Records Managers

NARA Bulletin 2000-02

December 27, 1999

NARA Bulletin 2000-02

TO: Heads of Federal agencies

SUBJECT: Disposition of electronic copies; suspension of NARA Bulletin 99-04

EXPIRATION DATE: December 31, 2001

1. What is the purpose of this bulletin?
This bulletin:

  • Notifies you that NARA Bulletin 99-04, Scheduling electronic copies of program records and administrative records not covered by the General Records Schedules (GRS), is suspended. That bulletin covered electronic copies that were created using word processing or electronic mail software that remain on the "live" computer system after the recordkeeping copy is produced. For agencies that have already submitted Bulletin 99-04 schedules or who still wish to submit such schedules, we will continue to process Standard Forms (SF) 115, Request for Disposition Authority, prepared in accordance with that bulletin, as outlined in paragraph 6 of this bulletin 2000-02.

  • Clarifies when the GRS 20 disposition authority for electronic copies (items 13 and 14) may be used. GRS 20, items 13 and 14, which apply to word processing and electronic mail copies, may be used only for electronic copies of scheduled records, and only after a recordkeeping copy has been produced and filed in a recordkeeping system. See in particular paragraph 4 of this bulletin.

  • Reminds you that NARA Bulletin 99-05, Disposition of electronic records (NARA Bulletin 98-02), issued on September 24, 1999, remains in effect. That bulletin states that new and revised items on SF 115s, Request for Records Disposition Authority, submitted for NARA approval must include provision for the disposition of both the copy of a record that resides on electronic mail or other office automation applications, and the recordkeeping copy maintained in the recordkeeping system.

  • Informs you how NARA is further addressing GRS 20, items 13 and 14. See paragraph 2 of this bulletin.

Please read this entire bulletin carefully to ensure that you do not destroy electronic copies of records without appropriate disposition authority.

2. Why is NARA suspending Bulletin 99-04?
Several factors were involved in our decision to suspend Bulletin 99-04:

  • On August 6, 1999, a three-judge panel of the U.S. Court of Appeals for the District of Columbia unanimously upheld General Records Schedule 20 (GRS 20). We believe there may be better alternatives to GRS 20 for disposition authority for electronic copies of program records and expect to develop those alternatives as part of a comprehensive review of the policies and procedures for scheduling and appraisal of records in all formats. The Court decision provides the Government time to include electronic copies in this overall review. Our review may result in significant changes in the way that agencies schedule their records in the future. When we have completed this review, we will promulgate new guidance.

  • Agency resources that would be expended to develop and submit schedules under Bulletin 99-04 are needed to schedule previously unscheduled records and to plan for the implementation of electronic recordkeeping. The Government Paperwork Elimination Act (GPEA), which takes effect in FY 2004, provides a strong impetus for agencies to develop the capability of managing records electronically for their full legal retention period. Under the GPEA (Pub. L. 105-277), by October 2003, agencies must give persons and entities that are required to maintain, submit, or disclose information to the Federal Government the option of doing so electronically when practicable as a substitute for paper, and to use electronic authentication (electronic signature) methods to verify the identity of the sender and the integrity of electronic content.

3. How long will the suspension period for Bulletin 99-04 last?
When we complete our scheduling and appraisal review in FY 2001, we will evaluate whether Bulletin 99-04 should be revised or replaced with an alternative scheduling procedure.

4. What electronic copies of records are covered by GRS 20?
GRS 20, items 13 and 14, authorize only the disposal of electronic copies of scheduled records, and only after a recordkeeping copy has been produced and filed in an electronic, paper or microform recordkeeping system. Scheduled records are those records that are covered by a NARA-approved agency records schedule or by a General Records Schedule.

5. What must I do to get disposition authority for electronic copies of unscheduled records?
Follow the instructions in paragraph 2 of NARA Bulletin 99-05, Disposition of electronic records. You are reminded that agencies are required by 36 CFR 1222.20 and 1222.32 to periodically review their records schedules and by 36 CFR 1228.26 to submit schedules to NARA covering records of new or changed programs within one year of the implementation of the change.

6. Can my agency still submit Bulletin 99-04 schedules?
    a. Yes, NARA will accept and process SF 115 packages prepared in accordance with Bulletin 99-04, Attachment B, that are submitted after December 27, 1999. We also will continue to process Bulletin 99-04 schedules that were submitted prior to this date. We will continue to adhere to the deadlines for NARA action specified in paragraph 14a of Bulletin 99-04.
    b. If you have not begun preparing Bulletin 99-04 schedules and intended to submit a plan on February 1, 2000, you do not have to submit either a plan or Bulletin 99-04 schedules.

7. Where can I get copies of NARA Bulletin 99-05 and GRS 20?
Your agency records officer should have paper copies of NARA Bulletin 99-05 and GRS 20. These documents are also available electronically on the NARA web site. NARA Bulletin 99-05 and GRS 20 is posted at http://www.archives.gov/records-mgmt/grs/grs20.html.

8. Who do I contact for further information?
Your records officer should address questions to the NARA appraiser or NARA records analyst with whom your agency normally works. A list of the appraisal and scheduling work groups is posted .

JOHN W. CARLIN
Archivist of the United States

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