 43[1980]: 163).111 Schellenberg referred ruefully to historians as sometimes being ''as clouds that arecarried by the tempest' of ideological prejudices" (Modern Archives 236).112 Herbert G. Nicholas, 'The Public Records: The Historian, the National Interest andOfficial Policy ' Journal of the Sociptv of Archivists 3 (1965): 4. Nicholas links the creationof the British Public Records Office with the passage of the Great Reform Bill, as a democraticinitiative analogous to the creation of the Archives Nationales at the time of the FrenchRevolution.72of presidential libraries had ensured the preservation ofimportant White House records for historical research withoutconfronting the issue of ownership. The legal and socialtraditions that had allowed politicians and their senior staff todecide for themselves whether the records of their office werepublic or private, and therefore whether access would be allowedto them, was challenged in some quarters, again through thecatalyst of Watergate. In 1974 the Society of AmericanArchivists rejected a resolution calling for public ownership ofrecords of public business, as too politically biased andunrealistic; but that same year Nixon's attempt to remove WhiteHouse records became a public scandal and was quashed byCongress .113Their neglect of the concept of accountability when it hadbecome an issue of public concern made archivists and archivalpractices targets of criticism within and outside the profession.Frank Cook attacked the failure to address "the people's right toknow what their government is doing long before a historian mayresearch the topic. H114 To the argument that the quality of thehistorical record would be damaged by premature access, heresponded that perhaps officials might learn "to govern moreresponsibly because of the realization that their activities andpolicies would soon face public scrutiny" and that "it has becomeessential to insure a greater public access to the decision-113 J. Frank Cook, "Private Papers' of Public Officials   Agierican Archivist 38 (1975): 317.114 Ibid., 319.73making process, if our democratic form of government is tosurvive. .11sThe new policy of freedom of information not only hadaccess and ownership implications, but raised expectations thatthe records would not be destroyed. Again in the United States,a coalition of historians and public activists protested againstthe destruction of Federal Bureau of Investigation (FBI) fieldoffice files, which had been approved by the National Archives onthe grounds that the records were either duplicates orsubstantially incorporated into reports to headquarters, althougharchivists had not been allowed to examine the records forthemselves. In 1980 a federal court ordered the Archives to"devise a new plan, after consultation with historians andarchivists, which would ensure the preservation of a completehistorical record. 11116 No doubt with an awareness of thisprecedent, in 1984 Australian archivists made a submission to theRoyal Commission on Australia's Security and IntelligenceAgencies stating that "government may be seen to be mostaccountable to Parliament, and in a wider public sense, when itpromotes maximum public disclosure of its activities" throughlegislation which spells out rights of access to records.Secondly,115 Ibid., 324.116 Athan G. Theoharis, The FBI and the FOIA: Problems of Access and Destruction,' TheMidwestern Archivist 5 (1981): 7074accountability in a more limited sense, expressed througheither Ministers or ultimately through the Courts,imposes some code of conduct in matters of disposal ofpublic records. Specifically, it suggests that disposalof public records shall be systematic, rather thanarbitrary or subject to caprice. 117"If government is to be held responsible for its mistakes, thencrown documents should be protected. 11118 The archivists promotedarchival legislation supporting systematic records disposal.The fact that accountability has become an issue inrelation to political scandals and the actions of secretive andinvasive agencies may make it appear to many archivists as'muckraking' rather than a genuine and challenging philosophicalconcern about the role records play in documenting and preservingthe relationships of government to the governed. There areproblems yet to be addressed in archival theory regarding theability of modern records to serve public accountability. Forexample, what constitutes reasons for decisions and how wellought they to be documented for the public; what is the nature ofthe distinction between working papers and official records; whattype of description is necessary to inform the public ofgovernment activities and records; and in general how toreintroduce controls over recordkeeping in order to ensure thateach request for information can be dealt with quickly,inexpensively and with assurance, and so that those creatingrecords know what is going to constitute evidence of theiractions and therefore what their obligations are in that respect.117 Mark Brogan, The Royal Commission on Australia's Security and Intelligence Agencies,*Archives and Manuscripts 12 (1984): 106.118 Ibid., 107.75Public accountability, in the form of access to informationlegislation, must rely for its success on good recordkeeping foradministrative accountability. Yet the latter concept is notcurrently well understood in archival theory, or even generally.Archivists and others have declared that freedom of informationmay lead records creators to avoid making records, to falsifythem, remove them from the context that would reveal theirsignificance or even keep 'phantom' or secret registries. 119 Butsuch possibilities exist in all attempts to obtain accountabilitythrough records, which is why procedures and routines for recordscreation exist in administration. Such procedures have not yetbeen devised especially to obtain public accountability throughoriginal records: there should at least be concern to ensure thatstandards of administrative accountability are sufficiently highto serve the additional purpose.Gradually, some of the more philosophical aspects ofaccountability have re-entered archival thinking. Michel Ducheinobserved in his 1983 RAMP study on Obstacles to the Access. Use and Transfer of Information from Archives, that the opening ofarchives for research could be traced to the "rebirth of the ideaof democracy, according to which sovereignty is derived from thepeople, and the people, consequently, have the right to controlthe action of the leaders they have chosen to govern them, u120 buthe noted that by the twentieth century,119 Quoted from an unnamed archivist by John Smart in The Professional Archivist'sResponsibility as an Advocate of Public Research,' Archivaria 16 (Summer 1983): 145.120^ Michel Duchein Obstacles to the Access. Use and Transfer of Information from Archives: aRAMP study (Paris: UNESCO, 1983), 3.76nowhere, with the sole exception of Sweden, was the rightof access to archives explicitly linked to the exerciseof democratic rights...laws and regulations wereformulated exclusively to facilitate historical andscholarly research...but never to provide the public withinformation on recent or current governmental oradministrative procedures. 121A writer on the Canadian 'access dilemma' referred to the recentreappearance of the concept of accountability as "an importantfeature of public jargon about the operation of government," butadded that "the impact of this thinking on archivists wouldprobably have been minimal if it had not been for two paralleldevelopments, the increase in the number of researchers and inthe collection of materials. H122The argument that it was new demands for recent andunmanageable materials that created archival concern withaccountability is not entirely supportable. In the late 1970s adesire for a more secure position for archival repositories ledsome archivists to question their status as purely scholarlyadjuncts, and to argue that archives have a broader societal rolethan simply as sources for history. Although the approachesvaried, they all stressed the administrative values of archivesand some evoked the concept of accountability. Most writers onthe theme emphasized the theoretical ideas expressed by Jenkinsonand questioned the distinction between records and archivescreated by Schellenberg. In 1978, Andrew Raymond and JamesO'Toole reviewed the two theorists and argued that the "middle121 Ibid., 4-5. Duchein was more familiar with the European context than the U.S. NationalArchives of the 1940's and 1950's.122 Don Page, The Access Dilemma " Archivaria 8 (Summer 1979): 135.77ground established by Norton," which retains the view ofarchivists as responsible professionals but emphasizes therelationship between archives and public administration, couldbring repositories "up from the basement." 123 They argued thatgood record-keeping bears directly on the accountabilityof public officials to the people, a subject of increasedpopular interest in recent years...[it] requires thepreservation and accessibility of the records containinginformation on their conduct in office. 124If archivists were to turn from their preoccupation withsecondary uses towards all phases of the life-cycle of recordsthey would be able to make unique and important contributions tothe implementation of better recordkeeping and of the policiesneeded for the management of public records. In the same year,the Association of Canadian Archivists rejected the purelyscholarly role conceived for archives in the Symons Report andstressed the need to preserve the connection between records andtheir context of creation, preferably through agency-sponsoredrecords management and archives programs rather than thecollection of documents by research repositories. Thoseresponsible for the creation of records having archival valueshould provide archival care for them. "In today's world, theprincipal motive for government archives should be to fulfill theobligation to be accountable to and protect the interest of thepeople governed. n 125 David Bearman also cited accountability in123 Andrew Raymond and James O'Toole, "Up from the Basement: Archives, History, and PublicAdministration   Georaia Archive 6 (Fall 1978): 26-27.124 Ibid., 29.125 The Association of Canadian Archivists, 'The Symons Report and Canadian Archives,"Archivaria 11 (Winter 1980-81): 9.781986, in claiming a broader purpose for archives and archivists:To claim a social role, to demand our share of resources,we point not to the needs of the indeterminate future andthe nostalgia of the unappreciated past, but to theimmediate requirements of today. These are therequirements for accountability, for applicableknowledge, and for cultural connectivity. 126The role of records in helping to "ensure the accountability ofgovernment and its officers" has been recently cited in argumentsfor local and state records programs. Howard P. Lowell urgedthat "archives are fundamental to government administration in ademocratic society," but archivists need to explain their role tothe public and administrators and institute programs that "mirrorcardinal canons of representative democracy and good publicadministration. u127 In 1990, accountability was identified as aprimary purpose of the records management programs of Americancolleges and universities:public expectation and requirements of legal and fiscalaccountability clearly help explain why 75 percent ofrespondents with campus-wide records management programsare from publicly supported colleges and universities...state legal mandates or records management requirementswere cited almost as often as the expected institutionaldesire for better archives, improved records retrieval,and savings of space and filing equipment. 128Outside North America, the accountability purpose of126 quoted in David B. Gracy, 'Is There a Future in the Use of Archives?" Archivaria 24(Summer 1987): 8.127 Howard P. Lowell, 'Thoughts on a State Records Program ' Aperican Archivist 50 (1987):398. See also Bruce W. Dearstyne, 'Principles for Local Government Records: A Statement of theNational Association of State Archives and Records Administrators," American Archivist 46 (1983):454.128 Don C. Skemer and Geoffrey P. Williams, 'Managing the Records of Higher Education: TheState of Records Management in American Colleges and Universities " American Archivist 53 (1990):537.79archives has been linked more closely to the foundation ofarchival theory, that is, the nature of archives. Peter Sigmond,presenting a European perspective to Americans, referred to agovernment obligation,that some part of all records should be preserved toprovide the possibility for citizens to oversee theadministration. It is not only the historical value thatcounts...The extra dimension that archives do have [ascompared to books], is this legal value. 129The same point was made recently by Australian archivists in asubmission to the 'Inquiry into Australia as an InformationSociety' conducted by the House of Representatives. Concernedabout "the relative invisibility of the recordkeepingprofessions" and the lack of a policy framework for managingrecords, the submission argued that "the effective creation andmanagement of the archival document is a precondition of aninformation-rich society and underpins the public accountabilityof government and non-government organizations...^This isbecause "archival documents first and foremost provide evidenceof the transactions of which they are a part" and they retainthis value as long as their integrity is protected. Thesubmission argued that "because the archival document is creatednaturally in the course of our transactions, it provides a muchbetter means of controlling our inter-relationships thaninformation reporting," and advocated, for cost-efficiency,129 J. Peter Sigmond, 'Divergences and Convergences of Archives: A European Looks at NorthAmerica,  in Proceedings of the Second European Conference on Archives (Ann Arbour, Michigan,1989), 7 .130 Sue McKemmmish and Frank Upward, 'The Archival Document: A Submission to the Inquiry intoAustralia as an Information Society ' Archives and Manuscripts 19 (1991): 18-19.80"greater use of records audits to regulate our organizations." 131It outlined the threats to the completeness, accuracy andreliability of archives, which include the general lack ofrecordkeeping principles in organizations, unregulateddestruction, few archival authorities, limited integration amongthose responsible for managing records, uncoordinated access andprivacy regulations and electronic technology.Unlike the Australians or Dutch, North American archivistswho have recently referred to the concept of accountability inits abstract, public sense, have not generally related it to theconcept of records as evidence, although this link is implied inRoy Turnbaugh's reflection on appraisal criteria in Americanstate archives. He found that respondents to a survey"considered informational value to be at least as important asevidential value," reflecting perceptions about why and for whomrecords are appraised: "Many respondents placed more weight onresearch or historical values than they did on protecting therights of the state and its citizens, this despite the ratherslender use scholars make of public records. "132^He urged"understanding and accepting the idea that we exist to make surethat the records of the significant actions of government arepreserved...The resulting holdings comprise a sort of giantledger, in which the accounts of the public trust are entered." 133131 Ibid., 26.132 Roy Turnbaugh, 'Plowing the Sea: Appraising Public Records in an Ahistorical Culture,'Amerif:an Archivist 53 (1990): 563.133 Ibid., 565.81Historical AccountabilityWhile the concept of accountability through preservation,management and access to records of government has become, if notcommon, then at least recognizable in literature about the roleof public archives in society, it has not found similaracceptance among archivists in non-government archives such asmanuscript libraries and historical societies. In some instancesa notion of 'historical accountability' has been evoked as arationale for the preservation of wartime records, privatearchives and the records of public officials. Oliver WendellHolmes used it to decry the destructive tendencies of recordsmanagement. John Hall Archer, a Canadian university archivist,explained in a 1969 article that it was "another term for a senseof history and tradition," by which he urged the preservation ofbusiness records: "I think that a strong case can be made forthe argument that a corporation not only is responsible forliving within the law of the host country but should contributeto the country's general welfare. "134 Public officials have alsobeen urged to preserve and make their records available tofulfill a historical accountability to society. Anna KastenNelson introduced a 1978 volume on the records of United Statesfederal officials by arguing that they134 John Hall Archer, 'Business Records: The Canadian Scene ' American Archivist 32 (1969):252. Interestingly, the same article notes that it was not a sense of history but theaccountability of provincial government departments to legislative committees that ensuredpreservation of their records and the establishment of public records programs (254).82must come to understand the importance of governmentaccountability through history as well as journalism, forthe citizens of this country must be provided withsufficient information to understand the decisions of thepast in order to understand those of the present. 135The same volume, however, revealed considerable confusionabout exactly what the concept meant, and how it should guidepractice. For example, one historian, speaking on "the burden ofaccountability to history", borrowed from administrative andpolitical ideas to stress that it was no mere service tohistorical curiosity:[no] public official, whether judge, executive orlegislator, can claim any right to privacy in how he orshe performs a public function...As long as we, thegeneral public, are affected by these decisions, I thinkit is a public function. 136The preservation of records of their actions is not only toprevent such officials from acting wrongly, but also to "havethem know there will be something of a record kept, that we wantto encourage them to operate as close to the highest ideals oftheir profession as they can."137 But as another panelist pointedout in response, the requirement that one leave an account forthe distant future is unlikely to affect current behaviour.Further, if historical accountability is owed because of theeffect of one's actions on contemporaries, restricting access tocurrent records, that are yet preserved for the future, is hardlythe way to meet it. Clearly, the concept of historicalaccountability is tied to the idea of a relationship between135 Nelson, ed., The Records of Federal Officials xxi.136 Professor Murphy, quoted in ibid., 224.137 Ibid., 259.83future and past, which cannot be a relationship of control.Another difficulty encountered by the panelists was the purelyvoluntary nature of records creation and preservation forhistorical accountability. As was repeated by severalcontributors, important officials should be encouraged todocument their actions and thoughts, but could not be obliged todo so. Archivists would sift the remains to determine whichdocuments should be preserved. However, as a manuscript curatorcomplained, the volume of routine and uninteresting records thatmembers of Congress donate to repositories makes this verydifficult. Another panelist argued that preservation forhistorical accountability could not take precedence over currentneeds. "I think we are saying that anything that is important tohistory ought to be called public records, so that we hold it,control it, and perpetuate it...so the historians will have afield day later on. "138 He advocated instead that the recordsthat are important to significant activities be designated aspublic records. Thus, for example, notes of the debate amongjudges prior to rendering a judicial decision would not berequired to be preserved, since they are irrelevant once thedecision has been reached and framed.Historians would not be satisfied by the retention of onlythose records required for current administrative and publicaccountability. They want a historical record that will revealmore than the published information and to have evidence from138 Mr. Buchen, quoted in ibid., 258.84behind the scenes, not just the formal deeds and justifications.They would argue that history has privileged needs, because thehistorical perspective is a disinterested overview of anextensive period of time, and therefore a more honest assessment.But this does not today provide a sufficiently convincingargument that historical accountability should be seen asaccountability to historians.Historical accountability may be, more broadly, a need toprovide and receive explanation and understanding from onegeneration to another. Groups of individuals often derive theircohesiveness, legitimacy and the authority for their actions fromtheir understanding and evaluation of the past. Families,nations and institutions endure beyond the lifespan of any onemember, as do their relationships with other groups; history isthe memory that gives members their understanding of the groupand helps it to endure and act. In the modern world there is abelief that history should be based on written evidence andresearch, rather than on oral legend and opinion, thus theimportance of preserving archival sources.Many current examples of this historical accountability canbe cited: the vicissitudes of the reputation of Louis Riel, forexample. Variously regarded as hero and traitor, madman andsaint, the Metis, English and French Canadians have used theirunderstanding of his role in Canadian history to explain tothemselves relationships in the present. For Australians, thediscovery that Winston Churchill betrayed their government duringthe Second World War reinforces a desire for independence from85Britain today. Political philosophers seek a truer understandingof the American constitution through the recorded debate of itsfounders. It is impossible to state whether a particularunderstanding of history justifies a group disposition or formsit: it may be a mutually strengthening interaction.An individual's sense of historical accountability must bedistinguished from mere egotism, or an Ozymandias syndrome. Itis rooted in a belief in an obligation to account to the futuremembers of the group, either by describing, explaining orjustifying what one has said or done. Of course, there mustfirst be a belief in the group as more than a collection ofautonomous individuals, in common values and a common good, andin responsibility to the community. Such beliefs are notcurrently part of dominant North American conceptions of society,however "most regimes in history have viewed public life as priorto and constitutive of individual life," 1" and no doubtindividuals hold these views and act on them in their own lives,for example when they donate their papers to a repository becauseof a sense of responsibility for their actions and a need toexplain their intentions to the future, which they affect.Where there is no sense of public responsibility to thefuture, archivists cannot engender a true historicalaccountability. They must instead rely on demands for present-day administrative and political accountability to ensure the139 Green, 'Constitutional Jurisprudence,  17. The author comments that the differencesbetween public and private law and between public and private administration are as important asthat between individual and community. Yet most current legal and administrative education isbased in the private dimension.'86preservation of records, and point out that accountabilityendures beyond the immediate needs of the moment, potentially foras long as the relationship that it serves persists. Thisargument can be made for the records of government, as theirpublic nature has now been accepted, and there is a generalunderstanding of the state as a formal and continuing entity.But there are significant obstacles to applying the concept ofaccountability to records which are defined as 'private'.Richard Berner noted with regard to corporate records that, "asbusiness becomes increasingly political and 'public' in itsimpact, the more secretive and arbitrary it must become - or soit seems. H140 As noted, past attempts have been made to arguethat while there may not be an obligation to provide access tocurrent records, important officials and institutions have anobligation to preserve their records for the future. But anotherphilosophical issue has undermined even this argument foraccountability.The 1960s and 1970s were dominated, in most of the Westernworld, by a "general challenge to the existing system ofauthority, public or private...in the family, the university,business, public and private associations, politics, thegovernmental bureaucracy and the military. u141 This was reflectedwithin the historical profession by an attack on the elitism of140 Richard C. Berner, 'Business Archives in Perspective,' Journal of Forest History 18(1974): 33.141 Stillman, 'Changing Patterns of Public Administration,' 29, terms this period therevival of Romantic Jeffersonianism.  Each of the three phases in American public administrationhistory identified by Stillman has been reflected in archival theory.87the assumption that only powerful people are important inhistory. The attitudes were carried into print in archivalliterature by the historian Howard Zinn, who challengedarchivists to reorient their acquisition focus to meet the newhistorical perspective. He pointed out that the control ofinformation is a means towards the maintenance of power. "One ofthe ways in which information is controlled and democracy denied,is by the government withholding important documents from thepublic, or keeping secret their existence altogether. H142 Heargued that contemporary archival collections of private papers,which usually document the lives of those in authority,represented a similar control over information by those in power:The existence, preservation, and availability ofarchives, documents, records in our society are very muchdetermined by the distribution of wealth and power. Thatis, the most powerful, the richest elements in societyhave the greatest capacity to find documents, preservethem, and decide what is or is not available to thepublic."3This results in a bias in archives "towards the important andpowerful people of the society." The bias is not just incollecting policies, but in recordkeeping itself, because thewritten word favours the "top layers, the most literate elementsin the population," and favours static situations over "dynamicsof social interaction." The net effect is "to protectgovernmental authorities from close scrutiny...To glorifyimportant people, powerful people...to keep obscure the lives of142 Howard Zinn, "Secrecy, Archives and the Public Interest,  Midwestern Archivist 2 (1977):21.143 Ibid., 20.88ordinary people in the society. .144^The solution that Zinnproposed was for archivists to lose their passivity and actagainst these biases by acquiring or creating records of lesspowerful segments of society.While few have addressed the issues as strongly as Zinn,his conclusions, or the social attitudes that informed them, hada significant influence on archivists. Zinn was quotedapprovingly by Gerald Ham in his influential essay "The ArchivalEdge", to argue against the "passivity and perceptions thatproduce a biased and distorted archival record. 11145 Ham blamedtraditional archival theory for producing archivists who were"passive, uninformed, with a limited view of what constitutes thearchival record." 146 This radicalism seems to appeal especiallyto archivists from manuscript libraries or other repositoriesthat were vulnerable to the accusations of elitism. 147 For anumber of reasons, therefore, there is little acceptance of theidea that the records of those with authority and power in theprivate sphere should be preserved because they are evidence ofactions which affect others and for which they are responsible.144 Ibid., 21, 25.145 F. Gerald Ham, "The Archival Edge ' American Archivist 38 (1975): 5.146 Ibid., 13.147 For example, Frank Boles has applied this activist stance to appraisal of public andprivate records, writing, an archives may be legally mandated to retain records of agovernmental agency and may choose to implement this mandate by a strategy consciously focusedupon the records of senior administrators" ("Mix Two Parts Interest... * American Archivist SO[1987], 359). However, this is not a matter of the archivists' choice because accountabilityrequires the retention of such records.89The Rediscovery of Accountability in AdministrationAlthough contemporary archival theory has linked thepurpose of public archives with the accountability of government,it does not provide a complete explanation of the relationbetween accountability and archives, because archivists do notalways understand the administrative need to preserve evidence ofactivity. The problems posed by electronic recordkeeping systemshave reintroduced the administrative aspects of accountabilityinto archival thinking in the 1990s.^This happened becausearchival theory has had to be re-examined in light of thechallenges electronic records pose to archival methods, andbecause it has forced records managers and archivists to considerbecoming involved in the design and administration of electronicrecordkeeping systems.When archivists first acquired machine-readable records, itwas for their value as information and, particularly, as largeaggregates of data. However, by the 1980s, computers had come tobe used in all aspects of administration, not merely forstatistical functions. It could no longer be assumed, asKatherine Gavrel put it, that "documents relative to policyformation, program management, and other organizationalactivities [are] in hardcopy form. ..i48 Archivists have had toexamine archival theory on the nature of records and theirvalues, and their methods of arrangement and description, inlight of the manipulability and transcience of electronic148 Katharine Gavrel, Conceptual Problems Posed by Electronic Records: A RAMP Study (Paris:Unesco, 1990), 21.90information, the software and hardware dependency of systems, andthe failure of the information technology profession tounderstand and protect the integrity of records created by thesesystems. The concept of accountability has been used to explainand reinforce the importance of the traditional archival view ofrecords as evidence of administrative action preserved by theagency responsible for it.The most thorough treatment of the subject is in the reportprepared by the United Nations (UN) on Manaaement of Electronic Records. It takes as a fundamental premise that "managing large,complex organizations and ensuring that they are accountable fortheir actions requires that administrators, and those to whomthey are responsible, have access to records documenting officialactivity. 11149 It states further that this is the fundamentalpurpose of records and archives programs:Records and archives management are administrativefunctions of organizations created to meet their need toaccount, to themselves and to society, for their actions.The job of records managers and archivists is to ensurethat all the records necessary to document the actions ofthe organization, but only those records, are retained,and that they are retained as long as they continue tohave value. 150The report stresses the nature of records as evidence ofthe transactions of which they formed a part. In the appraisaltheory that has evolved from Schellenberg's bulletin, recordswith evidential value are those which contain useful or important149 United Nations Advisory Committee for the Co-ordination of Information Systems (ACCIS),•^• IP^Z - • •^ (New York: United Nations, 1990), 17.150 Ibid., 19.91information about the agency that created them. But actualappraisal to determine which records have that value rely uponthe paper-based record system in which documents are grouped inan orderly manner into files, with titles that identify theirsignificance, and series that are usually based on function andthat distinguish, for the agency's convenience, between policyand information files, administrative and operating records, andwhich maintain the internal and external correspondence of eachoffice as a unit. No such arrangement and indexing system existsfor most electronic records, which are stored randomly, andgenerally with obscure document titles that rarely identifyorigin, function, or status. It has become apparent that'evidential value' refers to more than simply information aboutthe agency; it signifies the capacity of the record to serve asevidence of the actions of the agency, which is not found in itscontent as much as in the formal elements that give itauthenticity and completeness, and its relation to other records,that is in its context in the recordkeeping system.The United Nations report argues that the preservation andmanagement of evidence of actions must be governed by arecordkeeping system that is a product of organizational policyand systems design. In a complex organization, accountability issecured by procedures and routines governing recordkeeping. Asthe report states, "both work and communications are conducted byindividuals, but they take place within well understood, if notalways well defined, systems. Systems for work and communication92lead to regularized, predictable and accountable outcomes. H151This point was made by Paul Marsden against those who argue thatthe value of new information technology is its ability to putcontrol in the hands of the individual user. Corporate bodiesmust maintain control over their information holdingsboth for legal and corporate reasons. This means knowingwho created what, when it was created, and where it is.In the same way that churches and governments created andadopted ledgers and then filing systems to bring controlover their records, organizations will search out theways to do the same with electronic created documents.As the UN report points out, "each system must distinguishofficial from purely private information" depending on thepurpose it served in the agency:Spreadsheets reflecting departmental or sub-unit budgetskept by line managers for day-to-day control purposes donot substitute for the accounting system, butspreadsheets developed for purposes of submittingproposals or of resheduling debt may be of long-termvalue for accountability. 153Similarly, if organizations require accountability fromindividuals for the information that was consulted in makingdecisions, systems are required that document "all informationseen by an individual. "154Schellenberg, in the pre-computer era, had referred to thevalue of evidence about the process and information thatcontributed to decisions: "Research and investigative records are151 Ibid., 20.152 Paul Marsden, 'The Electronic Records of the Trade Negotiation Office and the Future ofthe Automated Offices in Archival Acquisition,  unpublished paper delivered at Association ofCanadian Archivists Annual Meeting (Banff, 1991), 17.153 Ibid., 20-1.154 Ibid., 25.93of undoubted importance, for they often contain the rationale ofgovernment programs-the reasons why they came into being and werehandled as they were. 11155 He may well have assumed that thesewere of significance chiefly to historians. Chester Guthrie wascertainly taking the scholarly perspective when he wrote,we are often left with the spectacle of capable,dedicated historians speculating as to why an importantdecision was made. Perhaps some speculation isinevitable; but, as better information systems aredeveloped, we shall have better histories. 156In 1972 Meyer Fishbein also raised the possibility of identifyingand accessioning the computerized data sources for policydecisions. 157 The 1990 UN report assumes the need to document theprocess leading to a decision through preservation of "thesoftware facilities and data access permissions and viewsavailable to any given user in order to provide evidence forpurposes of accountability. H158 Michael Miller has argued thereis no necessity for this:if the decision-maker is to be accountable for theprocess of decision-making this can, and should, becaptured in memos for the record, or as part of thesupporting documentation for a decision...For importantdecisions, an agency could require that all supportingdata be retained in a separate electronic file as part ofthe adequate and proper documentation of the decision. 159155 Schellenberg, 'Appraisal,' 250.156 Chester Guthrie, 'New Data to Shape History,' American Archivist 30 (1967): 331.157 Meyer Fishbein, 'Appraising Information in Machine Language Form ' American Archivist 35(1972): 35-43.158 ACCIS, XanaaemPnt of Electronic Records 25.159 Michael L. Miller, 'Is the Past Prologue? Appraisal and the New Technologies,' inArchival Management of Electronic Records ed. David Bearman, Archives and Museum InformaticsTechnical Report No. 13 (Pittsburg: Archives and Museum Informatics, 1991), 46.94The requirement to retain the actual information used indecision-making depends on the circumstances and the amount ofdiscretion allowed to the decision-maker. For example, decisionsconcerning entitlement to benefits are made on the basis of rulesapplied to information supplied through approved sources: thesigned application, or documentary proof such as a birthcertificate. The official who approves the entitlement is notexpected to rationalize the decision but is required to preservethe evidence on which it was based. Some information systems aredesigned to support this type of decision; among these, expertsystems, which eliminate the human evaluation of the evidence,are the most advanced. Other information systems, however, are ameans of conveniently providing information to support what isstill within the discretionary judgement of an individual orgroup. It is unlikely that policy decisions will ever be made byexpert systems, simply because the final decision remains amatter of human choice and not of following rules. In thesecases, organizations have always distinguished between workingpapers and official records, regarding the former as essentiallyprivate because the decision-maker's accountability is for theultimate justification given, not for the method by which thatjustification was reached. However, what is crucially importantis that information systems designers understand the degree offormality that attaches to the process of decision-making, sothat they can meet its requirements.Increased use of electronic systems will directly affectarchival methods. The appraisal of documents transmitted by95electronic mail cannot be made by an archivist after they ceaseto be of current use, as has often been the case with paperrecords. Not only would it entail a time-consuming item levelexamination and comparison with other record holdings todetermine the uniqueness and significance of the documents; butmost of the records may very well have long since been destroyed.Administrative systems of control, suited to the new media, willaffect records creation, classification, description, indexing,preservation and access. Because of the renewed importance ofcontrol over electronic recordkeeping, Paul Marsden observed"there will still be need for the traditional principles andpractices of the archivist. u160 But it will require theirinvolvement in the administrative aspects of recordkeeping, notjust the subsequent scholarly uses. As the UN report states, theneed to secure the integrity and authenticity of electronicrecords,will of necessity involve records managers and archivistsin the design of the application systems before theirimplementation. The objective of such involvement hereis to harness software capabilities to generate (andsegregate) records required for organizationalaccountability. 161"Records managers and archivists must therefore develop closeworking relationships with, and play part of the role of, systemsdesigners. u162 Archival methods cannot be confined to theinactive phase of the lifecycle of electronic records, nor can160 Marsden, 'Electronic Records of the Trade Negotiation Office,' 17.161 ACCIS, Management of Electronic Recordg 23.162 Ibid., 30.96records managers continue to focus on efficiency. Once again,archivists are finding they must become involved in the creationand administration of records.Both archivists and agency staff need to acknowledgeaccountability as a primary value for organizations. Those whoare accountable for their actions are responsible for ensuringthat the evidence needed to discharge their obligations ispreserved. "The fate of electronic records will depend on thedegree to which line managers perceive records management astheir responsibility, rather than the future responsibility of arecords management and archives staff. H163^However archivists,with their understanding of records and archival methods, canprovide guidance and support in records administration "and buildwidespread understanding of the organizational need for recordsand the organizational vulnerability to bad records practices. u164David Bearman has argued that in the future archivists will berecords experts, rather than custodians or appraisers.Bearman has also brought the concept of accountability intothe more traditional archival concern of description. Archivistsare defining descriptive standards and systems that will allowthem to use new technologies to provide better access to thematerials in their care. But, as Bearman argues, before aninformation system can be designed, its purpose must beidentified. If the purpose of archives is to preserve163 Ibid., 26.164 Ibid., 51.97administrative, public or historical accountability, archivalinformation systems should support this purpose and provide'documentary accountability'. "The information recorded in thesystem...is about activity for which there is documentaryaccountability, not about the documentation which happens toreflect that responsibility. .16s This can be seen in theregisters that are published in association with access toinformation legislation: they document the functions of agencies,rather than simply describe the records. As well, accountabilityfor actions is transmuted into accountability for documents,since the documents serve as the evidence of the actions.Therefore government archives should consider themselves tobe a repository of primary data on the activities oforganizations and an audit trail of the documentationresulting from such actions. Its focus is on theorganization and its activity, including its recordshandling activity, and not on the content of the fonds. 166While 'documentary accountability' seems conceptuallycomplex, it is the basis of what archivists know as provenance-based description and search methods. Rather than classifyingthe subject of documents, archivists identify the functions thatthe agency was responsible for, because accountability requiresthat it predictably record and preserve information about itsactions and their object. As the nineteenth century Europeansdiscovered with regard to arrangement, "the requirements of165 David Bearman, Who about What or from Whence, Why and How: Intellectual AccessApproaches to Archives and their Implications for National Archival Systems,' in Archives, Automation and Access: Proceedinas of an Tnterdisciolinary Conference  ed. Peter Baskerville andChad Gaffield (Victoria: University of Victoria, 1985), 44.166 Ibid., 43.98control are identical with those of access and the task ofarchival description is integral to the task of recordsmanagement." 167 Again, when archivists are faced with a choicebetween library and administrative methods, they find the lattersupports archival goals of preserving the integrity and value ofrecords as evidence, as well as the accountability that is owedby those who act on behalf of others in organized social life.References to accountability have appeared in many writingsby archivists on their discipline, and accountability is not anew concept in archival theory. In the context of directorganizational relationships, it has been used to characterizethe origin, role and value of records in administration; as ithas come to be applied to abstract relationships such as 'thepeople' and their government, archivists have used it to describethe nature, role and value of archives and archival repositoriesin society. As well, the tension between the desire to servescholarly purposes and the need to preserve and protect thecontext and integrity of archives can be illuminated and perhapsresolved by an understanding of the role accountability plays inrecordkeeping. David Bearman has claimed, "what is importantabout accountability and its documentary requirements is tounderstand that they are, and have historically been, theessential purpose of archives," but archivists have paid littleattention to understanding the source of their raison d'etre. 168167 Ibid., 41.168 Ibid., 42.99The lack of a conceptual grasp of the issue can lead to'dysfunctional' archival systems and methods which fail tosupport the accountability that organizations owe.If records provide the evidence that supportsaccountability, recordkeepers become accountable for theiractions with regard to that evidence. The next chapter,therefore, will examine how the concept of accountability appliesto archivists.100CHAPTER 3THE ACCOUNTABILITY OF ARCHIVISTSThe records that are preserved for accountability enableindividuals and organizations to maintain legitimaterelationships of delegation, and to uphold the rights andobligations that flow from those relationships, by providingevidence of what has been done and why. Persons who keep suchrecords are required to act responsibly by both ensuring anddemonstrating that the records and their valuable qualities areprotected.The fact that accountability through records impliesaccountability for records was recognized by American archivistsin the 1940s, as when Phillip Brooks wrote that, "government in ademocracy involves accountability to the governed for records ofits actions."' More recently, the Canadian Treasury Board hasrequired that government departments assign responsibility fortheir information holdings "to help ensure authenticity, accuracyand availability of information" and that they "provide acentrally co-ordinated inventory of corporate holdings to:provide knowledge of what is held; provide access to the holdings...[and] provide traceability of information flows. 2 The policyis linked to the new Access to Information Act, because, as JohnSmart has pointed out, "once there is federal legislation which1 Phillip C. Brooks, 'Planned Archival Procedures for Records Retirement,' American Archivist 11 (1948): 315.2 Canada, Treasury Board, Office Systems Standards Working Group, 'Information Management inOffice Systems: Issues and Directions' (Ottawa, 1990), 8.101gives Canadians the right to ask to see files created and held bytheir national government, that government must be able to saywhat records it holds and what has happened to any records itonce created but does no longer hold." 3While it is becoming a more familiar concept in publicrecords management, archivists have rarely discussed their ownaccountability. Its existence can be inferred by consideringwhat their behaviour might be if they were not accountable forthe records in their care. Individuals could follow irrationalimpulses in preserving, disposing of and providing access to thedocuments, in the same way as do private collectors of art ormanuscripts. There would be no published or unpublishedguidelines for practice because they might inhibit the excerciseof archival autonomy and creativity. Archivists would notconsult one another for advice, criticize another's work, orexplain their actions to others. Since records creators and thepublic would be uncertain about whether fonds existed and wereaccessible, or about their authenticity or completeness, therecords could not be used for accountability.Fortunately, archivists have not behaved this way, partlybecause, as it has been examined in the second chapter, they haverecognized the importance of records in accountability systems,and partly because the institutional context of their ownactivities has only delegated to them their authority andresources. Were archival repositories merely storehouses,3 John Smart, The Archival Records of Labour Canada,' ALC1111SILLA 27 (Winter 1988-89): 117.The Treasury Board has its own interest in departmental accountability.102archivists would simply guard the materials. But in thetwentieth century they have sought, or found it necessary totake, a more active role in managing records than the image of'keeper' implies, and they have claimed the knowledge, skill andimpartiality necessary to control the public and private recordsof importance to institutions and society. One result ofincreased archival authority over records has been a requirementfor responsiveness to external interests and needs. Archivistshave also had to develop theories, policies and procedures sothat their actions will not be capricious. They have createdsystems of documentation to record their record keepingactivities and have had to accept and respond to criticism oftheir actions from both inside and outside the profession.Examples from the history of archival practice can illustrate thedevelopment of these aspects of the accountability of archivists.While decisions to acquire records have often been made adhoc, using subjective and intuitive insight, 4 the decision todestroy them usually has required responsible judgement anddocumentation. In fact, in direct contrast to the appraisalphilosophy of fingerspitzengefuhl, the archival finger held up tothe wind, Phillip Brooks insisted that "in no case does theGovernment depend upon the judgment, which may be humanlysubjective, of any one person to decide what is to be kept andwhat destroyed."5 Public records that had no value to archivists4 Klumpenhauwer, Concepts of Value 44.5 Brooks, 'Planned Archival Procedures,' 313.103were important to others for accountability, therefore proceduresof records scheduling were developed to enable consultation withthose who could assess administrative, operational, fiscal, legaland audit values of records. 6 The schedule itself documents thereasons for the disposal decision and the process ofconsultation, ensuring accountable records destruction. Theformal procedures still require archivists to judge and justifythe permanent value of records, and the intense scrutiny ofappraisal theory in the United States in the 1940s and '50sreflected a need to meet this new responsibility with rationalstandards. Shellenberg's theories were not only published asarchival literature, they were also official policy of theNational Archives of the United States and continue to guide theappraisal judgements of its staff today.Archivists usually work as employees rather than freelancepractitioners, in repositories that delegate authority fordesignated functions and require an identifiable archivist toaccount for the expenditure of funds and for actions taken onrecords. Repository policies, whether official or unwritten,have always subordinated the practice of individual archivists toinstitutional needs, beginning with the archival principles ofrespect des fonds and original order, first issued as directivesin the national repositories of France, Prussia and theNetherlands. Large repositories develop systems to manage thecare of records, carefully allocating limited time and resources6 Although accountability of archivists has not been often articulated since the 1940s, themethods and practices that support it are still used.104to specific tasks and documenting actions, for example throughaccessioning forms or appraisal reports. As one archivistexplained, the latter serve "to document and support thearchivist's recommendations" and are permanently preserved asevidence.'The recent experience of the National Archives of Canadawith the Commission of Inquiry on War Criminals (the DeschenesCommission) underlines the importance of policies, procedures anddocumentation for delegated disposal decisions. During thecourse of the inquiry, witnesses and newspaper reports challengedthe destruction of immigration records by the Archives as beingsuspicious and improper, alleging that the records could haveassisted investigation of the entry of Nazi war criminals intoCanada after World War II. As Robert Hayward has explained,"fortunately for all concerned, every action in this case takenby Archives officials was adequately documented: notes to file,memoranda, copies of forms, letters exchanged with theDepartment." 8 Staff could show, also, that they had followedrepository policies in their actions and even though the policiesmay have been inadequate, staff members could not be blamed. Theunusual experience of outside scrutiny proved that, for theArchives as well as other departments, "playing by the rules of7 Kathy Roe Coker, "Records Appraisal: Practice and Procedure,' American Archivist 48 (Fall1985): 420. Kogan argues that, despite contemporary biases against hierarchy, a managerialstructure is as compatible with 'benign' professional and public initiatives, as withtotalitarian ones, and "reduces ambiguity about objectives and [increases] accountability becausethose in charge are identifiable' (Rducation Accountability 40).8 Robert J. Hayward, " working in Thin Air': Of Archives and the Deschenes Commission,"Archivaria 26 (Summer 1988): 127.105the bureaucratic book, particularly rules authorized by someoneelse, is critical when administrative decisions are questioned." 9Hayward particularly emphasized for archivists, "the crucialimportance of both carefully justifying appraisal decisions andrecording all acquisition activity, and...leaving clear paper(audit) trails to document their actions in these areas.The Deschenes Commission also highlighted the role ofrecords in government accountability, raising compleximplications for those who keep them. In the 1940s and 1950s,the federal government only preserved such documentation ofimmigration decisions as it needed for its own operations. Butthe Commission recommended that, for the future, new proceduresensure that the Department's questioning of applicants on pastactivities, "is reduced to writing and signed by the applicant.Where the application is granted, the forms should be kept untileither it is established or it can be safely assumed that theapplicant is no longer alive.i 11 The Archives has been concernedto keep records on government immigration policies foraccountability and samples of immigration files for socialhistory research, but it does not preserve the evidence needed tochallenge or affirm government action in individual cases. And9 Ibid., 130.10 Ibid., 131. Jerome O'Brien discusses briefly the implications of archival accountabilityon appraisal methods in 'Archives and the Law: A Brief Look at the Canadian Scene ' Archivaria 18(Summer 1984): 43-44. Attempts by the Australian Archives to 'meet the new standards ofconsistency, efficiency and accountability' are described by Beverly Hart, Stephen Ellis and IanPritchard in "The Appraisal and Scheduling of Government Records: A New Approach by theAustralian Archives " American Archivist 50 (1987): 591-597.11 Quoted in ibid., 129-130.106yet, if these applications are to be kept as evidence for ahundred years or more, the Archives would have to adjust itspractices to protect the accountability purpose of the records.Nor is this an isolated example. The past ten years havewitnessed unprecedented revisions of past decisions affectinghuman rights, justice or environmental matters, and there is noreason to believe the trend will not continue in the future.While the increased accountability of archivists can beeasily illustrated, archival writings do not provide a clearindication of to whom the accountability is owed. Archivistshave relationships with the donors of the archives, with thesponsors of their repositories and with the users of theirholdings. They also perceive themselves to have obligations tosociety, in both the present and the future, to their profession,and to the valuable records which are their principal concern.At different times archivists have regarded certain of theserelationships as analogous to delegation, and therefore requiringsome form of accountability.Archivists in the past usually saw themselves as acting onbehalf of the creators of the archives, who had delegated to therepository the care of their records. This is evident incontemporary institutional and corporate repositories, as well asearly in the history of government archives, when departments hadnot completely relinquished authority over their records. SolonJ. Buck generalized his position in the National Archives of theUnited States to the whole profession in 1947:107The archivist is essentially the servant orrepresentative of the agencies that created, not theindividual documents, but the bodies of archives orofficial records that have been placed in his custody.It is his responsibility to preserve the integrity ofthose bodies of official records, to make them or theinformation in them available to those agencies or theirsuccessors, and to render such service on them to othersas does not interefere with his primaryresponsibilities. 12Manuscript libraries and similar historical repositories alsoaccepted that a donor would place conditions on the care andaccessibility of 'private' records. One manuscript curatorexplained in 1929 that his relationship with donors was paramountbecause "our institution...stands in law and in ethics in eachcase in the shoes of the individual who originally received aswell as him who deposited with us the missives.H 13 It wasappropriate, therefore, for the archivist-curator to ensure thatany researchers who used the documents did not interfere with theinterest of the donor or damage the relationship of trust.He reviewed their notes, judging the accuracy andpropriety of quotations, and made researchers sign astatement pledging that they had a serious motive, freeof malicious intent, and that no trouble would ever arisefor the institution as a result of their work in itsholdings .14Presumably, the signed statement not only reinforced appropriatebehaviour by the researcher, but also protected the repository incase of donor dissatisfaction.12 Solon J. Buck, The Archivists 'One World' ' American Archivist 10 (1947): 10. This isalso Jenkinson's position.13 Edgar R. Harlan, quoted in Raymond H. Geselbracht, The Origins of Restrictions onAccess   American Archivist 49 (1986): 146.14 Ibid.108A new attitude towards researcher rights has led non-institutional repositories to claim ownership over the records intheir care and has weakened their concern to serve recordcreators. However, while repositories have attempted torationalize access restrictions, they still respect them. Beforethe articulation of public rights of access, Dominion ArchivistW. Kaye Lamb saw the role of the Public Archives of Canada asthat of trustee of the records on behalf of the creator:The relationship of a responsible and conscientiousarchivist to much of the material in his care isessentially trusteeship...the archivist makes thematerial available, or restricts its use, in accordancewith rules of access laid down by the department...so faras private papers are concerned, strict observance of theconditions of a deposit is the cornerstone upon which theintegrity of the institution rests. 15Rules of access to public records are now laid down bylegislation, but the observation probably remains true for mostrepositories holding non-government records.A repository often receives the funding and authority thatsupports its actions from a source other than the creators of thearchives, and it owes some form of accountability for the way thefunds are spent. For example, since its founding the PublicArchives of Canada has acquired and preserved non-governmentrecords. While the preservation, destruction and accessibilityof federal records is governed by laws, Parliament has neverspecified which non-government records should be preserved,except through the Archives mandate to support Canadian history15 W. Kaye Lamb, "Presidential Address,' Canadian Historical Association Annual Report (Toronto, 1958), 8.109and identity. Nor has Parliament ever set standards for care oraccessibility of non-government archives, leaving such matters tothe discretion of the Dominion Archivist, who accounted for thefunds received with annual reports describing the Archives'accomplishments. Modern archival reports often cite use oracquisition statistics that measure the effectiveness of therepository, while others emphasize the high quality or efficiencyof the archival service, but like all reports they must be basedon records supporting the claims. According to Hilary Jenkinson,an archival description of records is also evidence with which anarchivist "renders account of his stewardship, "16 revealing thecare and skill brought to the work, and its completion.Similarly, published descriptive tools, such as guides, do notsimply disseminate knowledge of particular archival holdings,they also serve to account for a project or repository to'resource allocators' and the public from whom tax dollarsderive.Archivists are accountable to their sponsoringorganization, whether a government, university or historicalsociety, and may be under pressure to meet its goals byencouraging research in a particular field or being directlyrelevant to contemporary scholarship. The orientation towardsresearch has meant that many archivists, rather than seeingthemselves as trustees on behalf of record creators or officialsfulfilling their sponsors' mission, regard themselves, as Herman16 Jenkinson, Manual 120.110Kahn put it, as partners to historians "in the great enterpriseof research and writing." 17 That a partnership entails some formof accountability, became apparent in the early 1970s, when newexpectations of scholars and the public were voiced. Kahn andother archivists at the Roosevelt Library were accused by a userof 'serious abuse of archival power', in not making availablematerial that was being used for a repository research project. 18One historian described the more general user dissatisfaction as"a growing conviction that custodians of Government archives, atbest, are overworked and hobbled by bureaucratic procedures or,at worst, are lazy, capricious, and inefficient." 19 The samehistorian advocated bureaucratic procedures to deal with users'complaints, and reporting by archivists to users to 'restoremutual trust'. 20In response to such assertions of the rights ofresearchers, archivists became conscious of the need to provideaccessible catalogs and finding aids for all of their holdings,even restricted ones, and to announce acquisitions or specialprojects. In light of the increased volume of holdings and ofrequests, many repositories now try to provide the means wherebyusers can search descriptions of the holdings for themselves,17 Herman Kahn, 'The Long-Range Implications for Historians and Archivists of the ChargesAgainst the Franklin D. Roosevelt Library,' American Archivist 34 (1971): 267.18 Richard W. Leopold, 'A Crisis of Confidence: Foreign Policy Research and the FederalGovernment ' American Archivist 34 (1971): 141.19 Ibid.20 Ibid., 152, 154-5.111rather than attempting to inform each, individually, of thesources that might meet their needs, thus escaping blame forinadequate assistance.21 Criticism from within and outside theprofession has also led many archivists in research repositoriesto distinguish their role more sharply from that of users, andrather than seeing the relationship as one of partnership, regardit as one of service. For example, it has only recently becomean important principle of archival practice that researchers betreated fairly and equally, and be given the opportunity to usethe resources of the repository in whatever manner, or forwhatever purpose, they desire.The recent emphasis on public rights to governmentinformation and researcher rights has led some archivists toargue that the relationship between a repository and its users ismore important than that with its archives creators or sponsors.Mark Hopkins has written that "our supporting role as archivistsin relation to a society's right to information and research mustkeep us at arm's length from the interests of the creating agencyand closer to the interests of our research clientele. ..22 OtherCanadian archivists have argued in favour of "a new recognitionof the importance of archivists' responsibilities with respect tothe public and to the necessity of clearly defining our21 Kahn, for example, complained that time and money spent in trying to keep everybodyinformed about what is going on everywhere is almost certainly going to be wasted,  in The Long-Range Implications,' 273.22 Mark Hopkins, ''There's a Hole in the Bucket, Dear Liza, Dear Liza': Archivists'Responsibilities Reviewed ' Archivaria 16 (Summer 1983): 136.112obligations and goals in this area." 23 Some archivists perceiveaccountability to users or to the public as one such obligation,arguing that archival theories and practices should be designedto meet public standards and obtain public approval. Tom Nesmithhas written that "archivists must be able to account above allfor the history of the documentation they turn over to theresearcher since they have been solely responsible for its placeand care." 24 Hans Booms devised his documentation theory in theearly 1970s because "it is necessary for archives actively topromote public scrutiny of, and input into, their work as much aspossible. "25Documentation strategies and plans, which have beenprominent in archival theory in the 1980s, are designed to obtainpublic authorization for acquisition decisions, reducing thearchivists' responsibility for appraisal. Like the theories ofselection developed in the 1940s and 1950s, these proposalsrespond to a perception that archivists should not be the solejudges of the permanent values of records, and that rationalstandards are needed to meet new, extremely varied andunpredicatable research interests in documentation for socialhistory 'from the bottom up'. However, as Booms and othersdiscovered, public participation or approval of archival23 Gabrielle Blais and David Enns, From Paper Archives to People Archives: PublicProgramming in the Management of Archives   Archivaria 31 (Winter 1990-91): 103.24 Tom Nesmith, 'Archivaria After Ten Years," Archivaria 20 (Summer 1985): 15.25 Hans Booms, 'Uberlieferungsbildung: Keeping Archives as a Social and Political Activity,'Archivaria 33 (Winter 1991-92): 29.113decision-making has not been possible and there have been nopublicly sanctioned documentation plans on either the German orthe American model. 26 Nor has the assumption of accountabilityto the public gone unquestioned. For example, at least one ofBooms' colleagues argued that "first of all, state archivistshave a primary responsibility to document the structure andfunctions of the administration which sponsors theiractivities..." 27 Similar arguments have been made in NorthAmerica. A municipal archivist has written that, because localgovernments have statutory obligations for record keeping,archivists must serve those obligations first, and do soeffectively and economically, for "if we ignore accountability toour sponsors...we do so at our own peril. 1128As explored earlier, administrative and politicalaccountability requires the preservation of the records thatprovide evidence of actions, although particular users ofarchives might be interested in the information for otherreasons. The accountability purposes of the records requireadherence to archival principles of respect des fonds andoriginal order, despite the frequent criticism of provenance byusers wanting subject and problem-oriented arrangement and26 Ibid., 28; Richard Cox, 'A Documentation Strategy Case Study: Western New York,' AmericanArchivist 52 (1989): 192-200.27 Quoted in Klumpenhauwer, Concents of Value 148.28 Anthony L. Rees, 'Masters in our own House?' Archivaria 16 (Summer 1983): 59.114description. 29 Archival strategies for public relations have notaddressed how archivists might deal with the experience, provenin other areas of social life, that public involvement includescriticism and demands, as well as support.Finally, schemes for direct public accountability, whetherin archives or other institutions, overlook the fact that theauthority which allows the repository to be organized and tooperate legitimately does not derive directly from the public.Although archivists, like others, believe in the abstract conceptof public sovereignty, there are no mechanisms for establishingan ongoing relationship of delegation directly with users orsociety, nor should there be. If the public has information andresearch rights with respect to archives, it is the obligation ofthe accountable individuals and organizations, not just archivalrepositories, to fulfill them. It may be that a stronger senseof accountability is needed among archive creators, so that theyacknowledge their obligation to preserve or delegate thepreservation of their records for the information of others, thusreducing the need for repositories to rescue neglected recordsthat are considered to be important to society. However,archivists cannot meet the accountability obligations of recordscreators behind their backs. No organization would delegate careof its records to an archivist or repository that it regarded asirresponsible. Archivists have been caught in the contradictions29 See for example, Peter Baskerville and Chad Gaffield, 'Shifting Paradigms and EmergentTechnologies: Archives in the Modern Research World,  in Archives. Automation and Access ed.Baskerville and Gaffield, 15-25; and Philip Goldring, Some Modest Proposals: A Public HistorianLooks at Archives ' Archivaria 24 (Summer 1987): 121-128.115of a political philosophy that allowed government business in ademocracy to be conducted privately, and which did notacknowledge public rights to public records. In formerly EasternBlock countries archivists acted in accordance with the politicalphilosophy of the governments whose records they preserved.Those previously secret archives are now being used, in the newpolitical climate, to discover, denounce and revise the pastbecause they are authentic and complete evidence of the actionsof the archives creators. Archivists ought not to be blamed forpreserving the evidence. 30What distinguishes public archives in North America fromthose in formerly communist countries of Eastern Europe, is thatwhile they derive their authority to act from the government orfrom their sponsoring institution, they do so in order to servethe public. Resource allocators, donors and transferringdepartments provide the repository with its mandate, which may beservice to the records creator, service to the sponsor, serviceto scholars or the general public, or service to the records.The repository owes accountability to its sponsoring institutionfor how it fulfills that mandate. The nature of theaccountability, whether for results such as the number of users,or for efficient and effective archival practice, will reflectthe relationship of delegation and the needs of the recordscreator or sponsor. If rights to information and research havebecome first principles in society, this should be reflected in30 Vladimir Kajlik, 'Czech Archives at the Crossroads ' American Au,hivist 54 (1991): 412-422.116the repository mandate, and thus in policies and procedures foropen and responsive archive keeping.While repositories may receive a clearly articulatedmandate from their sponsor, for adherence to which accountabilityis owed, the authority and legitimacy of the work of archivists,in many cases, no longer derives simply by delegation from thatmandate. The ambiguity and complexity of the relationshipsbetween archivists, creators and users has been heightened by theprofessionalization of archival work. There are many analyses ofthe characteristics of a profession, but an examination of itsaccountability obligations must consider the delegationrelationships it entails. One analysis has posited that clientsdelegate decision-making authority, in a particular area of theirlives, to professionals, because the latter have theoreticalknowledge which is difficult and time-consuming to acquire andwhich is necessary to solve practical problems. In theory,professionals promote only their clients' interests, as opposedto their own or that of the system in which they work, and theyact in as unbiased and objective a manner as possible. 31Generally, professional archivists are employed, by anarchives creator or a repository, as specialists in theidentification and care of permanently valuable records. 32 Users31 Carolyn J. Tuohy and Alan D. Wolfson, The Political Economy of Professionalism: APerspective,' in Pour Aspects of Professionalism (Ottawa: Consumer Research Council Canada,1977), 47. Professionalism first emerged in those areas of people's lives - legal, health andspiritual matters - where an objective and highly competent agent acting in one's best interestswas most critical.32 In archive work, as in society generally, the use and promotion of professionals hasdeveloped as an alternative to patronage.117consult archivists for reference advice, but employ researchassistants when they require agents. Yet it is in the nature oftheir work for archivists to regard current and future users astheir clients, and to try to promote their interests bypreserving and protecting valuable records. As has been shownearlier, the division between records management and archivalwork has been based on rigid allegiance to different interests,while a perspective compatible with archival principles andaccountability needs to be based on a recognition that recordsserve multiple and changing interests. 33Another important relationship characterizing a trueprofession, which may be inappropriate for archivists, arisesfrom the existence of the profession as an institution whichempowers individual members, such as lawyers and doctors, to act,provides them with considerable autonomy and sets limits to theiraction. 34 Because of the esoteric knowledge required for thework, it is commonly argued that only colleagues can judge eachothers actions, and professionals are almost exclusivelyaccountable to their professional associations. Professionals'internalize' standards of conduct through codes of ethics. Acode of ethics is33 See for example, Felix Hull, "The Appraisal of Documents-Problems and Pitfalls," journal of the Soceitv of Archivists 6 (1980): 291.34 "The providers of a service stand in a professional relationship to consumers to theextent that the provision of that service is regulated by an organization of providersexcercising authority delegated by the state" (Tuohy and Wolfson, "The Political Economy ofProfessionalism," 48); John Kultgen Ethics and Professionalism (Philadelphia: University ofPhiladelphia Press, 1991), 38.118an articulation of the terms of reference within whichparticular agency relationships are established betweenindividual practitioners and their clients. Itconstitutes not only a set of prescriptions, but istreated as a set of enforceable rules governingindividual practitioner-client relationships. 35However, the profession does not wish to scrutinize actively thework of its members, so that, in general, "clients trust toprofessional traditions and professional ethics" to instill thehigh standards that they require. 36 Therefore, as Kogan pointsout, professionalism tends to be associated with responsiveness,or areas of "morality, influence and power rather than authorityand accountability." 37Archivists, like other occupational groups, are seeking aprofessional identity partly in order to increase their status inthe eyes of their sponsors and society, which is important toobtain the authority to manage archives. They are placing agreater emphasis on self-criticism and explanation within theirdiscipline and there is a concerted movement to createdescriptive, acquisition and other standards of practice, toaccredit practitioners or repositories, and to establish codes ofethics, following the pattern of all developing professions ofpreventing the inadequate performance of individuals fromundermining the legitimacy of the entire group. 3835 Tuohy and Wolfson, "Political Economy of Professionalism," 56.36 Quoted in Kultgen, Ethics 91.37 Kogan, Education Accountability 32.38 Kultgen, Ethics 102. Other typical strategies, including establishment of professionalassociations and recognition in the university curricula, can found in current initiatives ofNorth American archivists.119However, the institutional setting which archivists occupy,the lack of a clear practitioner-client relationship, and thefact that their work is not essential to individual members ofthe public, make it very unlikely that archivists will ever befully self-governing professionals. Nor should this necessarilybe regretted. Kultgen argues, "experience shows thataccountability of members of a profession to one another is notsufficient to protect the public interest."39 The pursuit of aprofessional image for an occupation can be a self-serving desirefor status and remuneration. The professions have beencriticized as a 'self-accrediting elite', a privilegedaristocracy based on education instead of birth. 4° Efforts tomake professionals more accountable to society or to thegovernment that, increasingly, funds their activities, have notyet been successful, nor have all professional groupsacknowledged their accountability. 41In claiming a professional role for themselves, and thusjob security, autonomy, status, good pay and interesting work, itis not sufficient for archivists to cite their knowledge andskill. Richard Cox writes, "The essence of professionalism is39 Ibid., 164.40 Quoted in ibid., 277.41 For example, Peter Aucoin, 'Public Accountability in the Governing of Professions: AReport on the Self-Governing Professions of Accounting, Architecture, Engineering and Law inOntario," unpublished working paper prepared for the Professional Organizations Committee,Ministry of the Attorney General, Toronto, 1978.120having power within society" 42, but archivists should not assumethat power comes without corresponding responsibility. Nor isthe achievement of a more professional and authoritative positionmerely a matter of marketing and persuasion. Archivists need toaccept and demonstrate an increased sense of responsibility, forexample, to manage records efficiently, and a willingness todocument their actions. In addition to adopting standards foractions, professionals should accept the right of others toscrutinize, receive explanations and judge actions by thosestandards.Whatever the wisdom of establishing an archival profession,all archivists can cultivate what Kultgen terms the 'ideal ofprofessionalism'. For example, archivists can recognize thatsince they have been delegated the care of records on behalf oforganizations, in order to serve society, they should do soaccording to organizational and social needs, and not to servetheir own interests or a narrow interpretation of those needs.They can set and meet high standards for archival work, andattempt to inform and influence record creators to act in waysthat not only meet their own needs, but also reflect values suchas good government, accountability and freedom of inquiry.Archivists can be knowledgeable about the ethical standards andsocial obligations of their work. 43 One particularly importantvalue in archival work, as in other fields, is 'communicative42 Richard J. Cox, 'Professionalism and Archivists in the United States ' American Archivist 49 (1986): 47.43 Kultgen, Erbics 269-73.121integrity', involving both respect for individual privacy andstrict veracity.The organic society is not unified by controls over itsmembers. It does not require prying and peeking intoevery cranny of private life...This requires the properbalance of protection of the right to privacy, whereprivacy can be allowed, and insistence on publicity,where publicity is necessary. 44Finally, professionalism requires a service ethic, which can bedefined simply as promoting the good of the one served. 45While the concept of accountability has a specialsignificance for archivists because of the use of records as itsinstrument, like other professionals operating in the publicsphere, archivists are concerned with their own accountability.But, as Blais and Enns point out, "archives operate in a fluidenvironment, in which resource allocators, donors, supporters andvarious user groups play an increasingly prominent role." 46 Noclear and simple resolution of the issue of to whom, and forwhat, archivists owe accountability can be expected, becauserelationships in our society are no longer sharply drawn,universally accepted or clearly hierarchical. Archivists areinvolved in a network of relationships and seem to oweaccountability in various directions and to various degrees. Aswell, archivists are closely associated with archivalrepositories, and act in ways that will protect and promote boththe archival resource and the institution. It is not surprising44 Ibid., 344.45 Ibid., 352.46 Blais and Enns, "From Paper Archives to People Archives,  110.122that there are conflicts between the accountability archivistsowe to the institution that funds and supplies administrativelegitimacy to their work and whose records they care for, to thecollegues and institutions that provide them with theirprofessional legitimacy, and to 'society' on whose behalf theycare for the records. An understanding of the concept ofaccountability cannot resolve these conflicts, but it can clarifythe debate by focussing on the nature of archival authority, thefunctions delegated to repositories, the discretion given toarchivists, the standards by which archival actions should bejudged, and how any accounts should be rendered. Kutgen arguesthat "an effective system of responsibilities would defineexactly who is responsible, for what sort of actions, for whatgroups of people or aspects of people' welfare, and to whom," 47but such a system could only exist in an ideal world. Bycontemplating the features of an accountable archival system, andunderstanding what inhibits its achievement, archivists can atleast strive for the ideal.47 Kultgen, FX.hics 163.123CONCLUSIONArchivists are accustomed to discussing the ethical, legaland political issues that relate to their field in termsassociated with individual rights, because that is the commonlanguage of our times. Accountability, on the other hand, isfundamentally a duty. It is the obligation of a delegate toaccount for what has been done. Delegating can be distinguishedfrom both a grant outright and an appropriation, because itcreates a continuing relationship between the principal whodelegates authority for some purpose and the agent whoaccomplishes the task. The agent's role in this relationshiprequires that information and explanation about that action beavailable to the principal, without whom it could not haveoccurred and who has the right to know of and judge it.Organizations and their administration are founded ondelegation of authority, and accountability is therefore afeature of most administrative relationships. By involvingothers to accomplish actions, people organize themselves to meetpurposes and needs that would not be possible if each acted ontheir own. Accountability provides reliability to such organizedactions, sustains trust in the relationships involved, andenables delegation to succeed.The concept of accountability is an abstraction fromfamiliar circumstances of delegation. The concept can be foundin a range of contemporary writings on political theory,constitutional law, administration and certain professionalfields, however few sources use it unambiguously or in a manner124that is immediately relevant to archivists. In particular,although the concept originates in direct and concreterelationships between individuals, it is more often applied toindirect and abstract ones, such as political representation.Within the idea that governing authority is delegated to thestate by citizens, the concept of accountability implies the needto acknowledge that relationship.The connection between accountability and records forms thebasis for the role of the concept in archival theory. Theaccount required by accountability is information about actionstaken. While verbal accounts are still important in directrelationships, written accounts have long been essential wheredelegation lines are complex or the agent is removed from dailycontact with the principal. Agents who respect their duties ofaccountability preserve written records of the actions that weretaken with delegated authority, while those who destroy, concealor alter their records, whether through lack of awareness oftheir obligations or specifically to avoid detection, are notmaking themselves accountable, even if later they may be 'heldaccountable' through legal action. It is the creation,preservation and accessibility of information compiled in orderto meet the obligation to account, rather than the subsequent useof that information, that truly reveals accountability. Inpractice, therefore, accountability is often achieved throughprocedural and routine creating and setting aside of evidence ofactions, records.125Thus, accountability has many implications for archives andarchival theory. An obligation to account results in actionsbeing documented and in documents preserved that would nototherwise be kept. The source of delegated authority oftenrequires documentation according to standard forms andprocedures, providing the resulting records with a characteristicof predictability that is less often found in products ofindependent action. The timing of any call for account, and therecords that will meet it, depend on the particular relationshipof delegation and the significance of the actions; however, ifthe creator of an archival fonds has acted in a delegatedcapacity, then the arrangement, function, form, value,accessibility and ownership of the records may all be determinedby accountability.Archival theory has long recognized the importance ofarchives for preserving the rights of individual citizens, buthas less generally acknowledged the role of records in ensuringaccountability. Nonetheless, the concept of accountability hasfrequently appeared in archival literature. In discussion andexamples of arrangement and description, the ubiquity ofaccountability in the conduct of affairs and the use of recordsas its instrument provide an understanding of the context ofcreation of the archival material, explaining the function ofcertain records and predicting their subject matter. In thespecific areas of records management and electronic recordstheory, the concept of accountability explains the organizationalneed for preservation and access to records, and for controls126that ensure the existence and integrity of evidence. Inappraisal theory, the concept has been evoked with regard to thevalue of public records and the timing of their archivalacquisition or destruction. Routine records produced in volumeto meet administrative accountability have only short-term value,because the actions they document are relatively peripheral tothe primary functions of an organization and because proceduresexist to summarize and audit them. On the other hand, minutes,reports, policy documents and the records of decision-makingofficials have longer term value because they record actions ofconsiderable consequence for the organization, its constituencyand clients, while there is rarely a formal means to dischargethe accountability they serve.The concept of accountability has also been used to linksystematic preservation of archives and liberal access policiesto the legitimacy of institutional authority. It is most oftenapplied to public records because citizens in a democracy have anacknowledged right to call their government to account, andbecause government actions seem to determine many aspects ofmodern society. Deliberate preservation of and provision ofaccess to public archives is a means of ensuring accountabilityof the state to the citizens, because destruction of recordsafter a limited period of time would deny the opportunity forknowledge of what the state as agent has done. Unless it hasbeen explicitly discharged, accountability endures as long as therelationship of delegation continues, which, for publicinstitutions embodying ongoing relationships, is indefinitely.127At times, archivists have expressed the opinion that historicaland other scholarly work serves an audit function on behalf ofthe general population, but the assumption underlying that view,that scholars should be in a privileged position with respect touse of archival sources, has lost acceptance, on the grounds thatthe general public is entitled to equal and more timely access tomaterial.Seminal writings on modern public archives and recordsmanagement considered accountability a principle which shouldguide archivists. However, after the 1950s, the volume of modernrecords and apparent changes in the needs of users divided theprofession between the records managers who destroyed records andthe archivists who rescued them for secondary uses unrelated totheir origin. The administrative nature of archives and theirvalue for accountability largely disappeared from the theoryguiding the two professions. As well, the concept ofaccountability and its relationship to records can hardly befound in other scholarly disciplines after 1950, because thelegitimacy of authority was challenged, and information came tobe studied as a means of decision-making rather than decision-judging. Still, the high resonance of archival access, ownershipand destruction issues in the past two decades has meant that,while some archivists question whether evidence of theorganization and functioning of public agencies is worthpreserving, others have the conviction that such evidence has anorganizational and social value. But, without a solid and128accepted basis in archival theory, this point of view isdifficult to articulate.The significance of accountability increases with theresponsibility of the agent. In proportion to our belief thatauthority for certain actions in society is not a matter ofinherent right but of delegation, the deliberate preservation andaccessibility of evidence of those actions should becomeimportant. The concept of accountability implies that publiclyavailable archives are not a status symbol or privilege, but therecognition of an obligation to account for what has been done.The concerns that some archivists have manifested, thataccountability results in biased or incomplete records, can onlybe resolved ethically when those who owe the duty ofaccountability accept it. This might be encouraged if theconcept were emphasized as an acknowledgement of the rights andinterests of those who provide authority, and thus legitimacy foractions, rather than as a mechanism for the control of agents.The concept of accountability complements, rather thancontradicts, the idea of personal privacy. Individuals do nothave the same right to privacy with regard to the actions thatthey perform as agents as they do for their self-determinedactivities. However, the information required by a principaldiffers in particular situations: Every detail of financialtransactions is subject to review, while the process of reachingpolicy decisions may be essentially private. As access toinformation laws acknowledge, an individual's entitlement toprivacy must apply to personal information that has been129collected in order to carry out actions for which publicaccountability is owed.Accountability to the public does not require preservationof every document created or received. Access to informationinitiatives make available records that have already been createdand preserved for the functioning of the state as a bureaucracy,rather than as the agent of the people. These records serve theneed for accountability within the organization, documentingdecisions, procedures, and results in carrying out each action.To reduce this volume of information there needs to be aconscious assessment of the extent and reliability of therecordkeeping system, and authorized discrimination betweensignificant and insignificant actions, important and unimportantevidence for public accountability. This is what recordsmanagement and archival appraisal can accomplish.Archivists have also applied the concept of accountabilityto their own professional obligations. Authority over archivalmaterials appears to have changed hands. Except where claims forpersonal privacy must be respected, the original creator ofarchives no longer sets the standards for preservation ordestruction, arrangement and description, publication orreference use of the records. Both the users of repositories andthe archival profession have claimed a right to set thosestandards, the former on the basis of their needs, the latterbecause of its knowledge. Yet the institution sponsoring thearchival repository, which provides it with its mandate, stillprovides considerable authority and carries responsibility for130actions on archival materials, especially if the records are usedfor accountability. In the absense of a clear delegation ofauthority to archivists, they cannot owe exclusive accountabilityeither to their profession, to archives users, or to recordscreators, but the concept remains a useful reminder that aprofessional is not self-determining, or absolved fromresponsibility to others.Archivists are concerned with the need to preserve recordsin their context, and part of that context is accountability.The concept is only really meaningful for archival theory inconjunction with the understanding that the nature and meaning ofarchives lies in their origin as means and evidence of action,rather than in their subsequent uses as sources of information,and the concept is only found in the archival literature whichasserts this view. Archives are unique and valuable because oftheir nature as written evidence. 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