Records Managers

NARA Bulletin 2010-02

February 5, 2010

TO: Heads of Federal agencies

SUBJECT: Continuing Agency Responsibilities for Scheduling Electronic Records

EXPIRATION DATE: February 28, 2013

  1. What is the purpose of this bulletin?

    This bulletin reminds Federal agencies of their continuing responsibility to schedule all their electronic records series and electronic systems, including website content records. This bulletin also requires agencies to report to NARA semi-annually on the status of their electronic records scheduling activities.

  2. How does this bulletin differ from NARA Bulletins 2006-02 and 2008-03?
    NARA Bulletins 2006-02 and 2008-03 expired on October 1, 2009. This bulletin replaces the expired bulletins and provides updated guidance and new reporting requirements to assist Federal agencies in meeting their statutory and regulatory records management responsibilities for their electronic records.

  3. What is the background for this bulletin?

    Federal agencies are legally required to identify and schedule all their records, including electronic records, in accordance with the following authorities:

    • Section 207(e) of the E-Government Act of 2002 [44 U.S.C. 3501], directs the Archivist of the United States to issue policies requiring the adoption by agencies of policies and procedures to ensure that Chapters 21, 25, 27, 29, and 31 of Title 44, United States Code, are applied effectively and comprehensively to Government information on the Internet and to other electronic records; and

    • 44 U.S.C. Chapters 31 and 35, Office of Management and Budget (OMB) Circular A-130, and NARA regulations in 36 CFR Ch. XII, Subchapter B (effective November 2, 2009), requires Federal agencies to have effective and comprehensive records management programs for all of their records.

  4. What must agencies do to implement this bulletin?

    Federal agencies must continue to manage their records consistent with 44 U.S.C. Ch. 31, 44 U.S.C. 3506, 36 CFR Chapter XII, Subchapter B, Records Management, and OMB Circular A-130, par. 8a1(j) and (k) and 8a4. This bulletin highlights agency responsibilities under these authorities to identify and schedule all electronic records series and electronic systems, and to transfer to NARA when eligible all electronic records that have a permanent retention.
    1. Existing electronic records. For all agency records created or received as of the date of this issuance, agencies are already required to:

      i. Implement processes and procedures to manage electronic records in existing agency systems;
      ii. Identify and schedule electronic records in electronic information systems;
      iii. Transfer to NARA permanent electronic records from existing or legacy systems according to NARA-approved records schedules; and
      iv. Implement timely destruction of temporary records according to NARA-approved records schedules and agency guidelines.

    2. New electronic records systems. Federal agencies are reminded that OMB Circular A-130, par. 8a(1)(k) requires agencies to incorporate records management and archival functions into the design, development, and implementation of information systems, which includes obtaining the approval of the Archivist of the United States for retention schedules covering Federal records. Agencies are also required by 36 CFR 1236 to incorporate records management controls into their electronic information systems or recordkeeping systems to ensure that agency records can provide adequate and proper documentation of agency business for as long as the information is needed (i.e., for their NARA-approved retention period).

    3. Reporting requirements. This bulletin requires Federal agencies to report to NARA semi-annually on the status of their electronic records scheduling activities. The report must include (a) the name and description of all unscheduled electronic records series or systems; (b) the progress on drafting records schedules for these unscheduled electronic records series and systems, including when they will be submitted to NARA for approval; and (c) the percentage towards completion for scheduling all existing electronic records series and systems. The report must be submitted twice a year to the designated NARA appraisal archivist or records management contact on or before March 31 and September 30 of each fiscal year.

    4. Compliance. To ensure compliance with these reporting requirements, agencies should refer to 36 CFR 1236.26 for guidance on the maintenance and review of agency inventories of electronic information systems. Additional guidance and techniques to assist agencies in scheduling their electronic records is included in Attachment 1 of this bulletin.

  5. Whom do I contact for additional information ?

    NARA's National Records Management Program (NRMP), including the Life Cycle Management Division in Washington, D.C., and Records Management staff in NARA's regional offices, provides assistance and advice to records officers of agencies headquartered in Washington and in the field.
    Your agency's records officer may contact the NARA appraiser or records analyst with whom your agency normally works for support in carrying out this bulletin. A list of the appraisal and scheduling work group and regional contacts is posted on the NARA web site at http://www.archives.gov/records-mgmt/appraisal/index.html.

    If you need more general information about the contents of this bulletin, please contact Laurence Brewer, Director of the Life Cycle Management Division at Laurence.Brewer@nara.gov or on 301-837-1539.

DAVID S. FERRIERO
Archivist of the United States


NARA BULLETIN 2010-02

ATTACHMENT 1

Techniques for Scheduling Agency Electronic Records Systems

This attachment provides general approaches that agencies should use to identify and schedule their existing unscheduled electronic records. This guidance is consistent with requirements specified in paragraph 4(d) of this bulletin, and with 36 CFR Part 1225, Scheduling Records.

  1. What strategies should agencies implement to schedule their unscheduled electronic records?

    Agencies should develop a project plan to identify and schedule their unscheduled electronic records that includes the following tasks:

    1. Develop, review, and refine your agency's inventory of electronic information systems.
    2. Identify existing General Records Schedule (GRS) items and approved agency-specific records schedules that may be used to cover identified electronic systems.
    3. Prioritize the application of agency scheduling resources to focus first on the unscheduled electronic records systems that contain records warranting permanent preservation or that contain mission-critical records.
    4. Collect descriptive and technical information (i.e., metadata) about each electronic records series and system from the system owners and custodians.
    5. Consult your NARA appraisal archivist or records management contact to submit your records schedules for NARA approval.
  2. What sources of information should agencies use to develop their inventory of "existing electronic information systems"?

    To develop current and comprehensive records schedules for all agency electronic records and systems, agencies must determine what series and systems exist in the agency, which office owns and manages the information, and whether the electronic series or systems contain Federal records. The following agency offices and officials are important sources of information that can assist agency records managers with answers to the above questions:

    • Office of the Chief Information Officer (CIO). Agency CIO and information technology (IT) staff routinely develop and maintain inventories of electronic information systems to comply with the Federal Information Security Management Act (FISMA). CIO offices also create and maintain Office of Management Budget (OMB) Exhibit 300 inventories that list agency information systems. It is important to note, however, that many of these systems do not contain records.

    • Office of the General Counsel (OGC). In many agencies, OGC is developing inventories of electronically stored information (ESI) to support e-Discovery efforts.

    • Privacy Act and Freedom of Information Act (FOIA) Offices. Agencies publish Privacy Act System of Records Notices (SORN) that include electronic records systems, which in many cases, are unscheduled. A System of Records is any group of records under agency control from which information is retrieved by the name of the individual or by some identifying number, symbol, or other identifier assigned to the individual. The Privacy Act requires agencies to publish notice of its systems of records in the Federal Register.

    When reviewing these sources of information, it is important keep in mind that only those electronic information systems that contain and provide access to computerized Federal records must be scheduled. Other IT systems on the inventories, such as IT infrastructure systems, are not subject to the scheduling requirement.

  3. What other recommendations does NARA have for agencies scheduling their existing unscheduled electronic records?

    a. Review the revised records management regulations. NARA promulgated revised records management regulations effective November 2, 2009. These new regulations provide updated guidance covering the scheduling and management of existing and new electronic records series and systems. The regulations are available on the NARA web site at: http://www.archives.gov/about/regulations/regulations.html.

    b. Identify existing disposition authorities for potential use in managing electronic records series. Agencies should begin their scheduling project by identifying all electronic series and systems that do not require a new records schedule approved by NARA (i.e., already covered by the GRS or a NARA-approved agency-specific schedule). Agencies are encouraged to refer to the GRS to provide disposition authority for records created in many administrative business processes (e.g., human resources, budget, travel, procurement). See http://www.archives.gov/records-mgmt/grs/ for a list of the GRS and links to the specific schedules. For most records series covered in the GRS an agency may apply the given authority to records in all media, i.e., paper and electronic. Except where exclusions are noted, an agency may use the GRS to cover unscheduled temporary and permanent electronic series and systems without submitting to NARA a new SF 115, Request for Records Disposition Authority (see GRS 20, Item 3 for further guidance).

    c. Establish priorities. After identifying the electronic series and systems that remain unscheduled, agencies should prioritize where to begin. In consultation with NARA, agencies should develop a plan that focuses on series and systems that may contain permanent records or that support mission-critical business processes. Establishing priorities involves assessing risks to the records, and an understanding of how the records support the protection of citizens' rights and assure government accountability.

    d. Consider your options for scheduling the records. Before drafting the records schedules, NARA encourages agencies to consult with their appraisal archivist or records management contact to determine the type of schedule that is most appropriate for the records created in your agency. Agencies may continue to submit records schedules with series that include multiple electronic systems, or may submit schedules covering specific systems. Agencies may also consider the guidance and models in NARA Bulletin 2005-05, Guidance for Flexible Scheduling (http://www.archives.gov/records-mgmt/bulletins/2005/2005-05.html) . Further advice on developing flexible schedules will be issued shortly.

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