Federal Records Management

NWM 04.2010

December 22, 2009

MEMORANDUM TO FEDERAL AGENCY RECORDS CONTACTS: Advice on implementing records management requirements of Open Government Directive (OMB M-10-06)

On December 8, OMB issued OMB M-10-06 which is instructions to executive departments and agencies to take specific actions to implement the principles of transparency, participation, and collaboration set forth in the President’s Memorandum on Transparency and Open Government, issued on January 21, 2009. The role of records management in fostering transparent and open government is explicitly acknowledged in those instructions. This memo is intended to draw your attention to those specific requirements and to direct your attention to existing NARA records management regulations and guidance that is germane to agencies’ attempts to implement these instructions.

The link to OMB M-10-06 is
http://www.whitehouse.gov/sites/default/files/microsites/ogi-directive.pdf and the link to the President’s Memorandum on Transparency and Open Government is http://www.whitehouse.gov/the_press_office/TransparencyandOpenGovernment/.
Two parts of M-10-06 explicitly mention records management:

  • 1. Publish Government Information Online (a)Agencies shall respect the presumption of openness by publishing information online … and by preserving and maintaining electronic information, consistent with the Federal Records Act and other applicable law and policy. …
  • Attachment: Open Government Plan (3) Components of the Plan (a) Transparency (v) -- A link to a publicly available website that shows how your agency is meeting its existing records management requirements (36 CFR Chapter 11, Subchapter B). These requirements serve as the foundation of your agency’s records management program, which includes such activities as identifying and scheduling all electronic records (per E-Government Act of 2002, Pub. L. No. 107-347, section 207(e)) and ensuring timely transfer of all permanently valuable records to the National Archives.

NARA has significant guidance to assist agencies in accomplishing these directions.

  • The Toolkit for Managing Electronic Records http://www.archives.gov/records-mgmt/toolkit/ is a web portal that provides summary descriptions of a collection of guidance products for managing electronic records and resources (“tools”) that have been developed by NARA and other organizations.
  • NARA Bulletin 2008-03 http://www.archives.gov/records-mgmt/bulletins/2008/2008-03.html discusses agencies’ responsibilities for scheduling electronic records under the E-Government Act of 2002.
  • The records management portion of NARA’s website http://www.archives.gov/records-mgmt/index.html contains many valuable resources that define record management requirements and provides foundational material for agencies’ records management programs.

In addition, the OMB instructions for publishing government information online indicate “b. …agencies should publish information online in an open format… .” NARA’s Frequently Asked Questions (FAQs) About Selecting Sustainable Formats for Electronic Records http://www.archives.gov/records-mgmt/initiatives/sustainable-faq.html provides relevant information that may be useful in making an appropriate open format selection.

This same set of instructions require agencies to “d. …identify and publish online in an open format at least three high-value data sets… .” Agencies’ records schedules provide a practical place from which to identify these data sets.

Finally, the requirement for each agency to “e. …create an Open Government Webpage… to serve as the gateway for agency activities related to the… directive...” necessitates agency determination of the record status of such a significant web page. NARA’s Guidance on Managing Web Records http://www.archives.gov/records-mgmt/policy/managing-web-records-index.html can assist agencies in appropriately managing records of their Open Government website.

The linkage between the Administration’s initiative to provide greater openness in Government and the benefits derived from the application of appropriate records management is not only duly noted in OMB Memo M-10-06, but a critical factor to the success of the initiative . NARA is pleased to be able to provide salient and timely guidance in support of this critical initiative.

Paul M. Wester, JR.
Modern Records Programs