NARA Bulletin 2017-01
November 29, 2016
TO: Heads of Federal Agencies
SUBJECT: Agency Records Management Training Requirements
EXPIRATION DATE: Expires when revoked or superseded
In September 2014, OMB and NARA jointly issued Memorandum M-14-16, Guidance on Managing Email, reiterating a previous requirement from the Managing Government Records Directive (M-12-18) for agencies to establish and develop suitable records management training. In July 2016, OMB issued the revised Circular No. A-130, establishing policy for the management of Federal information resources and specifically requiring the implementation of records management training and guidance for agencies.
- What is the purpose of this Bulletin?
This Bulletin provides the minimum requirements for agency records management training programs. The Bulletin identifies who must take records management training and how often this training must be provided. It also describes promising practices for the development and administration of training. This Bulletin supplements the general training requirements outlined in 36 CFR 1220.34.
Agency Records Management Training Requirements
- This Bulletin applies to all agency personnel, which includes Federal employees, contractors, volunteers and others that create, receive, access, or use Federal records on behalf of the agency.
- All agency personnel with email accounts or IT network resource access must complete records management training within 60 days of employment and must complete annual refresher training.
- Agencies must provide records management training to all agency personnel that create, receive, access, or use Federal records on behalf of the agency, regardless of whether those individuals have email accounts or IT network access.
- Agencies must develop records management training content specific to the practices and policies of the organization.
- Agencies must incorporate the following minimum required content areas into annual records management training:
- Define Federal records.
- Describe how records management supports the agency's mission and business processes, and public access to government information.
- Provide an overview of government-wide and agency-specific records management policies and recordkeeping requirements.
- Explain legal responsibilities for creation, maintenance, and disposition of Federal records.
- Describe the stages of the records management lifecycle, to include the creation, maintenance and use, disposition, and the difference between temporary and permanent records, all of which are addressed in the agency's disposition schedule.
- Describe how to distinguish records from nonrecord materials and personal materials.
- Describe how records are maintained and filed in the agency, including:
- What is a records schedule, its legal authority, and where to find their agency's schedules;
- Why it is important to follow records schedules or file plans; and
- How records schedules or files plans are implemented and updated.
- Explain how legal holds (sometimes called records freezes) and the discovery phase of litigation affect records handling, retention, and disposition.
- Describe how and where to store agency Federal records.
- Describe how agency information technology (IT) systems are used for records management (if applicable, how to use agency records management technologies).
- Describe how to manage record and nonrecord materials in email, social media, and other electronic messages, including the statutory requirement that all emails and other electronic messages constituting a record that are sent or received using a personal or non-official account must be copied or forwarded into agency recordkeeping systems within 20 days of creation or receipt.
- Describe what to do with record and nonrecord materials when an employee leaves the agency.
- Describe what to do when records are removed, lost, or destroyed without proper authorization.
- Describe where to get more information about records management (e.g., websites, manuals, agency's records schedule, file plans, and agency Records Officer contact information).
- Provide agency contacts for records management questions. Include information for the field and/or headquarters points of contact for retiring records to storage, transferring permanent records, destruction of records, and answering records management questions.
- Agencies must provide targeted records management training to political appointees, senior agency officials, and senior executives upon their arrival and departure, and within three to six months prior to a presidential administration change. This may include conducting entry and exit interviews with your agency's records management staff, IT liaisons, and general counsel to ensure that records are preserved and protected.
- Agency Records Management Training Promising Practices
The following are promising practices that agencies should consider when developing a records management training program:
- Develop and Administer Joint Mandatory Training With Related Topics
Agency records officers and other staff should consider developing and administering RM training in concert with other mandatory training programs, such as information security awareness, privacy, or cyber-security training. This will create cost efficiencies, consolidate mandatory training cycles, and minimize training fatigue from the annual mandatory training requirements separately administered throughout the year.
- Training Design
Agency records management staff should coordinate with learning and development professionals to assist with the design, development, and tracking of training. Agencies should design training so that individuals apply what they are learning during training. Agencies are also encouraged to develop assessments to verify that trainees have learned the content.
- Role-Based Training
Agencies should offer records management training specific to the needs of the following groups:
- Senior level agency officials and political appointees;
- Records professionals at all levels within the organization;
- Managers and supervisors;
- Acquisition, contracting, and procurement personnel;
- Attorneys engaged in litigation or advising on records or access to information issues;
- Personnel developing and managing IT systems and applications; and
- Continuity of Operations and Disaster Preparedness personnel that manage mission essential records.
5. Whom should I contact for more information?
If additional information is needed, or if you have questions about any part of this Bulletin, please contact firstname.lastname@example.org.
DAVID S. FERRIERO
Archivist of the United States