NARA Bulletin 2023-04

TO: Heads of Federal Agencies

SUBJECT: Managing Records Created on Collaboration Platforms

Expiration Date: Expires when revoked or superseded

1. What is the purpose of this Bulletin?

This bulletin addresses the management of federal records created when agencies use collaboration platforms. For purposes of this bulletin, a collaboration platform is a space to communicate and produce a work product with others. While collaboration platforms provide messaging capabilities between individuals and groups, communication is only one component of collaboration. 

NARA is issuing this bulletin to address agencies’ increased use of intra/inter-agency collaboration platforms to accomplish their missions. The capabilities of collaboration platforms are increasingly robust and can be used when working from any location. Within the federal government, these platforms provide an environment that supports rapid and effective collaboration. They have become a regular part of government work culture. 

NARA conducted an assessment of agency use of collaboration platforms, Inter-Agency Collaboration Applications which informed the development of this Bulletin. Six agencies participated in this assessment, each with varying platforms, tools, and needs. The assessment showed that agencies are using collaboration platforms on a daily basis.

This bulletin builds on the guidance in NARA Bulletin 2009-02: Guidance Concerning Managing Records in Multi-agency Environments. This bulletin does not contain guidance on capturing records on specific collaboration platforms.

2. How are collaboration platforms typically used? 

Collaboration platforms enable people or organizations to hold video conferences, edit documents in real-time, share files, send messages, take notes, and schedule meetings. This allows for collaboration platform members to participate from any location either synchronously or asynchronously. In addition, federal agencies use collaboration platforms to work with internal staff, other agencies, and external groups in the public and private sector. The content created in collaboration platforms can be accessed on many types of devices. 

The term “collaboration platform” is broad. For purposes of this bulletin, a collaboration platform may contain¹: 

• Collaboration Suites: Google Workspace, Microsoft 365, Nextcloud, OpenPaaS, Zoho One 
• Document Collaboration: Box, Google Workspace, Huddle, Max.gov, Microsoft 365 
• File Sharing: Box, DoD Secure Access File Exchange (SAFE), Google Drive, Huddle, Max.gov, Microsoft OneDrive, Nextcloud, Owncloud 
• Email: Gmail, Outlook, ProtonMail, Thunderbird, WorkMail, Zoho 
• Calendars: Amelia, Calendly, Doodle, Google Calendar, Max.gov calendaring service, Nextcloud, Outlook, TeamUp, Thunderbird
• Chat: Discord, Facebook Workplace, Google Chat, HIVE, Jabber, Mattermost, Microsoft Teams chat, Zulip 
• Video Conferencing: Adobe Connect, AWS Chime, Cisco Webex, Google Meet, Jitsi, Microsoft Teams, Verizon BlueJeans, Zoom, ZoomGov 
• Project Management: Atlassian Trello, Salesforce Slack 

3. Can federal records be created on collaboration platforms?

Yes, agency employees create federal records when they conduct agency business using collaborative platforms. This is true for federal employees as well as for agency contractors, volunteers, and external participants working on behalf of the agency. Common records that may be created through collaboration platforms include shared documents, chats, and meeting recordings. Agencies must manage records in collaboration platforms, like all other federal records, in accordance with NARA-approved records schedules. Records schedules identify records created or maintained by a federal agency and provide the authority needed to dispose of records.

4. Should all records in a collaboration platform follow the same records schedule? 

No, not necessarily. For example, one office in an agency could use the collaboration platform to create program documentation covered by a records schedule related to mission functions. Another office may use the same platform to collaborate on purchase agreements or contracts, which fall under a different records schedule or the General Records Schedules (GRS). Agencies will need to examine how different offices are using collaboration platforms to be able to identify what records are being created. They will have to consider if any existing records schedules apply and how they could be implemented. 

Applying records schedules to electronic messages in collaboration platforms poses particular challenges. NARA Bulletin 2023-02 expands the role-based records management approach to electronic messages. Subsequently, NARA updated GRS 6.1 to include certain other types of electronic messages. Question 11 of the GRS 6.1 FAQ contains a non-exhaustive list of examples included or excluded from the GRS. Agencies should determine if GRS 6.1 applies to electronic messages in their collaboration platforms. Electronic messages falling outside the scope of GRS 6.1 must be scheduled with an agency-specific records schedule, whether the schedule is specific to messages or includes other program-related records.

5. My agency wants to procure a new collaboration platform. What records management factors should we consider before doing so?

NARA’s Universal Electronic Records Management Requirements identify high-level business needs for managing electronic records. Agencies should research collaboration platform capabilities to ensure these high-level requirements can be met before procuring and implementing a collaboration platform. It is imperative that agency records officers be stakeholders in the planning, implementation, and maintenance of collaboration platforms. Other stakeholders include program leads, general counsel, FOIA staff, acquisition staff, IT security, and system administrators.

Records management concerns should not hinder an agency’s full use of collaboration platforms. By providing these platforms, agencies maintain more control over the systems and can then determine a strategy to manage and capture content created in those systems. Agency records officers must work with system administrators and program managers to perform a risk-based analysis of how they intend to use the collaboration platform and ensure recordkeeping requirements are identified and met.

6. What are the considerations when implementing records management in an existing internal collaboration platform?

Agencies can use the following questions when discussing how records from internal collaboration platforms should be managed:

• Will records be created within the collaboration environment?
• Who is responsible for the records within a collaboration environment?
• When collaboration takes place across multiple offices within an agency, what are the records management responsibilities for each of the offices?
• Are the records in the collaborative environment scheduled? If so, how long must they be retained according to their records schedule? 
• Is a new schedule necessary?
• Can records created in the collaboration environment be maintained in the platform or do they need to be moved to a separate repository?
• How will the agency be able to respond to requests for information/records contained in the system?
• Can temporary records be deleted in accordance with their retention policy? 
• Can permanent records be identified and exported for transfer to NARA with associated metadata?
• Can records be migrated to another platform as needed in the event the current platform is replaced?

7. What are the records management considerations when using collaboration platforms provided by other agencies or external groups?

In addition to the considerations above, agencies also need to consider the following questions when using collaboration platforms provided by other agencies or external groups: 

• What is the risk the provider will fail to maintain the platform? 
• What if the provider has a shorter retention period than participating agencies for the records created in the collaboration platform?
• Does the provider need to configure records retention to allow other agency retention periods to be implemented?
• Can the provider export or give access to the records for participating agencies? 
• Do the security settings of the collaboration platform allow for the export of records? 

Generally, agency records officers should ensure individuals who join other agency collaboration spaces are aware of their responsibilities. This should be included in agency records management training. For example, if employees from a number of different agencies are drafting and reviewing a document, training should address if employees need to transfer a copy of the final document into their own agency records systems. Agencies should determine records management responsibilities at the beginning of the collaboration and review periodically to ensure arrangements are appropriate.

8. What are agency responsibilities when providing a collaboration platform for other agencies?

In general, NARA expects agencies providing collaboration platforms to manage the records in those platforms according to their approved records schedules. Ideally, the agency providing the collaboration platform is responsible for managing records for all participants in the platform. If this is not practical, the providing agency should make the records available to all participating agencies. 

All agencies participating in a collaboration platform should designate records management responsibilities prior to working together. Agencies also need to consider responsibilities when inviting new agencies to participate in the collaboration platform. Agencies may choose to use a Memorandum of Understanding (MOU) to further clarify the records management roles and responsibilities for collaboration platform participants. 

9. Many collaboration platforms capture every change to a document. Do agencies need to capture all these changes? 

While changes are part of the record, they may be intermediary records covered by GRS 5.2 that only need to be kept for a short time. Agencies should review their internal policies and business needs to set procedures for what changes to retain. To qualify as intermediary, a record must not be required to meet legal or fiscal obligations, or to initiate, sustain, evaluate, or provide evidence of decision-making.

10. Video conference, transcription, and chat capabilities are often included in collaboration platforms. Are agencies required to record every video conference, produce a transcription, or capture the chats from a video conference? 

No, agencies are not required to record every video conference or produce a transcription and capture chats. Agencies should follow the same established records management policies for documenting decisions or other substantive conversations during a video conference as they would for an in-person meeting. The Federal Records Act requires agencies to create adequate and proper documentation of their activities. 

11. If my agency decides to record a video conference, what are my records management requirements?

The content of a meeting recording determines its retention. Meeting recordings with significant value must be maintained in accordance with an applicable agency-specific schedule. If the meeting is recorded only for the purpose of generating meeting minutes, the recording may be destroyed in accordance with GRS 5.2, item 020, Intermediary Records, once the meeting minutes are created. Or, if the recording is only required for a short period of time and is not required to meet legal obligations, it may be destroyed in accordance with GRS 5.2, item 010, Transitory Records.

12. Whom should I contact for more information?

For specific questions regarding your agency operations, you should contact your agency’s records officer. A list of agency records officers can be found on the NARA website at https://www.archives.gov/records-mgmt/agency. 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 website at http://www.archives.gov/records-mgmt/appraisal/.

DR. COLLEEN J. SHOGAN
Archivist of the United States