January 31, 2014
TO: Heads of Federal Agencies
SUBJECT: Revised Format Guidance for the Transfer of Permanent Electronic Records
EXPIRATION DATE: Expires when revoked or superseded
1. What is the purpose of this Bulletin? (See end note****)
This Bulletin specifies which file formats are acceptable when transferring permanent electronic records to NARA. This Bulletin contains an appendix that will be updated to reflect the continual format changes in how agencies create and use electronic records. This Bulletin replaces all previous guidance identifying file formats that may be used when transferring permanent electronic records to NARA.
This guidance supports the requirements in Item A1, Section A, Part II, of OMB Memorandum M-12-18 Managing Government Records Directive to make available revised guidance for transferring permanent electronic records.
2. Does this guidance apply to all Federal permanent electronic records?
Yes, this Bulletin applies to all electronic records that have been appraised and scheduled for permanent retention. Specifically, it covers electronic records that are created, used, and managed on computer systems and which can be moved between computer file systems without alteration of the original method of encoding. It applies to records that originated electronically, such as word processing files or digitally recorded sound, as well as those that are digital representations of records which originated in a non-electronic form such as paper or film. The records management and transfer requirements for audiovisual and cartographic formats that are dependent on specific physical media are described in 36 CFR 1237. Metadata requirements for electronic records will be issued separately. Until they are published, agencies must comply with existing requirements for documentation and metadata as described in 36 CFR §§ 1235.48, 1236.12, and 1237.28.
3. What are some of the ways this guidance is different from NARA’s previous guidance?
Key changes from NARA’s previous guidance include:
a. There is no longer guidance dedicated to the Portable Document Format (PDF). PDF is now listed in each of the format categories for which it is appropriate. If PDF does not appear within a format category, then it is not appropriate for use with electronic records of that type;
c. There are now categories for Digital audio and Digital moving images, which expand on the Frequently Asked Questions (FAQ) About Digital Audio and Video Records;
d. There is a format category specifically for Computer aided design (CAD); and
e. Word processing and office automation formats are identified as appropriate for use with textual records.
4. What electronic formats will NARA accept for transfer?
- This Bulletin describes several additional categories of electronic records and expands the number of acceptable formats that NARA will accept for transfer, based on their sustainability. Sustainability as it relates to electronic file formats is the suitability of a format to preserve encoded information over time.
- Factors that contribute to a format’s sustainability include the availability and completeness of documentation, and the availability of applications that can interpret it. These factors are used by NARA to analyze formats that are in common use to determine their appropriateness for agencies transferring permanent records.
- Format categories provide a method of grouping formats that either share a common method of encoding, or are used to store the same type of data. The categories serve to provide a convenient way to associate formats that are generally used to store a particular electronic record type. The new format categories are:
5. What formats are included in each category?
NARA has identified preferred and acceptable formats for each category in the tables found at http://www.archives.gov/records-management/policy/transfer-guidance-tables.html (see Appendix A). Because files formats change frequently, the tables will be updated as needed to reflect new preferred or acceptable formats. Criteria such as the availability of technical specifications and licensing restrictions will be used to determine whether a format is sustainable and appropriate for use with permanent electronic records.
Formats are identified by name and by the relevant specification that defines appropriate encoding methods. Many file formats, especially those used with digital audio and video, are composed of multiple parts including a wrapper, which is the file format, and an embedded encoding stream or codec. In these cases the format category table will include a column that specifies the codec or codecs that may be used with each format. Agencies must submit electronic records in files that are valid both according to the wrapper and any specified codec standards.
6. Do transfers have to be records of only one format?
Transfers do not have to be records of only one format. This guidance assumes that transfers will be permanent records described by schedule items and will include files that are encoded in a format identified as preferred or acceptable as listed in this guidance. NARA does not require embedded files, attachments to email messages, or other subsidiary files included in the transfer to conform to the format categories under which they would fall if they were transferred on their own.
Transformation of an electronic record from one format to another could result in changes to the record content, structure, or metadata. Agencies that maintain records in formats that do not conform to this Bulletin should contact the appropriate NARA office, as listed in Section 11, before migrating, converting, or altering the permanent records to meet the NARA format requirements.
7. How and when should I transfer permanent electronic records to NARA?
Agencies should transfer records in accordance with the cut-off and disposition instructions on the approved disposition authority. Typically, agencies transfer legal custody to NARA when the records are 15 to 30 years old and are no longer needed to conduct the agency’s business. Acceptable transfer media and methods are described in 36 CFR 1235.46. More information on NARA transfer methods can be found on the NARA Transfer of Electronic Records page. When transferring electronic records, agencies should identify the applicable format category table and submit records in a format identified as ‘Preferred’, ‘Acceptable’, or ‘Acceptable for Imminent Transfer’. Formats identified as ‘Acceptable for Imminent Transfer’ are legacy formats that are no longer in common use and that NARA will eventually stop accepting. Agencies with permanent records in any of these formats should contact the appropriate NARA office, as listed in Section 11, to arrange for transfer.
8. What other steps should I take before transferring permanent electronic records?
In some cases, additional steps must be taken to ensure that permanent electronic records will remain accessible for as long as they are needed. Before transferring permanent electronic records, agencies should:
- Separate temporary records and non-record materials from permanent electronic records;
- Identify sensitive information within records that may require screening before the records are available to the public: e.g., personally identifiable information (PII), such as Social Security Numbers of living individuals, law enforcement information, and proprietary information;
- Ensure that all fonts necessary to interpret the information in each record are embedded when the files are created; and
- Comply with any existing agency policies regarding the encryption of physical media used to transfer electronic records to NARA.
Where possible, agencies should use available technology to cull non-record information and temporary records that are eligible for disposal under a previously approved records disposition authority from transfers of permanent electronic records – e.g., transitory records. Where the agency does not take these steps, NARA may exercise its discretion to do so, using the authorization provided in the transfer documentation.
In most cases, NARA screens records before making them available to the public when the transferring agency indicates that the records contain sensitive, non-public information. Accordingly, agencies are strongly encouraged to provide to NARA as much information as possible about the type and location of the sensitive information when transferring the records, in order to make NARA’s screening more efficient and effective. For example, if an agency transfers a database with individuals’ SSNs and dates of birth, the agency should indicate that these fields may be restricted.
In addition, in all cases, agencies must:
- Deactivate passwords or other forms of file level encryption including digital rights management (DRM) technologies commonly used with audio, video, and some publications that impede access to record data;
- Ensure permanent electronic records are valid according to the file format specifications identified in this guidance; and
- Retain a copy of all permanent electronic records transferred to NARA until receiving official notification that NARA has accepted legal custody of the records.
9. What access will I have to the records I transferred?
For accessioned records, NARA will provide access to all researchers requesting records accessioned from Federal agencies, subject to review of content for Freedom of Information Act (FOIA) exemptions or NARA’s General Restrictions (36 CFR Part 1256), as applicable. NARA may provide additional access to withheld records to the creating agency, or other agencies, Congress, or parties in litigation where there is a particular need. While compliance with these requirements will improve future access to accessioned records, NARA's ability to provide access to certain records will vary according to any hardware and software dependencies. At the present time, NARA provides users with the best available copy of fully releasable electronic record files on media currently approved by NARA. Users will be responsible for obtaining any hardware and software necessary to view the records.
10. What other NARA guidance on electronic records is available?
- NARA Bulletin 2011-01 Checklist of Current NARA Bulletins and List of Records Management Guidance in Effect: includes a checklist of the current NARA bulletins and list of records management guidance in effect;
- NARA Bulletin 2013-02 Guidance on a New Approach to Managing Email Records: provides agencies with a new records management approach, known as “Capstone,” for managing their Federal record emails electronically. This Bulletin discusses the considerations that agencies should review if they choose to implement the Capstone approach to manage their email records;
- NARA Bulletin 2014-02 Guidance on Managing Social Media Records: provides high-level recordkeeping requirements and best practices for capturing records created when Federal agencies use social media;
- Toolkit for Managing Electronic Records: provides descriptions of a collection of guidance products for managing electronic records. It includes resources (“tools”) that have been developed by NARA and other organizations.
- NARA Bulletin 2010-05 Guidance on Managing Records in Cloud Computing Environments: outlines the risks and challenges of records management in the cloud, highlighting the need for agencies to designate and control the record copies of all Federal records created in the course of business;
- NARA Bulletin 2007-02 Guidance concerning the use of Enterprise Rights Management (ERM) and other encryption-related software on Federal records: provides information on the use of Enterprise Rights Management (ERM) and other encryption-related software;
- Frequently Asked Questions About Media Neutral Schedule Items: NARA established that all records schedule items submitted on or after December 17, 2007 be media neutral, to improve the process of scheduling electronic records. This change in policy makes all schedules media neutral except for items explicitly limited to a specific recordkeeping medium (36 CFR 1225.12(e)); and
- PKI Digital Signature Authenticated and Secured Transaction Records: provides records management guidance to Federal agencies for PKI digital signature authenticated and secured electronic transaction records.
11. Who should I contact for additional information?
For information related to the transfer of electronic records, the agency must consult with the National Archives and Records Administration, Electronic Records Accessioning and Processing Staff (RDEP), 8601 Adelphi Road, College Park, MD 20740, general telephone number (301) 837-3420, email Etransfers@nara.gov.
For information specific to transferring digital photographs and their accompanying metadata, the agency must consult with the National Archives and Records Administration, Special Media Archives Services Division, Still Pictures (RDSS) for digital photographs, 8601 Adelphi Road, College Park, MD 20740 email firstname.lastname@example.org. Special requirements for digital photographs are described in 36 CFR 1237.28.
For information specific to transferring digital audio or video files and their accompanying metadata, the agency must consult with the National Archives and Records Administration, Special Media Archives Services Division (RD-SM) for digital audio and video, 8601 Adelphi Road, College Park, MD 20740, telephone number (301) 837-2903.
If additional information is needed, or if you have questions about any part of this Bulletin, please contact your agency’s Records Officer. A list of agency records officers can be found on the NARA web site at http://www.archives.gov/records-mgmt/agency/officers-lists.html. Your agency's records officer may contact the NARA appraisal archivist with whom your agency normally works. A list of the appraisal contacts is posted on the NARA web site at http://www.archives.gov/records-mgmt/appraisal/.
****NARA bulletins provide fundamental guidance to Federal agencies, who must then determine the most appropriate ways to incorporate recordkeeping requirements into their business processes and identify the specific means by which their agencies will fulfill their responsibilities under the Federal Records Act.
Updated: February 25, 2014