FAQs for GRS 5.2, Transitory and Intermediary Records

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QUESTIONS ABOUT ITEM 010 – TRANSITORY RECORDS

For more information on applying this item to electronic messages, see Frequently Asked Questions (FAQs) about Transitory Records in Electronic Messages

1. Why does this item include seemingly non-record materials such as “messages received from agency distribution lists or listservs” and “notifications, circulars, newsletters, and email blasts to employees”? 

Just because something is a copy does not mean that it is non-record. If it is used for decision-making or taking action, it is a record. Only reference copies are non-records. To assist agencies that do not want to declare these materials non-record, we have crafted this item to clearly distinguish and designate them as records of a transitory nature.

QUESTIONS ABOUT ITEM 020 – INTERMEDIARY RECORDS

2. What constitutes a meeting in the second bullet in item 020?

A meeting, for the purposes of this schedule, is a gathering (whether in person, via telephone, online meeting space, other means, or combinations of these) of a board, commission, advisory group, committee, task force, or other assemblage of Federal employees (or employees and members of the public), at which agency business is transacted or discussed.  This definition includes staff meetings but does not include interrogations, interviews, or other situations whose purpose is to subject individuals to questioning.

3. What are input or source records in the fourth bullet in item 020?

Input records are the sources of information agencies enter into an electronic system.  They support creating, updating, or modifying master files an agency keeps for recordkeeping purposes.  Input records may be electronic files or hardcopy (non-electronic) documents. They may include records such as upload files staged for ingest into a system or hardcopy forms scanned or otherwise entered into the system.

Not all input processes create separate records. Input processes that do not create a separate input record include:

• Structured data the user enters from online forms, and unstructured (textual) data that is born digital (i.e., not scanned from paper).
• Data moved automatically from another system with no associated data file.  Thus, the data is copied from one system to the other without creating an intermediary data file.  (For example, data are pulled from one system to populate another, and fields from System X are used to populate System Y.)

4. Please explain the statement that 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.

Generally, the final record to which an intermediary record contributes fills all recordkeeping needs.  On rare occasion, an agency may require an intermediary record—for example, an original input/source document with a wet signature—to meet such obligations or to provide such evidence.  In this case, the document is more than an intermediary record, and GRS 5.2, item 020, may not be used to dispose of it.

5. Can an electronic system’s content ever consist entirely of intermediary records?

Yes.  If a system’s sole function is to receive and integrate data from two or more other systems and export the resultant product to yet another independent system, it is known as a “pass-through system.” GRS 5.2, item 020 covers such a system’s content.

6. What does “verification of successful creation” mean in the disposition instruction for item 020?

“Verification of successful creation” means that the agency has taken steps to ensure that hardcopy or analog records have been converted to electronic format in their entirety, that no information or pages are missing, all information is readable (especially in cases where records are scanned), and that the electronic version of the record can be opened.  It is up to Federal agencies to define their verification procedures. NARA does not have specific requirements for how agencies should verify that they have successfully converted records to an electronic format.

7. Why does this item’s fourth bullet include hardcopy input source documents only if we incorporate all information on the document into an electronic system?

Unless all of the information in a hardcopy original is contained in its electronic counterpart, the electronic record does not fully duplicate the input record’s information.  For example, if a hardcopy source record contains an annotation not clearly included in the scanned copy, the scan does not entirely duplicate the input record. The input record therefore contains unique information that may change its value and the agency should retain it. 

Another example is data entered from a form.  If not all of the form’s data is entered into the system, then the source record has not been copied in its entirety.  One exception may be a form used to check a record already in the system. If information on the form already matches what is in the system, there is no need to update the information in the system.  In that case, the source record is still being copied in its entirety because the information on the input form and in the system is the same. As long as all the information in the source document has a one-to-one relationship to information in the electronic version and they match, the source record is being copied in its entirety.

8.   What are “inaccessible permanent records” in Exclusion 2? Why does item 020 exclude summarized information derived from such records?

Electronic records may be scheduled as permanent but a given record may be lost, corrupted, or otherwise unopenable or unreadable.  In that case, a data file output containing summarized information may be the only accessible version of the record, and NARA might want to take this output record in place of the inaccessible/unavailable permanent master record.  This exclusion does not mean that agencies must keep such outputs in case the permanent record becomes inaccessible at some future point. It only means that, if the master file is inaccessible right now, and you have the output records , you should contact NARA to see if you should transfer the output records instead.

9. Under what conditions are input records covered or not covered by item 020?

The following two tables explain the conditions under which input records are covered or not covered by item 020.  If the input records are in hardcopy format:

If the input records are in electronic format:

Note:  The agency must either schedule any electronic files it creates specifically from one system as an input to another system or dispose of them using GRS 5.2, item 020, regardless of whether the originating system is scheduled. The disposition authority for the original system is not a valid authority for input files the agency creates from that system.

10. When is it not appropriate to destroy input records according to item 020 once they are converted to an electronic format? 

Agencies may find that in certain circumstances they have a business need for the source records even after they have converted the records to an electronic format.  In such cases, agencies may determine that it is not appropriate to apply the GRS for converted input/source records. Agencies should assess their business need for the source records and may establish a longer retention period in their agency-specific disposition manuals without additional NARA approval.  In some cases, source records may be or become part of another records series scheduled on an agency-specific schedule. In these cases, the agency-specific schedule should be applied rather than item 020. For example, if the source record is part of another record, such as a case file, but the electronic version of the record is not a copy of the entire case file or has a separate purpose from the case file, then an agency-specific case file disposition authority, rather than item 020, may apply to the source record.

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