Frequently Asked Questions about GRS 5.1, Common Office Records
Updated: April 2024
1. What are “non-recordkeeping copies” in item 020?
Non-recordkeeping copies of records have the following characteristics:
- They are records. This means that they have a purpose and use beyond convenience and ease of reference. They are neither non-record nor personal records. In some cases, the record may have been used to conduct business, but it is not the copy kept in the official recordkeeping system. Email is often an example of this scenario.
- They are not the recordkeeping copy. Agencies identify certain copies of records as recordkeeping copies. Agencies keep recordkeeping copies to document the actions and decisions of government. In some cases, they may be the original copy of a record that now resides in a formal recordkeeping system. For example, you may draft a document then download a copy and place it in a formal case file system. In this case, the original document is a non-recordkeeping copy.
2. What is the difference between a "non-record" and a "non-recordkeeping copy"?
The primary difference is that a “non-record” is not a record and a “non-recordkeeping copy” is a record. A non-record does not meet the definition of a federal record. A federal record is recorded information made or received by the federal government in the course of business. Non-record materials include copies of records kept only for convenience of reference, stocks of publications, and library and museum material. (See 44 U.S.C. 3301.)
Non-recordkeeping copies are made and received in the course of business. Employees often use them when making decisions or taking actions. That is the key part: employees use the records for more than convenience of reference.
Email is a good example of a non-recordkeeping copy. Most agencies copy email to an official recordkeeping system for long-term preservation. Sometimes it is filed in a case file, but more often it is kept in an email archiving system. That email is the recordkeeping copy. It is the copy the agency manages and uses as the official documents of government. Copies of those same messages that exist in your local email account and are used to conduct business are still records, but are non-recordkeeping copies.
3. Non-record keeping copies of electronic records (item 020) includes “copies of the above electronic records maintained in websites or web servers, but EXCLUDING web pages themselves.” What is a “web page” in this context?
A web page in this context is the electronic files that make up the page as it appears on the web. These include HTML or XML files, style sheets, and any other associated files.
Agencies may use this item for copies of electronic documents, spreadsheets, or audio/visual files that appear on websites. This includes embedded files as well as online repositories (if they are non-recordkeeping copies). What they cannot use the item for is the web page itself. Agencies must schedule their web pages and websites.
4. Why does item 020, Non-record keeping copies of electronic records, only cover electronic copies?
The GRS does not provide disposition for copies except in specific cases. Copies often support business processes that are different from the original record. Copies should be scheduled in the context they are used.
The item for non-recordkeeping copies of electronic records came about in the age of print-and-file. Back then, the analog copy was the recordkeeping copy. The original electronic copy was still a record, however, and required a disposition authority. In the current digital world, it is often harder to tell which record is the "original" and which is the "copy."