January 2014
Records Management
for
OPM Internal Administrative
Records
Office of Personnel Management
Records Management
For
O
PM Internal Administrative Records
This document implements OPM’s Internal Administrative Records Management Program
Office of the Chief Information Officer, Records Management (OCIO/RM)
January 2014
i
Table of Contents
1. INTRODUCTION......................................................................................................... 9
1.1 Purpose ............................................................................................................................ 9
1.2 Scope and Applicability .................................................................................................. 9
1.3 Compliance, Enforcement, and Exceptions .................................................................. 10
1.3.1 Criminal Penalties .....………………………………………………………………….2
1.3.2 Reporting ………………………………………………………………………………2
2. RESPONSIBILITIES ................................................................................................. 11
2.1 OPM Director................................................................................................................ 11
2.2 The CIO ........................................................................................................................ 11
2.3 Records Officer (RO) .................................................................................................... 12
2.4 Records Coordinators (RCs) ......................................................................................... 13
2.5 Agency Employees, Interns, and Contractors ............................................................... 13
2.6 Senior Officials and Political Appointees ..................................................................... 14
2.7 New Employees, Interns, and Contractors .................................................................... 15
2.8 Human Resources ......................................................................................................... 15
3. RECORDS MANAGEMENT POLICY ................................................................... 15
3.1 Records Life-Cycle Process .......................................................................................... 16
3.2 Records Management Fundamentals ............................................................................ 16
3.2.1 Third Party Records Management of Federal Records ………………………………..9
3.2.2 Identifying and Classifying Records ............................................................................. 18
3.2.3 Series Inventory and File Plan ...................................................................................... 18
3.2.4 Records Scheduling ...................................................................................................... 19
3.2.5 Records Maintenance and Use ...................................................................................... 19
3.2.6 Records Retirement ....................................................................................................... 19
3.2.7 Records Disposition and Retention ............................................................................... 19
4. RECORDS CREATION AND RECEIPT ................................................................ 19
4.1 Controlling Records Creation and Receipt ................................................................... 20
4.1.1 Nonrecords ............................................................................................................ 20
4.1.2 Personal Papers .............................................................................................................. 21
ii
5. RECORDS MAINTENANCE AND USE ................................................................. 21
5.1 Records Maintenance Responsibilities ......................................................................... 21
5.2 OPM Files Electronic and Other Media........................................................................ 22
5.2.1 Organizing Files ............................................................................................................ 23
5.2.2 File Breaks and Cutoffs ........................................................................................ 23
5.2.3 File Folders, Labels, and Dividers ................................................................................ 24
5.2.4 File Stations ........................................................................................................... 25
5.3 Records Retirement ....................................................................................................... 26
5.3.1 Retiring Active Records ........................................................................................ 26
5.3.2 Retiring Inactive Records ..................................................................................... 29
5.4 Guidelines for Managing Nonrecord Materials ............................................................ 29
6. RECORDS DISPOSITION ........................................................................................ 30
6.1 Definition of Records Disposition ................................................................................ 30
6.2 Agency Functions ......................................................................................................... 31
6.3 Records Classification .................................................................................................. 32
6.4 Series Inventory ............................................................................................................ 33
6.5 Records Schedules ........................................................................................................ 33
6.5.1 General Records Schedules and OPM Schedules ......................................................... 35
6.5.2 New or Revised Records Schedules ............................................................................. 36
6. Standard Form (SF) 115 and Requesting a New or Revised Records Schedule .......... 37
6.7 Records Disposition and Retention Periods .................................................................. 39
6.7.1 Wording of Disposition Instructions and Retention Periods .................................. 40
6.7.2 Obtaining Government Accountability Office (GAO) Clearance ........................ 41
6.8 Factors to Consider When Recommending Retention Periods ..................................... 42
6.8.1 Frequency of Reference ........................................................................................ 42
6.8.2 Legal Factors ......................................................................................................... 43
6.8.3 Name Files ............................................................................................................ 44
6.8.4 Other Factors ......................................................................................................... 44
6.9 Identifying Permanent Records..................................................................................... 44
6.9.1 Files Documenting Substantive Agency Programs....................................................... 44
6.9.2 Selected Case Files ....................................................................................................... 44
6.9.3 Analytical Reports ........................................................................................................ 45
6.9.4 Records of Internal OPM, Interagency, and Other Committees ........................... ……45
iii
6.9.5 Legal Opinions and Comments on Legislation ............................................................. 45
6.9.6 Evaluations of Internal Operations ............................................................................... 45
6.9.7 Formal Directives, Procedural Instructions, and Operating Manuals .......................... .46
6.10 Flexible Scheduling, “Big Bucket” Schedules, and Flexible Retention ....................... 46
6.11 Transferring Records to Records Storage Facilities ..................................................... 47
6.12 Federal Records Centers ............................................................................................... 47
6.12.1 Purpose and Location.................................................................................................... 47
6.12.2 Records Eligible for Transfer to a FRC ........................................................................ 47
6.12.3 Preparing Records Transfer Forms ........................................................................ 52
6.12.4 Preparing the Files for Transfer ............................................................................. 54
6.12.5 Shipping the Records .................................................................................................... 55
6.12.6 FRC Reference Service ................................................................................................. 57
6.12.7 Disposal of Records in the Centers ............................................................................... 58
6.13 Transferring Permanent Records to the National Archives .......................................... 59
6.13.1 Offering Permanent Records to NARA ........................................................................ 59
6.13.2 Audiovisual Records ..................................................................................................... 60
6.13.3 Machine-Readable Records .......................................................................................... 61
6.14 Disposing of Temporary Records ................................................................................. 69
6.15 Disposition of Personal Papers and Extra Copies of Federal Records ......................... 70
6.15.1 Official and Personal Records Defined ........................................................................ 70
6.15.2 Extra Copies of Official Records .................................................................................. 71
6.15.3 Penalties for the Unlawful Removal of Records .......................................................... 72
7. ELECTRONIC RECORDS ....................................................................................... 72
7.1 Definition of Electronic Records .................................................................................. 72
7.2 Electronic Records Management Controls ................................................................... 72
7.3 Electronic Recordkeeping Systems ............................................................................... 73
7.4 Managing Electronic Mail Records .............................................................................. 74
7.4.1 Email Records Management Systems ........................................................................... 75
7.4.2 Email Records Management FAQs .............................................................................. 76
7.4.3 Multiple E-Mail and Personal E-Mail Accounts……………………………………...76
7.5 Maintaining Electronic Information Systems ............................................................... 79
7.6 Storing and Testing Permanent Electronic Records ..................................................... 80
7.7 Disposition of Electronic Records ................................................................................ 80
iv
7.8 Using Electronic Media to Transfer Records to the National Archives ....................... 80
7.9 Use of Compact Disk-Read Only memory (CD-ROM) and Optical Disk Systems to
Store and Transfer Federal Records .............................................................................. 81
7.9.1 CD-ROM Policy ....................................................................................................... 81
7.9.2 Optical Disk System Policy ........................................................................................ 82
7.9.3 OPM Policy ....................................................................................................... 82
7.10 Scanned Records ......................................................................................................... 83
7.10.1 Transferring Scanned Records to NARA ................................................................... 83
7.10.2 Acceptable Image Quality Specifications ................................................................... 84
7.10.3 Transfer Documentation ............................................................................................. 84
7.10.4 Transfer Mechanisms .................................................................................................. 85
7.10.5 Portable Document Format (PDF) .............................................................................. 85
7.10.6 Levels of Access ....................................................................................................... 85
7.10.7 Contact Information .................................................................................................... 87
7.11 Managing Web Records ............................................................................................... 87
7.12 Social Media and Records Management...................................................................... 89
7.13 Cloud Computing …………………………………………………………………….79
8. FOIA, E-DISCOVERY, AND LITIGATION FREEZES AND HOLDS .............. 92
8.1 Records Management and the Freedom of Information Act (FOIA) ........................... 92
8.1.1 Access to Certain Records Without a FOIA Request ................................................... 92
8.1.2 Time for Response 92
8.2 Records Management and Electronic Discovery .......................................................... 93
8.2.1 E-Discovery Responsibilities ........................................................................................ 93
8.3 Records Management and Litigation Holds and Freezes ........................................... 107
8.3.1 Litigation Holds ........................................................ Error! Bookmark not defined.
8.3.2 Litigation Freezes ..................................................................................................... 107
8.3.3 Requesting a Records Freeze ...................................................................................... 108
8.3.4 Lifting a Freeze ..................................................................................................... 108
9. VITAL RECORDS ................................................................................................... 110
9.1 Definition of Vital Records ......................................................................................... 110
9.2 OPM Vital Records Program ...................................................................................... 111
9.3 How Do I Identify Vital Records? .............................................................................. 112
9.3.1 Do Vital Records Need to Be in a Particular Format? ................................................ 114
v
9.4 Contingency Planning and Risk Assessment .............................................................. 114
9.5 Vital Records Plan ...................................................................................................... 115
9.5.1 Updating the Vital Records Plan................................................................................. 116
9.6 When Can Vital Records Be Destroyed? .................................................................... 116
10. TEMPORARY AND PERMANENT SHUTDOWNS OF OPM OFFICES ........ 117
10.1 Temporary Shutdowns ................................................................................................ 117
10.2 Permanent Shutdowns ................................................................................................. 117
11. Special Categories of Records [RESERVED] ........................................................ 119
12. RECORDS MANAGEMENT TRAINING ............................................................ 119
12.1 Annual Training and Evaluations for Records Coordinators ...................................... 119
12.2 Periodic Training for New Staff ................................................................................. 120
12.3 Periodic Training and Briefings for Senior Officials and Political Appointees ......... 120
APPENDIX A: ACRONYMS ............................................................................................... 122
APPENDIX B: GLOSSARY ................................................................................................. 124
APPENDIX C: REFERENCES ............................................................................................. 128
APPENDIX D: INDEX [RESERVED] ................................................................................. 136
APPENDIX E: PROCEDURES ............................................................................................ 137
Records Management for OPM Internal Administrative Records
vi
Revision History
Version Number
Revision Summary
0.1
Outline Draft
0.2
Draft sections 1, 2, and 3 added and edited by DKW
0.3
Draft sections 1, 2.-2.5; 3.3.2.1.4; 4.-4.1.1; 5.-5.x.x;
Appendix B: Glossary added & edited by DKW/cc
0.4
Draft sections 2.2-2.5; 3.1-3.2.1.4; 5.1-5.2.1 edited
by DKW/sc
0.5
Draft sections 2.1-2.5; 3.1-3.2.6; 4.1; 5.1-5.2.2
edited by DKW/cc
0.6
Draft sections 6, 7, 8 edited by DKW/sc
0.7
Draft sections 1 – 6 edited by DKW/cc
0.8
Draft sections 6 – 8 edited by DKW/cc, sc, ah
0.9
Draft – edited by DKW/cc, jbw
0.10
Draft – edited by DKW/cc, ah, sl
0.11
Draft new Section 8 E-Discovery section; Section 12
Training– edited by OPM/pc and DKW/cc, ah
0.12
Draft new Appendix A Acronyms; Section 12
Training; TOC; Appendix C References; Sections 5
& 6; Sections 7-12; Appendixes A & B; Sections 1-4
0.13
A. Happ, DKW, sent Draft to Ms. Bennett and Ms.
Capers OPM OCIO/RM
0.14
Patricia Capers, OPM Records Officer
0.15
Patricia Capers, OPM Records Officer edit
following OGC review addressing alternate language
regarding electronic records, e-discovery policy
inclusion, language for contractors, e-mail
management, cloud computing issues, VOIP and
other communications and system migration.
0.16
Joel Westphal, OPM Records Officer edit following
another OGC review and comment. All links
updated, e-discovery language updated, records
freeze information updated, other minor edits.
Added info on multiple email accounts.
Records Management for OPM Internal Administrative Records
vii
Executive Summary
This directive contains guidelines for the creation, organization, maintenance, and disposition of
OPM records. It implements the requirements of Title 36 Code of Federal Regulations,
Subchapter B, Records Management. This directive combines the former OPM Administrative
Manual Supplement 44-2, Maintenance of Records (1993) with the former OPM Administrative
Manual Supplement 44-3, Disposition of Records (2003).
Where text from these earlier documents was still pertinent to OPM’s records management
program, those passages were retained in the new Directive. Where records management policy
and procedure have changed, we have made every attempt to reflect those changes in the new
directive.
New material in this directive includes information on flexible schedules, “big bucket”
schedules, and flexible retention periods (see Subsection 6.10). There is also a substantial
amount of new information dealing with the management of electronic records generally (see
Section 7), and specifically managing email records, archival PDF images, Web records, and the
challenges to records management posed by Web 2.0 and Social Media.
A section addressing the challenges posed by electronic discovery, FOIA, and the records
management –related changes to the Federal Rules of Civil Procedure has been added (see
Section 8). Also new is a section on Records Management Training (see Section 12).
This directive is designed for use as a reference for OPM Records Coordinators (RCs)
1
who are
responsible for records management as part of their routine duties. In addition to RCs, other
records personnel within individual offices are responsible for adhering to the policies and
procedures within this document. This document will help them identify, maintain, retire,
transfer, and destroy OPM records. Among the many questions the Records Management
Directive answers are the following:
· What is a record?
· How can I tell the difference between a Federal record and a nonrecord?
· How should records be organized for easy access?
· What are the most efficient ways of maintaining records regardless of medium?
· How do I know when to retire records to a Federal Records Center (FRC)?
· How do I know when to destroy temporary records or archive permanent records?
These questions and many more will be fully discussed in this directive. Should you have
further questions about records that are not addressed in this directive, please contact the OPM
Records Officer in the Office of the Chief Information Officer.
1
See Glossary entry.
Records Management for OPM Internal Administrative Records
viii
The version of this document that is posted to the Web is the official, authoritative version.
Records Management for OPM Internal Administrative
9
1. INTRODUCTION
All Federal Agencies are required to create, maintain, and destroy or archive their records in an
efficient and economical manner. To assist in this endeavor, Federal Agencies are required to
establish records management programs.
2
OPM’s Internal Administrative Records Management Program provides for effective controls
over the creation, maintenance, and disposition
3
of all Federal records regardless of media. It
applies standards and techniques designed to improve records management and records security.
Finally, it assists OPM in complying with:
· 44 U.S.C. Chapter 21, National Archives and Records Administration.
· 44 U.S.C. Chapter 25, National Historical Publications and Records Commission.
· 44 U.S.C. Chapter 29, Records Management by the Archivist of the United States and by
the Administrator of General Services.
· 44 U.S.C. Chapter 31, Records Management by Federal Agencies.
· 44 U.S.C. Chapter 33, Disposal of Records.
1.1 Purpose
The purpose of this directive is to acquaint Office of Personnel Management (OPM) employees,
interns, and contractors with OPM’s Internal Administrative Records Management Program and
the importance of records management at OPM. It details the policies, procedures, roles and
responsibilities, standards, and techniques that OPM uses to manage its internal administrative
records.
1.2 Scope and Applicability
The scope of this directive is the life-cycle management of:
1. OPM internal administrative records, and
2. OPM personnel and employment-related records that pertain only to OPM and OPM
employees.
1. OPM internal administrative records: Internal administrative records are records created
and received by OPM during the normal course of business and that pertain to the day-to-day
functioning of the agency.
2. OPM internal personnel records: Although it is OPM’s responsibility to manage all three
types of Federal personnel records (internal systems of personnel records, centralized systems of
personnel records, and Government-wide systems of personnel records)
4
only the first type
(OPM internal personnel records) are covered by this directive.
2
See 44 U.S.C. 3101 – 3102.
3
See Appendix B, Glossary, for the definition of “disposition”.
4
See 5 CFR 297.104, OPM’s Privacy Procedures for Personnel Records – Types of Records.
Records Management for OPM Internal Administrative
10
For policy and procedure on centralized systems of personnel records and Government-wide
systems of personnel records, please see the Guide to Personnel Recordkeeping.
All OPM employees, interns, and contractors create or receive OPM internal
administrative records during the course of their daily work. This directive applies to all
OPM employees, interns, and contractors.
1.3 Compliance, Enforcement, and Exceptions
The heads of all Federal Agencies must establish programs for the economical and efficient
management of the agency’s records, as demanded by 44 U.S.C. 3102 Establishment of program
management.
5
Agency records management programs must comply with 44 U.S.C. Chapters
· 21 (National Archives and Records Administration),
· 25 (National Historical Publications and Records Administration),
· 29 (Records Management by the Archivist of the United States), and
· 31 (Records Management by Federal Agencies).
6
They are also expected to comply with 36 CFR Chapter XII, National Archives and Records
Administration and 41 CFR Part 102-193, General Services Administration (GSA) - Creation,
Maintenance, and Use of Records.
Enforcement of these statutes and regulations is expected to be undertaken by agency heads and
their records officers. In addition, both the National Archives and Records Administration
(NARA) and GSA encourage compliance by requiring that agency heads report on how their
records management programs comply with the statutes and regulations. Annually, NARA and
GSA obtain status reports from agencies, and follow-up with the agency head when programs are
not in compliance and corrective action is necessary. If an agency does not comply in a timely
manner, then the Archivist and GSA are required to report to Congress or the President detailing
failures of compliance by Federal Agencies.
7
While there are exceptions in the regulations pertaining to specific aspects of records
management activities and programs, there are no exceptions to the responsibility of Federal
Agencies to establish and maintain a records management program.
1.3.1 Criminal Penalties
The heads of Federal agencies are responsible for ensuring that all employees are aware of the
provisions of the law relating to unauthorized destruction, alienation, or mutilation of records,
and should direct that any such action be reported to them. Criminal penalties may be incurred
for the unauthorized removal, mutilation, or destruction of Federal records.
5
See 44 U.S.C. 3102.
6
See 44 U.S.C. 3102(3).
7
See 44 U.S.C. 2115 Reports; correction of violations.
Records Management for OPM Internal Administrative
11
These penalties are defined in 18 U.S.C. 2071, Concealment, removal, or mutilation [of records],
generally and 36 CFR 1228.102, Criminal penalties. Penalties include a fine or prison sentence
of not more than 3 years, or both.
1.3.2 Reporting
The head of a Federal agency shall report any unlawful or accidental destruction, defacing,
alteration, or removal of records in the custody of the agency to NARA. The necessary elements
of the report are outlined in 36 CFR 1228.104.
2. RESPONSIBILITIES
OPM uses a decentralized filing system for its internal administrative records. This means that
some files are located in working areas rather than a central location such as a specific OPM
office or facility. Responsibility for the administration and implementation of the records
management program belong to the OPM Director, the Chief Information Officer (CIO), the
OPM Records Officer (RO), and the Records Coordinators (RCs). However, all OPM
employees, political employees, interns, and contractors are responsible for managing the
documents (records and non-records) they create and receive.
2.1 OPM Director
The Director is responsible for making and preserving records that document the organization,
function, policies, and decisions of the agency (44 U.S.C. 3101). The Director is also
responsible for establishing an active and continuing program for the management of agency
records (44 U.S.C. 3102). In addition to these basic responsibilities, the Director is required to
remind all OPM employees annually of the agency’s records management policies and of the
sanctions for the unlawful removal or destruction of Federal records, as provided in
18 U.S.C.
2071 (Concealment, removal, or mutilation [of records] generally).
8
The Director of OPM has
delegated the administration and implementation of the internal administrative records
management program to the Chief Information Officer.
2.2 The CIO
The CIO or designee is responsible for administering and implementing all rules, regulations,
policies and procedures related to records management regardless of medium (paper and
electronic). The CIO has responsibility for ensuring that information technology systems
provide adequate and cost effective records management and retention capabilities. As
information systems are planned, the CIO will:
· Ensure that the Records Officer and appropriate program area and field office Records
Coordinators are included in the initial planning for new systems, and plans for migration
or updates from existing systems;
· Provide guidance on the security of electronic records over the life of the records, and
ensure that Records are valid, authentic, and reliable in order to meet legal requirements.
8
See also 36 CFR 1222.20(b)(9) and 36 CFR 1228.100(b).
Records Management for OPM Internal Administrative
12
2.3 Records Officer (RO)
The Records Management (RM) organizational unit, located in the Office of the Chief
Information Officer, is responsible for the overall direction of OPM’s Internal Administrative
Records Management program. The RO is designated by the Chief of Records Management,
who in turn is responsible to the CIO. The RO is responsible for:
· Serving as OPM’s representative with NARA, other Federal Agencies, and external
organizations on matters pertaining to records management.
· Developing plans, policies, and standards governing the maintenance and disposition of
all OPM records in all media and formats.
· Approving any directives by program offices that supplement the prescribed records
management-related instructions contained in this directive.
· Evaluating the records management program to ensure its adequacy, effectiveness, and
efficiency.
· Providing leadership and guidance to the Records Coordinators (RCs) in OPM’s program
areas and field offices to ensure reasonable uniformity in records management activities
throughout the agency.
· Developing agency-wide policies, standards, and procedures for records management by:
(a) Developing and implementing management systems and procedures to ensure that
officials, staff, and contractors do not remove Federal records from OPM custody
without appropriate authorization.
(b) Establishing procedures for the participation of RCs, and others with records
management duties, in developing new or revised agency programs, processes,
systems, and procedures to ensure that adequate recordkeeping requirements are
established and implemented.
· Ensuring that all OPM RCs, senior officials, employees, interns, and contractors are
given training in records management and are aware of OPM records management
policies and the possible sanctions for the unlawful removal or destruction of Federal
records.
· Reporting any unlawful or accidental removal, defacing, alteration, or destruction of
OPM records to the CIO and NARA (44 U.S.C. 3106).
· Conducting reviews of Headquarters and field office programs to ensure conformance
with Government-wide and agency-wide records management standards.
Records Management for OPM Internal Administrative
13
2.4 Records Coordinators (RCs)
RCs are designated by the OPM Records Officer, or by the Program Managers with the approval of
the RO. They are responsible for records management in Headquarters program areas and in field
offices. The names of RCs, and any changes in their designation, must be reported to the OPM Records
Officer immediately. The RCs are responsible for:
· Developing and maintaining the program area and field office records management
program in conformance with OPM's policies and standards.
· Establishing and implementing procedures to ensure that officials, employees, interns,
and contractors do not remove records from OPM custody without prior authorization.
· Ensuring that adequate recordkeeping requirements are established and implemented for
new or revised programs, processes, systems, and procedures.
· Conducting annual reviews of inventories and file plans to ensure that adequate and
proper documentation is maintained, permanent records are preserved, and other records
are destroyed in accordance with applicable schedules. Reporting to the RO on the
results of this review.
· Assisting the RO in administering the records management program to ensure reasonable
uniformity throughout OPM. Providing the RO with information and documentation
requested for annual evaluation of the program area and field office records management
program.
· Reporting any unlawful or accidental removal, defacing, alteration, or destruction of
OPM records to the RO.
· Ensuring that employees are aware of records management responsibilities and
established recordkeeping requirements.
2.5 Agency Employees, Interns, and Contractors
ALL OPM employees, interns, and contractors are responsible for managing the documents
(records and non-records) they create and receive in accordance with OPM’s internal
administrative records management policies, procedures, and applicable external regulations as
stated in this directive.
OPM employees also are responsible for following all instructions and guidance provided by the
OPM Records Officer and their Records Coordinator.
At the most basic level, it is the responsibility of all OPM staff to knowing that Federal records
are:
· Recorded information created by employees, interns, and contractors in the course of
agency business.
Records Management for OPM Internal Administrative
14
· Recorded information received by employees, interns, and contractors requiring them to
act or make decisions relevant to agency business.
· Recorded information documenting acts and decisions made by employees, interns, and
contractors in the course of agency business.
All OPM employees, interns, and contractors create and receive Federal records and must have
some knowledge of the records management policies and procedures employed by OPM.
Therefore, they are responsible for managing the records necessary to document the agency’s
official activities and actions in accordance with policy and procedures in this document and
corresponding references.
2.6 Senior Officials and Political Appointees
All Federal employees are responsible for creating and preserving records that adequately and
properly document "the organization, functions, policies, decisions, procedures, and essential
transactions of the agency."
9
However, senior officials
10
(the Director, deputy directors,
associate directors, deputy associate directors, etc.) must be especially mindful of their records
management responsibilities. Many of the records created or received by senior officials are
considered permanent because they document OPM's decisions and policies. NARA has
determined that the records of senior officials have sufficient value to warrant archival
preservation.
11
Federal agencies are mandated by 44 USC 3101 to provide annual information management
training to Executives and Managers. The training will not only assist in compliance, it also
boosts the overall score that determines whether or not OPM is at high risk, medium or low risk
for records mismanagement and alienation of Federal records. OPM has to submit an annual
Self-Assessment to the National Archives and Records Administration to verify whether
executive training did occur. Data evaluating compliance is thereafter included in a report to
Congress and the Office of Management and Budget.
In addition to the records management responsibilities pertaining to other employees, senior
officials are responsible for:
· Creating records necessary to document the actions taken and decisions made by them, or
on their behalf, in the course of agency business.
· Securing records before they leave the agency.
· Understanding that all records created and received during their tenure belong to the
Federal Government.
9
See 44 U.S.C. 3101.
10
For a list of senior officials compiled by NARA, see the General Records Schedules (GRS): Note following GRS
23, Item 5a.
11
See Disposition of Federal Records (DFR): A Records Management Handbook, Appendix C, Appraisal
Guidelines for Permanent Records.
Records Management for OPM Internal Administrative
15
Senior officials typically manage the following records:
· Calendars, schedules, and logs of daily activities.
· Records created and received while serving on committees, including Federal advisory
boards, councils, and interagency and external committees.
· Records that document the development of OPM policies and programs.
· Reports to Congress, the President, or both.
· Speeches and testimony.
· Major correspondence.
2.7 New Employees, Interns, and Contractors
All new employees, interns, and contractors at OPM must obtain records management training to
ensure they know the difference between Federal records, nonrecords, and personal papers, and
are aware of OPM records management policies and the possible sanctions for the unlawful removal
or destruction of Federal records. This requirement is mandated by 36 CFR 1228.100.
2.8 Human Resources
In conjunction with the RO, Human Resources is responsible for allotting training time in their
new hire orientation for records management training.
3. RECORDS MANAGEMENT POLICY
It is the policy of the Office of Personnel Management (OPM) to establish and adhere to an
efficient and economical records management program for its internal administrative records and
those personnel records that pertain only to OPM employees. The policy applies to all OPM
employees, interns and contractors and is mandatory guidance for information lifecycle
management. Unauthorized deviation from the policy puts OPM at risk for sanctions.
The purpose of the policy is to:
· Ensure compliance with all relevant Federal statutes and regulations.
· Preserve the rights of the agency and its employees.
· Support effective decision-making.
· Minimize litigation risks by ensuring that:
i. employees, interns, and contractors are properly trained in their roles and
responsibilities for creating, maintaining, retiring, and destroying records at
OPM, and
ii. the systematic and routine destruction of temporary records takes place.
· Reduce operating costs through control over the creation, storage, destruction of
temporary records, and transfer of ownership of permanent of records to NARA.
Phase 1. Records
Creation and Receipt
Phase 2. Records
Maintenance and Use
Phase 3. Records
Disposition
Active Inactive
Records Management for OPM Internal Administrative
16
· Safeguard vital information.
· Preserve organizational memory.
· Preserve primary historical documents.
3.1 Records Life-Cycle Process
The records life-cycle process focuses on managing records from their creation through their
maintenance, use, and disposition.
According to this process, records go through three basic phases (see Figure 1 below):
Figure 1: Records Life Cycle
Recorded information created or received in the course of agency business make up the Records
Creation and Receipt phase of the records life cycle. As soon as the record is filed in a file
drawer or on a shelf, it enters the Records Maintenance and Use phase. As figure 1 indicates,
active records are those captured in the Records Creation and Receipt phase and extending into
the Records Maintenance and Use phase. At some point during the Records Maintenance and
Use phase, the records cease to be active and become Inactive Records.
12
At this point, it is
common for agencies to retire their records to a Federal Records Center. At the end of the
Maintenance and Use phase, the record is determined to be of no more use to the agency. It is
then transferred to NARA if that agency has decided that the records are of permanent, or
archival, value. If the records are temporary, they are destroyed.
3.2 Records Management Fundamentals
Records management is the planning, controlling, directing, organizing, training, promoting,
and other managerial activities involving the life cycle of records regardless of media.
All Federal employees, interns, and contractors create and use Federal records. They may be in
any medium or format. Records document the organization, functions, policies, decisions,
procedures, operations, and other activities of the agency.
There are rules governing the creation, receipt, use, and disposition of all Federal records. It is
the responsibility of all Federal employees, interns, and contractors to protect Federal records in
their custody, and there are legal implications for destroying records without the proper
12
See Appendix B, Glossary, for the definitions of “active records” and “inactive records”.
Records Management for OPM Internal Administrative
17
authority. In addition, following good records management practices benefits OPM by
improving access to information and saving time, space, and money.
13
Below is an overview of OPM’s Records Management Program:
· Records Identification – identifying and separating records from nonrecords and personal
papers.
· Records Classification – categorizing the records in an office or agency so that they are
recognized as correspondence, reports, contracts, financial records, among other
classifications.
· Series Inventory – a listing of all agency records by record series.
14
· File Plan
15
– a listing of all agency records by folder.
· Records Maintenance – ensuring that OPM has a recordkeeping system that makes it easy
to locate records while guarding against their unauthorized removal, mutilation, or
destruction.
· Records Retirement – ensuring that inactive records are retired to a Federal Records
Center, freeing up more expensive OPM space.
· Records Disposition – transfer of ownership of permanent records to NARA when they
are no longer needed by OPM. It is also the orderly and timely destruction of temporary
records.
3.2.1 Third Party Records Management of Federal Records
The following standard items relate to records generated in executing the management of Federal
records by a third party contractor. The NARA highly recommends language such as this should
be included in a typical Electronic Information Systems (EIS) procurement contract:
· Citations to pertinent laws, codes and regulations such as 44 U.S.C chapters 21, 29, 31
and 33; Freedom of Information Act (5 U.S.C. 552); Privacy Act (5 U.S.C. 552a); 36
CFR Part 1222 and Part 1228.
· Contractor shall treat all deliverables under the contract as the property of the U.S.
Government for which the Government Agency shall have unlimited rights to use,
dispose of, or disclose such data contained therein as it determines to be in the public
interest.
· Contractor shall not create or maintain any records that are not specifically tied to or
authorized by the contract using Government IT equipment and/or Government records.
13
See Environmental Protection Agency’s What Every EPA Staffer Should Know About Records Management.
14
See Appendix B, Glossary, for the definition of “record series” and “series inventory”. See also DFR, Chapter III
Records Inventory (NARA: 2000).
15
See Appendix B, Glossary, for the definition of “file plan”. See also DFR, Part VI Schedule Implementation
(NARA: 2000).
Records Management for OPM Internal Administrative
18
· Contractor shall not retain, use, sell, or disseminate copies of any deliverable that
contains information covered by the Privacy Act of 1974 or that which is generally
protected by the Freedom of Information Act.
· Contractor shall not create or maintain any records containing any Government Agency
records that are not specifically tied to or authorized by the contract.
· The Government Agency owns the rights to all data/records produced as part of this
contract.
· The Government Agency owns the rights to all electronic information (electronic data,
electronic information systems, electronic databases, etc.) and all supporting
documentation created as part of this contract. Contractor must deliver sufficient
technical documentation with all data deliverables to permit the agency to use the data.
· Contractor agrees to comply with Federal and Agency records management policies,
including those policies associated with the safeguarding of records covered by the
Privacy Act of 1974. These policies include the preservation of all records created or
received regardless of format [paper, electronic, etc.] or mode of transmission [e-mail,
fax, etc.] or state of completion [draft, final, etc.].
· No disposition of documents will be allowed without the prior written consent of the
Contracting Officer. The Agency and its contractors are responsible for preventing the
alienation or unauthorized destruction of records, including all forms of mutilation.
Willful and unlawful destruction, damage or alienation of Federal records is subject to the
fines and penalties imposed by 18 U.S.C. 2701. Records may not be removed from the
legal custody of the Agency or destroyed without regard to the provisions of the agency
records schedules.
· Contractor is required to obtain the Contracting Officer's approval prior to engaging in
any contractual relationship (sub-contractor) in support of this contract requiring the
disclosure of information, documentary material and/or records generated under, or
relating to, this contract. The Contractor (and any sub-contractor) is required to abide by
Government and Agency guidance for protecting sensitive and proprietary information.
3.2.2 Identifying and Classifying Records
Records identification takes place when the OPM employee or contractor determines that a
document or other recorded information matches the definition of record found at 44 U.S.C.
3301. This simple step also has the effect of separating the record identified from all nonrecords.
Once the records have been separated from nonrecords, the process of classification along
business function lines and document type can begin (see Subsections 6.2 and 6.3 below).
3.2.3 Series Inventory and File Plan
Once records have been classified, the Records Officer and all Records Coordinators must
inventory them. A records inventory (in this directive referred to as a “series inventory”) is
simply a listing of all the record series in the office. Once all office inventories are completed,
the Records Officer combines them into an inventory of all of OPM records.
Records Management for OPM Internal Administrative
19
After completing the inventory, each office must create a file plan. The difference between a
series inventory and file plan is that a series inventory results in a list of record series, whereas a
file plan is a listing of agency records down to the folder level. See Subsection 6.4 below for
details.
3.2.4 Records Scheduling
The process of creating a records inventory and file plan aids in records scheduling. A records
schedule describes a group of related records and documents its disposition instructions and
retention period. All records schedules must be approved by NARA. Most of OPM’s schedules
are based on NARA’s General Records Schedules, which are applicable to all Federal Agencies.
See Section 6, Records Disposition for details.
3.2.5 Records Maintenance and Use
The period during which a record is needed for the conduct of OPM business is its period of
maintenance and use. During this period, the record legally belongs to OPM even if the record is
no longer stored in OPM space. During this period, OPM employees, interns, and contractors
must ensure that the record is safe and secure. See Section 5, Records Maintenance and Use for
details.
3.2.6 Records Retirement
The Maintenance and Use phase of a record’s life cycle is sometimes divided into two periods:
an active period and an inactive period. According to NARA’s definition, active records are
referenced at least once a month, and inactive records are referenced less often. Agencies often
retire their inactive records to Federal Records Centers (FRCs). The FRC has custody of the
record, not ownership, while it is stored at the FRC. See Section 6, Records Disposition
for
details.
3.2.7 Records Disposition and Retention
A record’s disposition defines its status as a temporary record that is eventually destroyed, or a
permanent record that is archived. A record’s retention period is the period of time during which
the record is needed for agency business, after which it is either destroyed or archived. See
Section 6, Records Disposition for details.
4. RECORDS CREATION AND RECEIPT
Federal employees, interns, and contractors create and receive many documents in many media
and formats on a daily basis. The first lesson of records management is to identify which types
of documentary materials are records and which are not.
The statutory definition of a “Federal record” can be found at 44 U.S.C. 3301. To paraphrase,
Federal records are documentary materials regardless of physical form or characteristics, which
are made or received by an agency of the United States Government, and preserved and
appropriate for preservation as evidence of actions taken or decisions made by or on behalf of
Records Management for OPM Internal Administrative
20
the United States Government. This can be simplified still further. A Federal record is any
recorded information that is:
· Created in the course of agency business,
· Received for action in the course of agency business, or
· Preserved to document actions taken or decisions made in the course of agency business.
4.1 Controlling Records Creation and Receipt
To maintain an economical and efficient records management program, agencies must be
concerned with maintaining some control over how records are created and received. Federal
employees, interns, and contractors can begin to establish control first by remembering that not
every document they encounter is a Federal record.
Many types of recorded information do not meet the statutory definition of “Federal record.”
These materials are defined in the Code of Federal Regulations as “nonrecords”. According to
this definition, nonrecords are federally owned recorded information that does not meet the
criteria of a Federal record. Excluded materials are extra copies of documents kept only for
reference, stocks of publications and processed documents, and library or museum materials
intended solely for reference or exhibit.
16
This definition would also include printed copies of electronic records, where the electronic
record is considered the original. However, where agencies have not yet established an email
records management system, it is still necessary to print out email records. In this instance, the
printed copy is the record (see Section 7
of this directive).
Having a sound knowledge of what recorded information constitutes a Federal record and what
does not makes it possible to control the size of an office’s records collection. Performing a
series inventory is a good opportunity to separate records from nonrecords and personal papers.
Records Coordinators and others with records management duties must develop procedures for
managing their nonrecords. This can be accomplished by controlling records accumulation and
destroying nonrecords as soon as they are no longer needed.
4.1.1 Nonrecords
Nonrecord material consists of extra copies, drafts, directives (in other than the originating
office), periodicals, and convenience copies of Federal records. The fact that they are
nonrecords does not necessarily mean that they are not scheduled. Many nonrecords are
scheduled, but they usually have retention periods that are either very brief or very flexible.
Such schedules often state that the nonrecord must be destroyed “when no longer needed”.
As indicated previously, it is very important that nonrecords and records be kept separate in the
files. Such nonrecords as professional journals, periodicals, and other reference materials can
16
See 36 CFR 1220.14, Records Management – General definitions.
Records Management for OPM Internal Administrative
21
accumulate rapidly. It is important that these materials be destroyed when no longer needed.
For examples of nonrecords, see 36 CFR 1222.34(f).
4.1.2 Personal Papers
Personal papers are documentary materials of, or belonging to, private individuals or entities.
Because they can be created and received by Federal employees, interns, and contractors, it is
sometimes easy to mix them with Federal records. However, such materials are not created and
received in the course of, or pursuant to, Government business. They are not Federal records
and, like nonrecords, must be segregated from Federal records and destroyed at the earliest
opportunity. For examples of personal papers, see 36 CFR 1222.36.
5. RECORDS MAINTENANCE AND USE
In Federal usage, records are described as “active” or “inactive,”
17
depending on the stage they
have reached in their life cycle. These terms refer to the use of records in the daily work of the
office. NARA has defined active records as those records that are referenced at least once a
month, while inactive records are those referenced less than once a month.
It is often desirable to move inactive records offsite, usually to a Federal Records Center (FRC),
to free up agency space and take advantage of cheaper FRC space.
18
The maintenance of
inactive records “retired” to an FRC becomes the FRC’s task, although the costs associated with
the performance of this task are borne by OPM. OPM may store records in agency-operated and
commercial storage facilities, but such facilities are required to meet NARA standards as stated
in 36 CFR Subpart K Facility Standards for Records Storage Facilities.
19
Because of their frequency of reference, it is usually to an agency’s benefit to keep active records
in agency storage. It is the agency’s task to maintain these records and keep them safe from loss
or damage for the length of time indicated by their associated retention periods.
5.1 Records Maintenance Responsibilities
OPM uses a decentralized filing system. This means that the files are located in work areas
rather than in a central location. In a decentralized system, it is the responsibility of everyone
using the files to maintain the files.
While the Records Officer and the Records Coordinators are ultimately responsible for records
maintenance, OPM employees, interns, and contractors who make greatest use of OPM records
bear the largest responsibility for ensuring that the records are properly maintained. They must
notify their RC if they notice such things as misfiles or over-packed filing drawers.
17
Some sources use the terms “current”, “semicurrent”, or “noncurrent”. See DFR, Chapter III, Figure 3-1a.
18
See the OPM Records Schedules (currently being revised) for specific instructions regarding whether and when
specific record series should be retired to the FRC.
19
See 36 CFR 1228.150 for authority to store records in commercial facilities; 36 CFR 1228.150-1228.156 for
transfer of records to storage generally; 1228.160-168 for transfer of records to NARA facilities; and 1228.220-244
for storage facility standards.
Records Management for OPM Internal Administrative
22
Many of OPM’s files have not been indexed into a database. Therefore, if folders are misfiled,
the only way to find them is if they are noticed by alert employees or during periodic shelf
audits. To avoid this problem, each office must establish file stations (see Subsection 5.2.4 and
Figure 4) supplied with charge out records listing folders that have been removed by employees.
Over-packing drawers and shelves is one of the easiest ways to damage paper records. The
repeated pulling out and pushing in of over-packed file drawers shreds the edges of paper records
and causes loss of information.
This sort of damage can be easily avoided. Periodically auditing file shelves and drawers soon
brings problems to light. A plan for the periodic retirement of inactive records also frees up
agency filing space and avoids over-packing of shelves and drawers.
5.2 OPM Files – Electronic and Other Media
It is important to understand that OPM files are anywhere where OPM’s records are stored and
managed. The “files” are predominately electronic files located on servers, backup tapes,
personal computers, laptops, tablets, shared and private drives. However OPM also maintains
files in other media and may be located in a large room full of filing cabinets, a file cabinet or
two located in a small office or cubicle, or a file drawer in an employee's or contractor’s desk.
No matter where the records are kept, they are a part of the OPM records system, and are subject
to the requirements of the OPM records management program. Remember that personal files
that do not contain any official record copies or working papers are not considered part of
OPM’s files. It is each employee’s responsibility to separate personal files from Federal records.
In the case of records that contain some personal information mixed with OPM-related
information, it is the employee’s responsibility to extract the OPM-related information and file it
appropriately.
Records Coordinators are responsible for being aware of the location and content of all the files
in their offices, and for periodically reviewing the files to ensure that they are being maintained
in accordance with OPM records management policies and procedures and U.S. Government
statutes and regulations.
As a general rule, documents are filed in the record collection of the organizational component
that originated the document. The record copy of a letter originating in office A and sent to
office B must be filed in office A. Offices may vary this general rule as long as all persons
involved are aware of the system being followed.
Some records are of concern to more than one office. To prevent fragmenting the record, the
OPM Records Officer and the responsible Records Coordinator from one of the offices involved
must assign responsibility for the records. Fragmentation can easily occur when more than one
office is assigned responsibility for a particular function or project. The records documenting the
project will be created and received by both offices. In this situation, decisions or judgments
may be made on the basis of incomplete information since each of the offices has only a portion
of the complete record.
Employees and contractors may not maintain OPM records at their individual workstations.
These files are usually not maintained in accordance with accepted OPM records management
Records Management for OPM Internal Administrative
23
guidelines, they are often known only to the employee, and they frequently disappear when the
employee leaves the office.
It is necessary, of course, for employees, interns, and contractors to maintain copies of records
relating to projects in which they are actively engaged. Once these projects are completed,
however, employees must turn these records over to the Records Coordinator for filing in the
office’s records collection. RCs must remind employees, interns, and contractors working in
their offices of this requirement.
5.2.1 Organizing Files
OPM files must be organized by records schedule titles wherever possible. The program records
schedules approved by NARA have set titles that cannot be changed without authorization. The
General Records Schedule published by NARA also has set titles. Use of appropriate titles
facilitates proper records disposition.
All of OPM’s schedules are broken down into disposition items, sometimes called “record
series.” These are smaller groups of records with the same disposition and retention period. For
instance, schedule ADM has 26 disposition items. In addition, many disposition items are
broken down into sub-items. Schedule ADM, Item 2 has three sub items: 2a, 2b, and 2c. For
filing purposes, ADM, Item 1 records must be filed before ADM, Item 2 records, and ADM,
Item 2a records before ADM, Item 2b records (see Subsection 6.5 Records Schedules).
20
Within this general scheme, records can be filed either chronologically or alphabetically as suits
the business practices of the individual office and the types of records that the office maintains.
Electronic file folders throughout the agency should have a consistent taxonomy. Records
taxonomy is a documented and orderly set of types, classifications, categorizations and/or
principles that are often achieved through mechanisms including but not limited to naming,
defining and/or the grouping of attributes, and which ultimately help to describe, differentiate,
identify, arrange and provide contextual relationships between record items, entities or types.
5.2.2 File Breaks and Cutoffs
The instructions accompanying schedule disposition items often tell you when to "break" or "cut
off" the files. Breaking the files means keeping the files from becoming unmanageable by
stopping at a convenient place -- usually the end of a fiscal or calendar year -- and starting a new
file. The application of the records disposition schedules is made easier using these breaks.
If, for example, a file is to be destroyed 2 years after the close of the fiscal year, a new file must
be started October 1 of each year. Two years later, and with the permission of the RO, the file
may be destroyed. It is good practice to make a careful review of the contents of the folders to
be sure they do not contain material that is still needed for current operations before destroying
them.
20
For more information about schedules, see also DFR.
Records Management for OPM Internal Administrative
24
5.2.3 File Folders, Labels, and Dividers
Paper File Folders. As a general rule, offices should use either letter size or legal size folders.
Folders must have either a full-cut or a half-cut tab to accommodate a four-inch label. Just as
shelves and drawers must not be over-packed, employees must avoid over-packing file folders.
In both cases, over-packing makes searching difficult and record mutilation more likely.
To avoid over-packing folders, it is good practice not to file more than ¾ inch in a single folder.
Once the folder has been filled to this thickness, a new folder must be prepared. In cases where
there is a rapid accumulation of records, offices may use accordion folders with a capacity of 3
inches. Accordion folders are especially useful for filing large reports.
Labels. Folders must be clearly labeled for ease in searching and refiling. Labels must have
enough information so that records can be easily found, but not so much information that the
labels are difficult to read.
Labels must be large enough to accommodate four lines of text. It is recommended that offices
use Avery Number 5161 Address labels (see figure 2). The label text must include the following
information:
1. OPM schedule, disposition item, and disposition item name
2. Folder name in bold
3. Disposition and retention period specifications
4. Record location
1. ADM 1. Organizational and Functional Files
2. FY 2010 Reorganization Correspondence
3. PERM. Break Annually. NARA 20
4. OCIO 5425, Cab. R-2
Figure 2. Recommended Label Text
Records Management for OPM Internal Administrative
25
Note that line 3 abbreviates the actual disposition and retention period text of schedule ADM 1.
This is necessary because disposition and retention period specifications are often lengthy. Their
full text cannot fit on a 4-inch label. In this instance, the disposition of the record is permanent.
This is abbreviated as PERM. Break Annually follows the actual specifications of the schedule
item, but NARA 20 indicates that these records are to be transferred to NARA after 20 years.
The fourth line gives the location of the folder. This is necessary for efficient refiling. In the
example, the first element of the location (OCIO) is the office where the record is filed; the
second element (5425) is the room number, and the third element (Cab. R-2) is a code for a
specific filing cabinet and shelf or drawer, in this case cabinet R, shelf 2.
Dividers. Dividers, or file guides, can be used as a tool to make file searching and refiling
easier. They are made of heavy cardboard, are usually the size of a letter-sized file folder, and
have a tab for an identifying label. Use dividers to identify groups of folders, i.e., FY 2008 Case
Files, to separate those case files from all other case files.
Electronic File Folders. Just like paper files, electronic files need to be well-organized and
labeled correctly so that they are identifiable and accessible by all employees. This is especially
important for government agencies in order to comply with legal requirements to ensure the
availability, integrity, accessibility, and, if appropriate, the confidentiality of all records.
5.2.4 File Stations
Each office or organizational unit with a significant number of records must establish a file
station. The file station is the location where the file plan, file guide, and charge out cards are
located. A file station can be a container affixed to the side of the first filing cabinet in an office,
or it can be the first folder in the first filing cabinet. Remember, the file station, in whatever
form it takes, must contain:
· A copy of the office file plan,
· A copy of the office file station guide, and
· A number of charge out records.
The office file plan lists all record series used by the office. In addition to the record series, each
folder within the series is listed.
The office file station guide lists the contents of each file drawer or shelf by schedule and record
series. For example, if the office has some administrative records (OPM Schedule ADM) and
some records pertaining to competitive examinations (OPM Schedule EXR), its records would
be arranged in the file drawers in order by schedule and record series as follows:
Records Management for OPM Internal Administrative
26
SCHEDULE
ITEM#
21
ITEM DESCRIPTION
ADM
1
Organizational and Functional Files
ADM
5
Invitations and minutes of ad hoc meetings
EXR
3
Correspondence relating to shipment of tests
EXR
4
Stock control records
The file station guide must be ordered in the same way, reflecting the order of files by schedule
and record series found in the file drawers as in figure 3 on the next page.
A charge out record is a listing of folders that have been removed, showing who removed them
and when they were removed. It is a means of tracking records at the folder or document level.
The charge out record used by OPM is Optional Form 23 (OF 23), as shown in the example at
figure 4 below.
When removing a folder or document,
22
enter the required information in the form. Enter the
folder name or a description of the document in the Identification of Record column; enter your
name and office in the Charged To column; and enter the date the folder or document was
removed in the Date Charged Out column. After entering this information, place the form in the
files where the folder or document was removed. When the folder or document is returned to the
files, the form will help ensure that it is refiled correctly. Remove the charge out record, strike
through the entry for the returned records and return it to the file station. A small supply of these
forms can be kept at the file station, or employees can simply download the form from the GSA
Forms Library Web site.
5.3 Records Retirement
5.3.1 Retiring Active Records
The Federal Records Centers (FRCs) operated by NARA will accept active records for storage.
23
However, offices are encouraged to avoid this practice because of the expense of having to recall
active records. If there is a shortage of agency storage space, however, storing active records at
FRCs is one option. It is the RO’s responsibility to approve any retirements of all records,
including active records, to an FRC.
Before shipping active records to the FRC, the Records Coordinator must obtain the approval of
the OPM Records Officer. This can be done in an attachment to the SF 135 Records Transmittal
and Receipt form. The Records Officer has to be aware of any active records being retired to an
FRC. Before signing an SF 135 form not accompanied by an active records attachment, the
21
A disposition item is synonymous with a record series. Both determine the disposition and retention of a record.
22
Removal of individual documents from a folder is not recommended. To avoid accidental loss of records, it is
recommended that employees, interns, and contractors chargeout the folder in which the record is filed whenever
possible.
23
See FRC Toolkit under Storage and Servicing Active Records.
Records Management for OPM Internal Administrative
27
Records Officer must examine the disposition authority cited and the disposal date indicated on
the form. This data will determine whether the records being retired are active or inactive.
Records Management for OPM Internal Administrative
28
OPM FILE STATION GUIDE
Location: OCIO RM 5425, Cabinet A, Shelves 1 and 2
Page: of__
Schedule and
Item Number
Folder Name or Description
Disposition and
Retention Period
ADM 1
Reorganization Chart for 2005
PERMANENT. Break
annually. Transfer to
NARA when 20 years
old.
ADM 1
Reorganization Chart for 2010
PERMANENT. Break
annually. Transfer to
NARA when 20 years
old.
ADM 5
Minutes From Productivity Workshops
Break annually.
Destroy 3 years after
break.
BUF 87 a(1)
Control Office Master Address File Action Lists
Destroy when 3 years
old.
BUF 87 a(2)
Individual Payroll Office Master Address File
Action Lists
Destroy when 1 year
old.
EXR 3
Test Shipment Billing
Break annually.
Destroy 1 year after
break.
EXR 3
Test Shipment Correspondence
Break annually.
Destroy 1 year after
break.
LEG 3a
Legislative Bill Correspondence
PERMANENT. Break
annually. Transfer to
WNRC periodically.
Offer to NARA when
15 years old.
LEG 3b
Proposed Legislation: FY 2008
Destroy immediately
upon adjournment of
related session of
Congress.
LEG 3b
Proposed Legislation: FY 2009
Destroy immediately
upon adjournment of
related session of
Congress.
Figure 3. File Station Guide to be Included with File Station Material
Records Management for OPM Internal Administrative
29
OUT
IDENTIFICATION OF RECORD
(NUMBER, TITLE AND/OR SUBJECT, DATE OF
FILE OR DOCUMENT)
CHARGED TO
(PERSON & OFFICE)
DATE
CHARGED
OUT
ADM 5 Minutes From Productivity Workshops John Q. Public,
OCIO/IM/RECMGMT
06/14/2011
EXR 3 Test Shipment Correspondence Jane Doe,
OCIO/IM/RECMGMT
08/23/2011
LEG 3b Proposed Legislation: FY 2008 Alfred E. Neuman
OCIO/IM/QA
10/13/2011
Figure 4. Chargeout Record (OF 23)
5.3.2 Retiring Inactive Records
Inactive records, whether temporary or permanent, are most often retired to FRCs. Records must
be retired from agency space to FRC storage only if transfer costs do not exceed the expense of
retaining them in agency space. Records sent to FRC storage must have a remaining retention of
at least 1 year. If special circumstances, such as a lack of filing equipment or space, make it
imperative that records be retired, exceptions can be made to this policy. These decisions are
made on an individual basis by the appropriate NARA facility director in consultation with the
OPM Records Officer.
Procedures for transferring records to records center storage in a NARA facility are found in
36
CFR 1228.154(c) and 1228.160.
5.4 Guidelines for Managing Nonrecord Materials
When it is difficult to decide whether certain files are records or nonrecord materials, the Records
Officer must treat them as records. Nonrecord materials must not be interfiled with records, and must
be destroyed when no longer needed for reference.
The following are the nonrecord files most commonly found in OPM:
1. Working files contain papers on projects or cases in progress. Included are such things
as studies, data in various forms, preliminary drafts, opinions, concepts, schedules, etc.
Working files are frequently maintained at the workstations of the employees working on
the project. When final action is taken, these files must be screened to extract all
(non?)record materials relating to the project or case. The remaining papers are to be
retained in a reference file pertaining to the project or case. NARA exempts working
files such as preliminary drafts and rough notes seen only by the author from its retention
requirements.
24
24
See 36 CFR 1222.34(c)(1).
Records Management for OPM Internal Administrative
30
2. Reference files consist of work-related material that is kept only for the operating
convenience of an office. Typical reference files contain such things as extra copies of
reports, brochures, regulations, and correspondence. The information in these files is
normally available elsewhere, but because the office frequently refers to it, they keep a
copy for convenience. This material must be reviewed and purged periodically, and may
be destroyed when it has served its purpose.
Reference files may be interfiled in the same file cabinets with record files in cases
where all materials on a subject should be filed together. Otherwise, people looking for
information on a particular subject would be required to look in both the record and
reference files to ensure that they had found all materials on the subject.
Formerly it was the practice at OPM to print record copies of documents on yellow
onionskin paper. This made the record copies easily distinguished from reference
copies.
25
Offices may continue this practice if they wish, but record and reference files
must not be filed together in the same folders. Record and reference files must be
clearly identified as to type by using one color of file folder labels on the record file
folders and another color on the reference file folders, or equivalent means.
3. Reading files are extra copies of communications written by the employees of the
organizational component in which the file is kept. They are arranged in a folder by date
(most recent date first).
6. RECORDS DISPOSITION
6.1 Definition of Records Disposition
Records disposition means the actions taken regarding Federal records when they are no longer
needed in office space to conduct current agency business. These actions include:
1. Transferring records to records storage facilities.
2. Transferring records from one Federal agency to another.
3. Transferring permanent records to the National Archives.
4. Disposing of temporary records no longer needed to conduct agency business, usually by
destruction or occasionally by donation.
Subsections 6.11 – 6.14 of this Directive explain how to carry out each of these four actions.
Before any action is taken to destroy records, however, all records must be inventoried and
scheduled.
25
Many documents older than ten years have a yellow, onionskin coversheet. Documents with these yellow sheets
are record copies, not reference copies and should not be destroyed before consulting the appropriate schedule.
When such documents are discovered in office record collections, the RC must make a determination, based on the
document’s age, whether to retire, destroy, or transfer it to NARA.
Records Management for OPM Internal Administrative
31
Inventorying involves distinguishing records from nonrecord materials and personal papers, and
gathering information about the records themselves.
26
See Subsection 6.4 below for further
details on conducting a series inventory.
Scheduling means that different types of records are identified, described, and grouped together
and specific instructions are applied to properly retain, destroy, or archive them after the
appropriate period of time. All Federal records, including those created or maintained for the
Government by a contractor, must be scheduled. See Subsection 6.5 below and 36 CFR 1228.22
Developing Records Schedules for more details on how records schedules are developed.
6.2 Agency Functions
OPM’s schedules are based on some 20 agency business functions, such as Administrative
Management, Business and Finance, and Personnel. Each OPM schedule includes a variety of
record types or classifications. Before records can be scheduled, retired to FRCs, destroyed, or
archived, knowledge of the agency’s business functions and record classifications is needed.
To begin the process of organizing the records, it is necessary to review the agency’s functions
as reflected in its program responsibilities, structure, and levels of authority. Doing this involves
examining pertinent documents, such as laws, regulations, organization charts, and functional
statements, and consulting with program managers and records personnel. This process is
essential in locating, inventorying, and classifying agency records. The following questions
must be answered:
· Which are the key line and staff offices?
· What programs does the agency have?
· What units are responsible for developing policies?
· What is the nature of staff support activities? Legal? Fiscal and budgetary? Inspection?
General management? Administrative services?
OPM has assigned its functions to two broad groups: administrative functions and program
functions. These two groups account for 24 separate functions, as follows:
ADMINISTRATIVE FUNCTIONS PROGRAM FUNCTIONS
ADM – Administrative Management
APP – Appeals
ADS – Administrative Services CLC – Classification and
Compensation
BUF – Business and Finance EDU – Employee Development
and Utilization
COM – Committee Management EMP – Employment
EOR – Electronic Office Records ERS – Employee Relations and
Services
26
For more information about conducting a record series inventory, see DFR, Chapter III The Records Inventory.
Records Management for OPM Internal Administrative
32
FEB – Federal Executive Board
Operations
EVL – Evaluations
INF – Information Services EXR – Examining and
Recruiting
INS – Insurance
INV – Investigations
IPP – Intergovernmental
Personnel Programs
LEG – Legal
MED – Medical
OCR – Office of Congressional
Relations
OIG – Office of Inspector
General
PER – Personnel
RET – Retirement
OPM’s records management program is unusual in that these functions also serve as OPM
records schedules.
6.3 Records Classification
Records management begins with records classification. Classifying the records in an office is
simply placing them into categories that make sense for the business practices of the office. Start
with those categories common to all or most offices such as correspondence, reports, contracts,
or financial documents. These broad categories can be divided into finer subcategories
depending on the size and complexity of the office.
The next step is to combine the classifications arrived at with the business functions developed in
Section 6.2. For example, the Office of General Counsel (OGC) is likely to have many legal
records. The primary business function of this office is Legal and the OPM schedule most often
used is probably LEG (Legal). However, simply calling every record a legal record is not
sufficient to help in identifying and locating individual records, all of which may be legal
records, but of very different types. For instance, legal correspondence might be a useful
combination of agency Function/Schedule and record classification.
The fact that most offices create and receive a variety of correspondence simply means that finer
classifications need to be created. In an office like OGC, there may be correspondence dealing
with court cases, legislative bills, voting rights, and legal advice. Each of these groups
represents a combination of agency function and records classification.
Records Management for OPM Internal Administrative
33
6.4 Series Inventory
After identifying agency functions and record classifications, the next step is to perform a series
inventory. In records management, an inventory is a descriptive listing of each record series,
together with an indication of location and other pertinent data. It is not a list of each document
or each folder but rather of each series.
A series inventory can provide valuable information about the volume and variety of records and
the ratio of records to nonrecords. An inventory can also show what percentage of the agency’s
records are unscheduled.
27
Information gained from inventorying can show the status and condition of the records
management program in each phase of the records life cycle. For instance, conducting a
thorough series inventory can show the rate at which certain types of records are accumulated
during the records creation and receipt phase. During the records maintenance and use phase,
this accumulation rate helps determine how long records must be maintained in active storage
and whether new shelving must be acquired.
An inventory can also show the reference activity of any series of records. The reference activity
is simply how often a record series is accessed. NARA classifies records’ reference activity as:
· Current: at least one reference per month;
· Semicurrent: less than one reference per month; and
· Noncurrent: not used for current agency business.
An inventory can determine if a record series has a high, medium, or low rate of activity – i.e.,
whether it is current, semicurrent, or noncurrent. With this knowledge, records managers can
plan when records can be retired to a Federal Records Center, destroyed, or transferred to the
National Archives.
Planning for the orderly retirement, disposal, or archiving of records is one of the primary aims
of inventorying. These plans are formally documented in an agency’s records schedules.
6.5 Records Schedules
A records schedule is a formal description of a group of related records providing mandatory
instructions about how long the records must be kept, and whether they must be destroyed or
archived at the end of that period. It is important to realize that the disposition and retention
instructions indicated in records schedules are legally binding.
28
27
See Appendix B, Glossary, for the definition of “unscheduled records”.
28
See 44 U.S.C. 3303(3).
Records Management for OPM Internal Administrative
34
Records schedules are sometimes referred to as records control schedules or records disposition
schedules. Certain Standard Forms
29
refer to disposition authority, meaning the records schedule
authorizing the disposition of a series of records.
There are two basic types of records schedules: Organizational Schedules and Functional
Schedules. Organizational schedules are prepared for each department or division within an
agency; functional schedules are grouped by business function or functional type. Most OPM
schedules are functional schedules, although there are a couple of organizational schedules
also.
30
NARA must approve all agency records schedules.
31
Agencies must also receive NARA’s
approval before lending records outside the Federal Government,
32
before retiring them to
NARA-operated records centers,
33
and before transferring them to other Federal agencies,
34
unless exceptions are granted by the Archivist of the United States. In fact, it is illegal to remove
or destroy official records unless they are covered by a NARA-approved disposition schedule.
35
Agencies must also receive NARA’s approval before establishing or relocating their records
centers
36
and before converting permanent or unscheduled paper originals to other media.
37
Previously approved schedules for permanent hard copy records can now be applied to records in
other media either by sending NARA a notification or by rescheduling with a SF 115 Request for
Records Disposition Authority form.
38
Records are created by or for an agency and are maintained under agency control as long as the
records are needed to conduct agency business. Records schedules are required for all records.
When a new kind of record is created which is not covered by an existing records schedule, one
must be created for it.
In 1978, use of the General Records Schedule was made legally mandatory. The disposal
authorization must be used by a Federal agency to the greatest extent possible General Records
Schedules in developing their own schedules. However, agencies that have program schedules
that are unique to the mission of that agency and are not covered by the GRS. When this
happens, contact the NARA records appraisers, who will assist agency staff in the development
of new schedules.
39
29
For example, SF 115, Request for Disposition Authority; SF 135, Records Transmittal and Receipt; and SF 258,
Agreement to Transfer Records to the National Archives.
30
OPM’s schedule ADM (Administrative Management) is an example of a functional schedule; schedule OIG
(Office of Inspector General) is an organizational schedule.
31
See 36 CFR 1220.38(b).
32
See 36 CFR 1228 Subpart E, Loan of Permanent and Unscheduled Records.
33
See 36 CFR 1228.160.
34
See 36 CFR 1228 Subpart H, Transfer of Records From the Custody of One Executive Agency to Another.
35
See 44 U.S.C. 3303a and 3314.
36
See 36 CFR 1228.240.
37
Other media includes electronic, microform, cartographic, etc. See 36 CFR 1228.31, 1228.266, and 1228.268.
38
See NARA Bulletin 2010-04 Guidance Concerning Notifications For Previously Scheduled Permanent Records.
39
To find OPM’s NARA Records Appraiser, see NARA’s Contact Information For Federal Agency Appraisal And
Scheduling Work Groups, and click on Domestic Work Group 2.
Records Management for OPM Internal Administrative
35
6.5.1 General Records Schedules and OPM Schedules
For the purposes of scheduling records in the Federal Government, there are two different groups
of records schedules. These two groups are (1) the General Records Schedules (GRS) issued by
NARA and available on NARA’s Web site, and (2) individual record schedules approved by
NARA for specific agencies such as OPM. The 25 schedules included in the GRS are listed
below. Notice that although the schedules are numbered 1 through 27, one schedule (19) is
reserved and another (22) has been withdrawn.
General Records Schedules
Schedule 1. Civilian Personnel Records
Schedule 2. Payrolling and Pay Administration Records
Schedule 3. Procurement, Supply, and Grant Records
Schedule 4. Property Disposal Records
Schedule 5. Budget Preparation, Presentation, and Apportionment Records
Schedule 6. Accountable Officers' Accounts Records
Schedule 7. Expenditure Accounting Records
Schedule 8. Stores, Plant, and Cost Accounting Records
Schedule 9. Travel and Transportation Records
Schedule 10. Motor Vehicle Maintenance and Operations Records
Schedule 11. Space and Maintenance Records
Schedule 12. Communications Records
Schedule 13. Printing, Binding, Duplication, and Distribution Records
Schedule 14. Information Services Records
Schedule 15. Housing Records
Schedule 16. Administrative Management Records
Schedule 17. Cartographic, Aerial Photographic, Architectural, and Engineering Records
Schedule 18. Security and Protective Services Records
Schedule 19. RESERVED
Schedule 20. Electronic Records
Schedule 21. Audiovisual Records
Schedule 22. Inspector General Records (WITHDRAWN)
Schedule 23. Records Common to Most Offices Within Agencies
Schedule 24. Information Technology Operations and Management Records
Schedule 25. Ethics Program Records
Schedule 26. Temporary Commissions, Boards, Councils and Committees
Schedule 27. Records of the Chief Information Officer
As noted in Subsection 6.2, OPM’s schedules are a close match to OPM’s business functions.
Because of this, OPM’s schedules cover broad categories of records and have many individual
disposition items.
OPM’s GRS-based and individual records schedules are available on THEO on the OPM
Publications Database. In addition to applying the General Records Schedules to our internal
agency records, OPM issues instructions to other agencies regarding the maintenance and
disposition of records for which OPM has Government-wide program responsibility. These
Records Management for OPM Internal Administrative
36
instructions are issued through the FPM Issuance System, Privacy Act notices, and by
delegations of authority and other means. Before issuing such instructions, OPM offices must
ascertain if they conform to records disposition guidelines published by NARA in General
Records Schedule No. 1 (Civilian Personnel Records). When the NARA guidelines do not
apply, OPM must submit the instructions to NARA for approval. Records created because of
new programs must be scheduled for disposition within 1 year of the implementation of the
program. Submit requests for approval of these disposition instructions to NARA through the
OPM Records Officer, as described in Subsection 6.6.
GRS schedules that are open-ended (e.g., destroy when no longer needed for administrative,
legal, audit, or other operational purposes) must be modified by the Records Officer to apply a
more specific disposition instruction, such as destroy when 1 year old or delete after 2 update
cycles applying the modified disposition to agency and program needs. The point of organizing
an agency’s electronic records is to enable accessibility not only by current users, but by future
users as well. Records retention schedules are applied to electronic records just as they are to
paper records. Having the relevant date associated with the file is essential. Though many
operating systems store this information with the file, as users move the file among folders and
computers and as the file is re-saved as revisions are made, those dates change. A file could have
dates that do not make much sense to its original creation. The best way to prevent confusion is
to embed the relevant date (the date that the file was created or revised) in the file name itself.
6.5.2 New or Revised Records Schedules
If your office has records that are not covered by an approved records disposition schedule, you
must obtain a new or revised disposition schedule. In addition, if your office develops a new
program, or program revision, requiring new records to be maintained by a number of OPM
offices, your office must submit a request for approval of a disposition schedule for the records.
By definition, unscheduled records are not covered by NARA approved disposition schedules.
Therefore, they must be treated as permanent records until they are covered by an approved
schedule.
40
NARA approval is required even if you no longer accumulate the records in
question.
PUT in NOTE box Note: If your office wishes to destroy unscheduled records, you must first
consult the OPM Records Officer, who will then consult with OPM’s NARA appraiser as to
whether or not these records can be destroyed. Subsection 6.6 provides instructions on
recommending and obtaining approval of a new or revised records disposition schedule. More
detailed guidelines on the factors to consider when recommending disposition schedules are in
the NARA records management handbook, Disposition of Federal Records
(DFR).
To reiterate, NARA must approve:
· Any new and revised OPM records schedules.
· Any temporary extension of a retention period.
41
40
See 36 CFR 1228.70.
41
See 36 CFR 1228.32 and 1228.54.
Records Management for OPM Internal Administrative
37
· The use of a retention period that is different from that provided in a General Records
Schedule.
42
6.6 Standard Form (SF) 115 and Requesting a New or Revised Records Schedule
To request NARA approval of a new or revised schedule, submit an email to the OPM Records
Officer in the Office of the Chief Information Officer (OCIO) and provide a description of the
records and a recommended retention period as outlined in paragraphs 1 and 2 below. Based on
this description, the RO will make a determination whether the records described are:
1. already covered by one or more GRS schedules,
2. are covered by one or more OPM schedules,
3. are covered by either the GRS or OPM schedules, but require substantial revision,
43
or
4. are new records presently not scheduled by either GRS or OPM schedules.
If the RO decides that either option 3 or 4 pertain to the records, a Standard Form (SF) 115
Request for Records Disposition Authority will be completed and sent to NARA for approval.
44
You must complete a SF 115 form for the scheduling of all records for which no GRS or OPM
schedule is applicable. You must also complete a SF 115 form to make substantial revisions in a
schedule already approved by NARA (see Note 44). Such revisions constitute an amendment
and must be approved by NARA.
After an annual inventory and file plan is completed, you may have discovered unscheduled
records in your office. The information about these records can be used in completing a SF 115.
In fact, it is often during the inventory process that unscheduled records, or records whose
schedules require revision, are discovered.
SF 115 forms are usually complete the Records Coordinator and signed by the Records Officer,
but occasionally NARA will complete SF 115 forms and the Records Officer approves the form.
This may happen during a project to schedule large numbers of unscheduled agency records
stored in FRCs. In this case, NARA submits the SF 115 to the agency that owns the records for
their approval.
The SF 115 form itself is brief and consists mainly of boxes for contact information (Boxes 1
through 5), an Agency Certification box confirming that the signatory below is authorized to act
for the agency in matters pertaining to records disposition, and that Government Accountability
Office (GAO) concurrence is not required, is attached, or has been requested (Box 6) (see
Subsection 6.7.2).
Box 7 Item Number is used to list disposition item numbers for new schedules or new disposition
items for existing schedules to be revised.
Box 8 Description of Item and Proposed Disposition is the most important part of the form. Here
the RO, working with the RC(s) and Program Manager(s) most familiar with the records, write a
summary description of the records included in a new schedule. Below this summary
42
See 36 CFR 1228.42 [Schedule] Applicability.
43
Substantial revision means the addition of a new series of records to the schedule, i.e., a new disposition item; or
the change of disposition or retention periods or both to one or more disposition items in the schedule.
44
See DFR, Chapter V Schedule Preparation And Clearance for more information about the SF 115 form.
Records Management for OPM Internal Administrative
38
description, there will be descriptions of individual items or sub-items. Below the description(s)
there must be included language indicating the disposition of the records and their retention
periods (see Subsection 6.7.1).
Box 9 will be completed by the RO only when the SF 115 is used to revise an existing schedule
by entering the GRS schedule or SF 115 number. The SF 115 number will be in the format:
· N# - ### - ## - #.
45
Box 10 is completed by NARA.
1. Description of the Records
Describe the records for which you need a disposition schedule. Show the inclusive dates of the
records. Indicate if they are not textual records (for example, magnetic tape, photographs, or
sound recordings).
Each record series must contain the largest practical grouping of separately organized and
logically related materials that can be treated as a single unit for purposes of disposition.
Subparts of a series may be listed separately if numbered consecutively as 1a, 1b, etc., under the
general series. (See Section 7 for instructions for electronic records, electronic information
systems, and Web records.)
NARA also needs specific information on the identification and definition of all electronic data
sets transferred, record layouts specifying relative positions, lengths, and definitions of all data
elements, and codebooks for all unique codes used in the records.
A description for electronic records must include the elements indicated below:
· Name of the system: Indicate the commonly used name and acronym of the system.
· System control number: Specify the internal control number assigned to the system for
reference, control, or cataloging purposes. For example, the ADP plan control number.
· Agency programs supported by the system: Show the agency program(s) or mission(s) to
which the system relates, and cite any laws or directives authorizing such programs or
missions. Also, list the names, office addresses, telephone numbers, and location of the
program personnel who can provide additional information about the program and the
system supporting it.
· Purpose of the system: Indicate the reasons for the system and the requirements met by
it.
· Data input and sources: Describe the primary data input sources and the providers of the
data to the system. Also, give the names of any other systems, either inside or outside the
agency, from which this information system receives data.
45
See NARA’s Records Control Schedules for PDFs of most SF 115s for Record Groups 146 (Civil Service
Commission) and 478 (OPM).
Records Management for OPM Internal Administrative
39
· Major output: Show the system's main products and the frequency of their preparation.
For example, reports, tables, charts, graphic displays, catalogs, or correspondence-
prepared weekly, monthly, or yearly. Also, indicate whether the information is
transferred to other systems.
· Information content: Indicate the main subject matter, date coverage, time span,
geographic coverage, update cycle, and other major characteristics of the system. Also,
tell whether the system saves superseded information and whether it contains microdata
or summary data (see Section 7 Electronic Records in this directive).
2. Recommended Retention period
Following the guidelines below, include a recommended retention period, with a brief
explanation of how you arrived at the recommended period.
As a general rule, no series should be retained for more than 5 years after creation, or 5 years
after the close of the transaction or case file, or 5 years after an event without justification by the
creator of the file or file custodian. If you are recommending a retention period of more than 5
years, include a justification in the request memorandum. The justification would normally be
one of the following:
· Administrative needs requiring a longer period.
· Pertinent statutory provisions, if any.
· Needs pertaining to rights of and benefits to individuals.
· Needs pertaining to national security.
· Government-wide needs.
If you are recommending a permanent retention period, explain how the records meet the criteria
set forth in Subsection 6.9 of this directive.
3. Media Neutrality
All new records schedules submitted to NARA for approval after December 17, 2007 are
considered media neutral unless otherwise specified in the schedule. This means that the
disposition instructions apply to the records described in the schedule regardless of whether they
are paper, electronic, or in some other medium.
46
For more information about media neutral
schedules, see NARA’s Frequently Asked Questions (FAQs) About Media Neutral Schedule
Items.
6.7 Records Disposition and Retention Periods
Records schedules indicate both a record’s disposition (whether it is of temporary or permanent
value) and its retention period (how long the record must exist in agency ownership before it is
destroyed or archived). The retention period is the period of time during which OPM must be
concerned with records maintenance.
46
See 36 CFR 1228.24(b)(3).
Records Management for OPM Internal Administrative
40
Although maintenance of our permanent records is a particular concern, we must be mindful of
how all OPM’s records are maintained. While the great majority of any agency’s records are
temporary, there is wide variation in the length of retention periods. Temporary records can be
retained anywhere from a few months to decades. Care must be taken in the maintenance of all
records, but most especially those with long retention periods.
Once records are no longer needed by OPM, the ownership of permanent records is transferred to
NARA, and temporary records are destroyed. It should be noted here that unscheduled records
cannot be destroyed and their ownership cannot be transferred to NARA. Unscheduled records
are treated like permanent records, at least until they are given a NARA-approved schedule or
destroyed.
6.7.1 Wording of Disposition Instructions and Retention Periods
The wording of the schedule disposition instructions must be completely clear. If records are to
be retired to a Federal Records Center (FRC) when they become inactive, the schedule must
make this clear in its disposition instructions. The timing of the records destruction and whether
it is to take place at OPM or a FRC must not be left to chance or possible misinterpretation. This
also means that offices must inventory their records annually to make sure that records are being
retired, destroyed, or archived in a timely manner.
Use the term "destroy" instead of "dispose of" or "dispose" in the disposition instructions.
Technically speaking, "dispose" means destruction or donation of records and nonrecords.
47
Please note there is a common misconception that the word dispose can mean the removal of
records from an office rather than physical destruction. This is not correct. Depending upon the
scenario, the correct words to use are “transferring” “retiring” “loaning” ”donating” or if
transferring records to NARA, you are then archiving records. Contact your Records
Coordinator or Records Officer for further clarification.
The use of the word "destroy,” does not preclude donation of the records. Temporary records
may be donated by agencies to any eligible person, organization, institution, corporation, or
government (including a foreign government) that has requested them, with prior written
approval from NARA.
48
Permanent or unscheduled records are not eligible for destruction and
cannot be permanently donated.
It is important to remember that neither permanent nor unscheduled records may be destroyed
without the approval of OPM’s Records Officer and NARA’s appraiser.
Permanent and unscheduled records can also be loaned to other Federal Agencies for limited
periods. They may not, however be loaned to non-Federal entities without NARA approval. See
36 CFR 1228.70 – 1228.76.
47
See DFR, Appendix D Glossary (1997 edition in paper only). See EPA’s Records Web site under Glossary,
Abbreviations and Acronyms which is based on the NARA document.
48
See 36 CFR 1228.60, Donation of temporary records.
Records Management for OPM Internal Administrative
41
One method of expressing the retention period for temporary records is to specify a fixed period
after the creation of the records. For example, the phrase "destroy when 2 years old" provides
continuing authority to destroy records in a given series 2 years after their creation.
Records can also be scheduled for destruction a fixed period after a predictable event, as in the
following examples:
· "After completion" (e.g., of a study, project, or audit).
· "After sale or transfer" (e.g., of personal or real property).
· "After publication" (e.g., of an annual report).
· "After it is superseded" (e.g., a directive).
· "After revision or cancellation" (e.g., of a form).
· "After acceptance or rejection" (e.g., of an application).
· "After audit" (e.g., of accounts).
· "After settlement" (e.g., of accounts or a claim).
· "After acceptance" (e.g., of a bid or recommendation).
· "After end of fiscal year" (e.g., of budget reports).
· "After termination" (e.g., of a contract).
· "After transfer" (e.g., of an employee).
· "After conversion from paper to another medium" (e.g., the PDF
49
image from scanning
information contained in a paper report).
You may transfer the records after the event has occurred and provide a definite disposition date,
as in the following disposition instruction: “Retire records to FRC after completion of project.
Destroy 5 years after retirement.”
Avoid open-ended retention periods as much as possible. Retention period language such as
“destroy when no longer needed” must only be used for nonrecords or records of very brief
retention (less than a year).
Every effort must be made to establish retention periods that are fixed rather than
contingent because of the cost of storage incurred by OPM.
6.7.2 Obtaining Government Accountability Office (GAO) Clearance
You must obtain Government Accountability Office (GAO) approval before:
· applying a retention period of less than three years to program records,
· before scheduling records pertaining to claims by or against the Government, and
49
PDF stands for “Portable Document Format”, a type of image file.
Records Management for OPM Internal Administrative
42
· before applying retention periods that are shorter than those applied by the General
Records Schedules for the following types of records.
50
Note that these types of records
are expressly covered by GRS 2 through GRS 10.
o Payroll and pay administration
o Procurement and supply
o Property disposal
o Budget preparation, presentation, and apportionment
o Accountable officers' accounts
o Expenditure accounting
o Stores, plant, and cost accounting
o Travel and transportation
o Motor vehicle maintenance and operation
The OPM Records Officer will obtain this clearance, when it is required. Your request
memorandum must explain why the shorter retention period is required.
51
6.8 Factors to Consider When Recommending Retention Periods
6.8.1 Frequency of Reference
The frequency of reference is a major determinant of retention periods. The following are
examples of retention periods based on normal reference experience:
(1) Office correspondence files on administrative matters
- At group and division levels: 3 years
- At other levels: 2 years
(2) Office correspondence files on program matters
- At all levels: 3 years
(3) Reports data
- At summarizing levels: 4-5 years
- At submitting levels: 2-3 years
(4) Records of routine transactions
- 6 months to 1 year after completion of the transaction
(5) Inspection and audit reports
- 5 years
(6) Work papers for publications
50
See CFR 36 CFR 1228.30(d) and 44 U.S.C. 3309.
51
Box 6, Agency Certification, of the Standard Form 115 Request for Records Disposition Authority specifically
calls for the Records Officer to certify that he or she is authorized to request disposition authority for records and
that written concurrence by the GAO is not required, is attached, or has been requested.
Records Management for OPM Internal Administrative
43
- 2 years after publication
(7) Transaction files
- Maximum of 6 years after close of file or termination of transaction unless there are
special legal factors requiring a longer period
6.8.2 Legal Factors
Legal factors may influence the determination of some retention periods. Federal statutes of
limitations require that some records be retained for as long as legal actions are possible.
The Records Disposal Act of 1943 states:
52
Records pertaining to claims and demands by or against the Government of the United States
or to accounts in which the Government of the United States is concerned, either as debtor or
creditor, may not be disposed of by the head of an agency until the claims, demands, and
accounts have been settled and adjusted in the Government Accountability Office, except
upon the written approval of the Comptroller General of the United States.
Claims must be made within 6 years after the event on which the claim is based. Few statutes of
limitations affecting the retention of records are longer than 6 years. Transportation claims must
be brought within 3 years of a given event. A 6-year period governs tort and other types of
claims brought before the Court of Claims.
When retention periods are based on the requirements of a statute of limitations, a short period in
addition to the required limit may be added. This is sometimes needed to prevent legal problems
that may arise if disposal is effected on the exact day that statutes of limitations expire. The
length of such added periods must be carefully controlled. Legal factors other than statutes of
limitations may affect the determination of retention periods. Ongoing litigation may influence
the retention of many classes of records beyond established retention periods. Records involved
in pending claims must be withdrawn and segregated. In this way, the scheduled disposal of
records can proceed without interruption or complication. The OPM Records Officer must
maintain close contact with OPM’s Office of the General Counsel (OGC) to avoid the improper
destruction or archiving of records subject to litigation freezes and holds, or the indefinite
postponement of the destruction of unneeded records. The Records Officer must request that
OGC submit an annual list of all litigation holds as an added safeguard. See Section 8 for more
details concerning litigation holds and freezes.
52
See 44 U.S.C. 3309.
Records Management for OPM Internal Administrative
44
6.8.3 Name Files
Three conditions govern the disposal of name files relating to rights, benefits, and other
transactions involving persons:
1. Close of the file. This takes place when claims benefits are exhausted (for either the
claimant or survivors), after the death of the individual, or after separation from the
Federal service.
2. Provisions of statutes governing a program. These affect rights following the close of
a file and the time limits on exercising those rights.
3. Administrative needs of the agency. These affect re-audit, determination of fraud, or
relation to internal agency program controls.
6.8.4 Other Factors
Special OPM administrative needs may influence retention periods. A temporary program may
be in progress, a special management audit may have been undertaken, or a special investigation
may be taking place. If one or more of these circumstances may continue beyond 1 year,
retention periods for related records must be geared to the temporary needs. When those needs
have been satisfied, shorter periods must be determined.
6.9 Identifying Permanent Records
This subsection describes the types of records that NARA generally appraises for permanent
retention. These are general guidelines only, as they cannot possibly cover the great variety of
records maintained by the Federal Government.
53
6.9.1 Files Documenting Substantive Agency Programs
Records originated by the Director's Office and by other key OPM personnel are often
designated for permanent retention since they document the evolution of major policies and
procedures. These records include correspondence with outside groups and organizations,
internal memorandums, narrative and statistical reports, budget estimates and justifications, and a
variety of other records.
Files created at lower levels within the agency may be designated for permanent retention when
they document significant developments that are not documented by files maintained at the
higher levels within the agency. Where substantial duplication exists, the file created at the
highest level is chosen.
6.9.2 Selected Case Files
Although most case files are disposable at some future date, a complete set occasionally may be
designated for permanent retention. More frequently, however, only a portion of a case file is
53
See DFR, Appendix C Appraisal Guidelines For Permanent Records.
Records Management for OPM Internal Administrative
45
selected for transfer to the National Archives. Those chosen normally fall under one or more of
the following categories:
· The case established a precedent, and therefore resulted in a major policy or procedural
change.
· The case was involved in extensive litigation.
· The case received widespread attention from the news media.
· The case was widely recognized for its uniqueness by established authorities outside the
Government.
· The case was reviewed at length in OPM’s annual report to Congress.
· The case was selected to document agency procedures instead of capturing information
relating to the subject of the individual file.
· The file is for a person of historical significance such as a former President, Vice
President, Member of Congress, high-level appointment, survivor of a high-profile
individual, and anyone who has or is receiving media attention or is historically of high
importance, whether famous or infamous.
6.9.3 Analytical Reports
Regional reports forwarded to the central office are sometimes selected because they contain
information relating to ethnic, social, economic, or other aspects of specific geographical
locations. Excluded from selection are studies and reports that are published and therefore
widely available to public libraries, as well as recurring periodic reports that are summarized on
an annual basis.
6.9.4 Records of Internal OPM, Interagency, and Other Committees
These include minutes, agendas, proposals submitted for review, and final recommendations of
meetings of ad hoc and more formally established councils, conferences, etc.
6.9.5 Legal Opinions and Comments on Legislation
Includes memorandums prepared by OGC and program offices concerning interpretations of
existing laws and regulations that govern OPM or have a direct effect on its operations.
Normally excluded are general comments and opinions relating to other Federal Agencies.
Included are formal comments on pending legislation prepared at the request of Congress or the
Office of Management and Budget (OMB). Excluded are copies of bills, hearings, and statutes
held for convenient reference.
6.9.6 Evaluations of Internal Operations
These may include evaluations of both program and administrative operations, and may be made
by OPM or by outside agencies. Agency internal evaluations will be made in accordance with
36 CFR 1220.42 relating to records creation and record keeping requirements, maintenance and
use of records and records disposition. The evaluations shall include periodic monitoring of staff
determinations of the record status of documentary materials in all media, and implementation of
Records Management for OPM Internal Administrative
46
these decisions. These evaluations should determine compliance with NARA regulations. Only
studies that recommend significant changes in policy or note significant procedural violations are
preserved.
6.9.7 Formal Directives, Procedural Instructions, and Operating Manuals
a. Records of Functional Organizations
These include organization charts, reorganization studies, function statements, and maps
showing field organization and boundaries.
b. Briefing Materials
These include statistical and narrative reports, and briefing books, designed to inform
recently appointed senior OPM officials of the current status of the agency or their
portions of the agency.
c. Public Relations Records
These include the remarks made by the Director and other senior OPM officials
concerning OPM programs. This also includes one copy of each news release or other
prepared statement issued to the news media.
d. Publications
These include annual reports to Congress; studies conducted by OPM or under contract
for OPM; procedural brochures, pamphlets, and handbooks distributed for guidance to
other Federal Agencies; and audiovisual instructional and educational materials.
e. Scientific and Technical Data
These include data resulting from controlled laboratory or field experiments. The data
may be recorded in either human-readable or machine-readable format and may be found
in notebooks, completed forms, tabulations and computations, graphs, microforms, or
machine-readable files. These items are selected for preservation if they are unique,
usable, and important. The data must be accurate, comprehensive, and complete, and
likely to be applied to a wide variety of research problems. In assessing the importance
of any set of data, consideration must be given to its historical as well as its scientific
significance.
6.10 Flexible Scheduling, “Big Bucket” Schedules, and Flexible Retention
Largely in response to the passage of the E-Government Act of 2002 (44 U.S.C. 3501), NARA
issued several bulletins describing flexible scheduling and retention as techniques for scheduling
large numbers of unscheduled electronic information systems.
54
54
See NARA Bulletins 2005-05, 2008-04, and 2010-03.
Records Management for OPM Internal Administrative
47
Flexible Scheduling: Traditional records schedules are generally applied to discrete groupings
of records or individual databases. Flexible scheduling attempts to provide concrete disposition
instructions and retention periods to groupings of information and categories of records.
Functional schedules lend themselves to flexible scheduling more easily than organizational
schedules.
“Big Bucket” Schedules: Big bucket schedules are flexible schedules that are applied to larger
aggregations of records or systems. GRS 26, Item 2a, Records Created by Advisory
Commissions, is one example of a big bucket schedule.
Flexible Retention: Flexible retention periods allow for minimum and maximum retention
periods to be assigned to large aggregations of records as found in big bucket schedules. The use
of maximum and minimum retention periods can be expressed with such instructions as:
· Destroy when 3 years old. Records may be retained for an additional 2 years if required
for business purposes, or
· Destroy when no less than 3 years old and no more than 6 years old.
6.11 Transferring Records to Records Storage Facilities
OPM may transfer records for storage in the following types of storage facilities:
· NARA Federal Records Centers (FRCs).
55
· Records centers operated by or on behalf of OPM,
56
either alone or together with other
Federal Agencies, other than NARA.
· Commercial records storage facilities operated by private entities independently of OPM.
Records transferred to a storage facility remain in OPM’s legal custody. See 36 CFR 1228
Subpart K for storage facility standards, the requirements that OPM must meet before
transferring records,
57
and mandatory transfer procedures.
58
6.12 Federal Records Centers
6.12.1 Purpose and Location
A nationwide system of Federal Records Centers (FRCs) is operated by NARA for the cost-
effective storage of Federal records. Records are now stored in these centers at a per box
charge to agencies, including OPM. The records stored in the FRCs remain in the custody of the
submitting agencies and can be accessed at any time. See contact information for the National
and Regional Federal Records Centers on the next three pages.
6.12.2 Records Eligible for Transfer to a Federal Records Center (FRC)
55
See NARA’s FRC Toolkit for procedures for shipping records to a Federal Records Center.
56
Such as the Retirement Operations Center at Boyers, PA.
57
See 36 CFR 1228.154.
58
See 36 CFR 1228.160.
Records Management for OPM Internal Administrative
48
OPM’s records disposition schedules indicate when many OPM records are to be transferred to
the FRC. Records transferred to the FRC must meet the following criteria.
- Records must be designated for transfer to a FRC in a NARA-approved records
disposition schedule. The Federal regulations regarding the transfer of records to
storage can be found in 36 CFR 1228, Subpart I.
- Records must be covered by a disposition schedule with a definite disposition date.
The disposition date cannot be contingent on some other event, such as “destroy 6
months after the abolishment of the register”. Contingency disposition will be
allowed by the OPM Records Officer when:
· The contingency upon which the disposal of the records is based is unavoidable, i.e.,
disposal after a set retention period would unduly hamper the operation of the agency,
endanger legal rights or obligations of individuals or the Government, or prevent the
agency from carrying out statutory responsibilities.
· The annual volume of the series justifies the shipping and processing expenses of
retirement.
· The FRC's have sufficient space to accommodate the records.
· OPM provides a review date for the periodic, systematic review of the records to
determine if they can be destroyed.
- Records must not be needed to carry out current agency operations.
- Records must be referred to only occasionally (usually not more than once a month
per file drawer) in the normal course of events.
- Records must not be eligible for immediate destruction, or for destruction within 1
year of the date of transfer.
- It must cost less to transfer the records than to retain them in agency space and
equipment.
Records which meet the above criteria, and which are adequate in volume to justify the transfer,
must be sent to a FRC.
Give priority to transferring records from expensive office space, from space convertible to
office use, from leased space, and from reusable filing equipment.
Before transferring records, remove all nonrecord materials from the files. Do not transfer
nonrecord files to the FRC. Destroy this material when it is no longer needed. See Subsections
4.1.1 Nonrecords and 4.1.2 Personal Papers. Section .01.B.2 of Part I of AM Supplement 44-2,
Maintenance of Records, also discusses the difference between record and nonrecord file
materials.
59
NATIONAL RECORDS CENTERS
59
The Maintenance of Records (1993) is out of print and not available on the OPM Publications Database, although
Word copies are in existence. Contact the OPM Records Officer for more information.
Records Management for OPM Internal Administrative
49
Areas Served
Location
Entire Federal Government for personnel records
of separated Federal employees; medical and pay
records of all Federal employees; designated
medical records of Army and Air Force military
personnel and their dependents; and records of
agencies in the St. Louis area (Missouri only), of
Scott AFB, IL, and of the Memphis Service
Center, Internal Revenue Service. Permanent
microforms from offices (except Washington,
D.C. area) are stored at the National Personnel
Records Center-Civilian Personnel Records.
National Personnel Records Center
(Civilian Personnel Records)
111 Winnebago Street
St. Louis, Missouri 63118-4126
* * *
(314) 801-9250
FAX: (314) 801-9269
* * *
Email: [email protected]ov
Designated records of the Department of Defense
and the U.S. Coast Guard.
National Personnel Records Center
(Military Personnel Records)
9700 Page Avenue
St. Louis, Missouri 63132-5100
* * *
Phone: (314) 801-0800
Fax: 314-801-9269
Email: [email protected]ov
District of Columbia, Maryland, Virginia, and
West Virginia and armed forces worldwide
(except records of Federal courts in MD, VA and
WV)
Permanent microforms from offices in the
Washington, D.C. area.
Shipping and mailing address:
Washington National Records Center
4205 Suitland Road
Suitland, MD 20746-8001
* * *
(301) 778-1600
Figure 5. National Records Centers
Records Management for OPM Internal Administrative
50
REGIONAL RECORDS CENTERS CURRENT AS OF SEPTEMBER 10, 2010
Region
Location
Areas Served
NARA’s Northeast Region
(Boston)
Frederick C. Murphy
Records Center
380 Trapelo Road
Waltham, MA 02452-
6399
(781) 663-0130
Maine, Vermont, New
Hampshire,
Massachusetts,
Connecticut, and Rhode
Island
NARA’s Northeast Region
(Pittsfield)
Federal Records Center
10 Conte Drive
Pittsfield, MA 01201-
8230
(413) 236-3600
Selected Federal records
from throughout the U.S.
NARA’s Mid-Atlantic
Region
Federal Records Center
14700 Townsend Road
Philadelphia, PA 19154-
1096
(215) 305-2000
Delaware and
Pennsylvania, and Federal
court records for
Maryland, Delaware,
Virginia, West Virginia,
and Pennsylvania
NARA’s Southeast Region
Federal Records Center
4712 South Park Blvd.
Ellenwood, GA 30294
(404) 763-2820
Kentucky, North Carolina,
South Carolina,
Tennessee, Mississippi,
Alabama, Georgia, and
Florida
NARA’s Great Lakes
Region (Chicago)
Federal Records Center
7358 South Pulaski Road
Chicago, IL 60629-5898
See NARA Chicago Web
site for phones.
Illinois, Wisconsin,
Minnesota, and Federal
court records for Indiana,
Michigan, Ohio, Illinois,
Minnesota, and Wisconsin
NARA’s Great Lakes
Region (Dayton)
Federal Records Center
3150 Springboro Road
Dayton, OH 45439-1883
(937) 425-0600; and
8801 Kinsridge Drive
Dayton, OH 45458
(937) 425-0601
Indiana, Michigan, Ohio,
Agency Services,
Bankruptcy Reference,
and selected Internal
Revenue Service Centers
NARA’s Central Plains
Region (Lee’s Summit)
Federal Records Center
200 Space Center Drive
Lee’s Summit, MO 64064-
1182
(816) 268-8100
Federal Agencies and
courts in New Jersey, New
York, Puerto Rico, The
U.S. Virgin Islands, and
most Department of
Veterans Affairs offices
nationwide
Records Management for OPM Internal Administrative
51
Region
Location
Area Served
NARA’s Central Plains
Region (Lenexa, KS)
Federal Records Center
17501 W. 98
th,
Suite 47-48
Lenexa, KS 66219
(913) 563-7600
Kansas, Nebraska, Iowa,
and Missouri Veterans
Affairs and Internal
Revenue Service records.
NARA’s Southwest
Region
Federal Records Center
1400 John Burgess Drive
Fort Worth, TX 76140
(817) 551-2000
Texas, Oklahoma,
Arkansas, and Louisiana
NARA’s Rocky Mountain
Region
Denver Federal Center
Building 48
West 6
th
Avenue &
Kipling Street
PO Box 25307
Denver, CO 80225
(303) 407-5700
North Dakota, South
Dakota, Colorado,
Wyoming, Utah, Montana,
and New Mexico
NARA’s Pacific Region
(Riverside)
Federal Records Center
23123 Cajalco Road
Perris, CA 92570-7298
(951) 956-2000
riverside.archives@nara.gov
Clark County, Nevada,
Southern California
(counties of San Luis
Obispo, Kern, San
Bernardino, Santa Barbara,
Ventura, Los Angeles,
Riverside, Orange,
Impenal, Inyo, and San
Diego), and Arizona
NARA’s Pacific Region
(San Francisco)
Federal Records Center
1000 Commodore Drive
San Bruno, CA 94066-
2350
(650) 238-3500
Nevada (except Clark
County), California
(except Southern
California) and selected
Federal Agencies in the
Pacific Ocean area
NARA’s Pacific Alaska
Region
Federal Records Center
6125 Sand Point Way, NE
Seattle, WA 98115-7999
(206) 526-6501
seattle.archives@nara.gov
Washington, Oregon,
Idaho, and selected
Federal Agencies in
Alaska, Hawaii, and the
Pacific Ocean area
Figure 6. Regional Records Centers
Records Management for OPM Internal Administrative
52
6.12.3 Preparing Records Transfer Forms
Transfers to FRCs must be accompanied by Standard Form (SF) 135, Records Transmittal and
Receipt. Electronic copies of the SF 135 are available at NARA’s Federal Records Centers Web
site under Forms.
Records Coordinators and other records management staff in Headquarters Program offices and
in field offices complete the SF 135 form. After completion, the form is submitted to the OPM
Records Officer, or designee, for approval and signature.
The instructions - At group and division levels: 4-5 years below cover item 6 on this form, and
are for those field offices that complete the form themselves. Most of the items on the form are
self-explanatory.
Columns 6a, b, & c, Transfer Number
A separate transfer number, formerly called an accession number, is required for each series of
records listed on the form. A transfer consists of records in one series that have the same
disposal authority and disposition date. Each transfer will be shelved in contiguous space in the
record center. The transfer number consists of three parts.
a. The OPM record group number, which is 478 (RG 478).
b. The last two digits of the current fiscal year.
c. A four digit sequential number. This number is assigned by the FRC that will be
receiving the retired records.
Column 6d, Volume
Enter the total volume (in cubic feet) for each series of records being transferred. Each standard
size FRC carton equals 1-cubic foot.
Column 6e, Agency Box Numbers
Show the inclusive box numbers for each transfer being shipped. Each new transfer must begin
with number 1 and each carton must be numbered sequentially in the upper right hand corner.
Column 6f, Series Description
Describe the records in sufficient detail to allow the records center to check for the proper
application of the disposal authority and to facilitate reference service. Indicate whether or not
the records have special status such as ”vital records" or "GAO site audit records." Give the
inclusive dates of the records. Indicate the organizational component that created the records
when it is different from that shown in item 5, the address of the originating organization.
Explain special restrictions here (see the following section – 6g). Identify any boxes that have
Records Management for OPM Internal Administrative
53
non-textual materials. If materials will not fit into standard FRC boxes (such as rolled
drawings), include the dimensions of the records in inches.
Column 6g, Restrictions
Enter one of the following codes in column 6g to show the restrictions on the use of the records.
Q - "Q" security classification
T - Top secret
S - Secret
C - Confidential
W - Restricted use/witnessed destruction required (specify restriction in
column 6f). See Subsection 6.14 Disposing of Temporary Records.
R - Restricted use/witnessed destruction not required (specify restriction in
column 6f)
N - No restrictions
OPM should have few, if any, occasions to use the first four restrictions above. The "W"
restriction is appropriate, however, for records covered under the Privacy Act of 1974. Other
restrictions, such as limiting access to certain agency officials, are to be specified by a statement
in column 6f.
Column 6h, Disposal Authority
For each series of records, cite the OPM records schedule and the specific item number
authorizing disposition. If the records are covered by a disposition schedule that has not yet been
incorporated into the OPM Records Disposition Schedules Directive, cite the NARA disposition
job and item number. See Subsection 6.6 of this Directive for NARA disposition job number
format.
If the records are covered by the General Records Schedule (GRS), list the GRS
schedule number and item number.
Column 6i, Disposal Date
Applying the disposition authority cited in column 6h, enter the month and year the records must
be destroyed.
Email a copy of the SF 135 completed through Box 6 to the OPM Records Officer. The RO will
review the SF 135 for accuracy and completeness. The RO will approve the SF 135 by signing
and dating the form in Box 2. If the RO does not approve the SF 135, it will be sent back to the
preparer’s office to be corrected. After approval, the RO will email the SF 135 to the FRC. The
FRC will review the SF 135 for completeness, and to determine the appropriateness of the
transfer. If the transfer is approved, the FRC will assign a Transfer number (See Boxes 6a, 6b,
and 6c of the SF 135) to the SF 135 and email the form to the OPM Records Officer, indicating
that the records may be transferred. The RO will forward the approved SF 135 to the preparer’s
office.
Records Management for OPM Internal Administrative
54
After receiving the approved SF 135, the preparer will write the transfer number on each box to
be shipped. The preparer will also write box numbers on each box in the format Box 1 of 8, Box
2 of 8, etc. The preparer will place copy of the FRC-approved SF 135 in the last carton of the
shipment when the records are shipped to the center. The center will annotate block 6j with the
shelf location where each transfer is stored.
The physical transfer of the records must be made within 90 calendar days after the receipt of the
approved SF 135. A delay of more than 90 days will require resubmission of the SF 135.
Upon receipt of the records shipment at the records center, the cartons are matched against the
copy of the SF 135 submitted with the transfer. That copy is then signed by a representative of
the FRC and returned to the submitting office. Any changes in the location numbers will be
noted on this receipt copy before it is returned. This is the only receipt that the records center
will provide for the transferred materials.
Note that FRC has four quarterly disposal cycles, in January, April, July, and October. Advance
the disposition date for temporary records into the next cycle.
6.12.4 Preparing the Files for Transfer
1. Records Center Boxes
The standard container used to transfer letter- and legal-size documents to a FRC is a cardboard
box (known popularly as a records center box). Each box holds approximately 1-cubic foot of
records. The following records center boxes and materials required for records transfer are
available from the General Services Administration:
(a) Standard-size record boxes:
14 3/4" x 12" x 9 1/2" NSN 8115-00-117-8349
(b) Special-purpose boxes:
Half-size box
14 3/4" x 9 1/2" x 4 7/8" Special Order - GSA
Use half-size boxes only for microfilm, index cards, or other odd-size material. When preparing
SF 135, item 6(d), a half-size box equals 1/2 cubic foot each.
Magnetic tape box
14 3/4" x 11 3/4" x 11 3/4" NSN 8115-00-117-8347
Microfiche box
14 3/4" x 6 1/2" x 4 1/2" NSN 8115-01-132-1923
2. Packing the Cartons
Use the proper size box when packing records. For legal- and letter-size material, use standard-
size boxes. Place letter-size records in the box with labels facing the numbered end. The
numbered end will be opposite the stapled end. Place legal-size records in the box so that the
Records Management for OPM Internal Administrative
55
labels face to the left of the box as you face the numbered end (see FRC Toolkit, figure 2).
Leave approximately 1 inch of space in each box for working the files (more if interfiles will be
added later). Send only completed or closed case files, contracts, etc. Leave all guides and tabs
in the records if they will help the records center personnel service the records. Do not over-
pack the boxes. Never add additional material on the bottom, side, or top of the records in the
box.
In general, pack only one record series in a container. However, when a particular series consists
of less than 1 cubic foot at the time of its scheduled retirement, you may pack more than one
series in the same container, provided all of the series have the same retention period. Such
combinations must be approved by the FRC before the records are packed for transfer.
You must purge non-record files before packing the boxes so that they contain only Federal
record material. The boxes may not contain duplicate copies or other reference materials.
Examples of materials, which you may not include, are extra copies of documents retained for
stock, publications, copies of correspondence received for information rather than action,
preliminary drafts of reports and correspondence, working papers, notes, tickler copies, and
follow-up copies of correspondence.
While boxing the files, write the sequential box number in the upper right corner. Begin with
box number 1 and include the total number in the accession, such as 1/10, 2/10, 3/10, etc. Put
the transfer number in the upper left front of the carton (see FRC Toolkit, figure 2). Transfer
number and box number must be at least 1 1/2" high and written directly onto the box with a
BLACK, permanent, felt-tip marker.
Do not use labels to supply additional identifying information. No standard method of affixing
labels is effective in long-term storage. Provide any additional identifying information well
below the accession number and box number, again using a permanent black felt-tip marker.
6.12.5 Shipping the Records
Shipments to record centers normally are made by mail, truck, or rail freight at the expense of
the transferring agency. Regardless of the method of shipment used, keep the shipment cost as
low as possible. When using commercial carriers, the lowest freight rate for "old" office records
can be obtained by including the following statement on bills of lading or other shipping
documents:
The agreed or declared value of this property is hereby specifically stated by the shipper not to
exceed 3.5 cents per pound.
Records Management for OPM Internal Administrative
56
a. One center carton holds 1 cubic foot of
paper records weighing an average of
30 pounds; however, tabulating punch
cards weigh in excess of 50 pounds per
cubic foot.
b. One ton of records, on average,
measures 70 cubic feet in volume.
c. One empty, four-drawer, letter-size,
steel filing cabinet weighs 145 pounds:
wood, 100 pounds.
d. One empty, five-drawer, letter-size,
steel filing cabinet weighs 195 pounds:
wood, 180 pounds.
e. One empty, four-drawer, legal-size,
steel filing cabinet weighs 180 pounds:
wood, 160 pounds.
f. One empty, five-drawer, legal-size, steel
filing cabinet weighs 214 pounds:
wood, 200 pounds.
g. One 40-foot freight car easily will ship
1,800 cubic feet of records.
h. One 32-foot tractor trailer will
transport 1,000 cubic feet of records,
provided interstate weight limits
governing carriers do not reduce these
quantities.
i. One cubic foot equals 3,000 letter-size
sheets of paper.
j. One cubic foot equals 10,000 tabulating
punch cards.
k. A letter-size file drawer holds 1 1/2 cubic
feet of records; a legal-size drawer holds 2
cubic feet.
l. Fifty 100-foot, 35mm microfilm reels can
be stored in a standard records center
carton.
m. One hundred 100-foot, 16mm microfilm
reels can be stored in a standard records
center carton.
n. One letter-size National Archives box is to
be computed as holding .35 cubic foot of
records.
o. One legal-size National Archives box is to
be computed as holding .43 cubic foot of
records.
p. Seven reels of standard digital computer
tape (2,400 ft. in length, 1/2 inch in width)
are to be computed as the equivalent of 1
cubic foot.
Figure 4. Conversion Table for Estimating Size and Weight of Shipments of Records to FRCs
OPM Headquarters currently ships its internal administrative and programmatic records to the
Washington National Records Center (WNRC) in Suitland, MD. This FRC prefers boxes of
records to be placed on packing pallets or skids and moved to OPM’s loading dock prior to
pickup.
A packing pallet will hold 50 boxes and must be stacked so that the last box in the sequence is on
the top level. A skid holds 24 boxes and also must be packed with the last box of the sequence
on top. Facilities Management often has pallets and skids available for use. When requesting a
pickup from WNRC, the RC or other staff responsible for the shipment must request the required
number of packing pallets or skids, if Facilities Management has none.
Records Management for OPM Internal Administrative
57
If records being retired are to be transported a short distance (50 miles or less) by Government
vehicle, the top flaps of the boxes need only be tucked. For shipments over long distances, or by
commercial carrier, tape the top flaps and, as necessary, reinforce the bottoms and corners with
tape. Strapping tape and other packing supplies can be ordered at the GSA Advantage Web site.
If you use a Government truck to transport large quantities of records, call the FRC Operations
Branch or Loading Dock 24 hours before delivery so prompt unloading can take place. If you
use a commercial carrier, instruct the carrier's dispatcher to call the Operations Branch or
Loading Dock 24 hours before delivery. This instruction must be noted on the bill of lading.
See NARA’s FRC Toolkit for details about shipping records to WNRC or other Federal Records
Centers. The address for emailing SF 135s for WNRC approval is [email protected].
6.12.6 FRC Reference Service
FRCs provide a wide-range of reference services, including loan or return of records to the
agency of origin, preparation of authenticated reproductions of documents, and furnishing of
information from the records. Most inquiries are answered within 24 hours of receipt. Urgent
requests made by telephone or personal visit receive faster service.
At OPM headquarters, to retrieve a record from a FRC, contact the Records Officer, who will
arrange to withdraw the record from the center. If you know the transfer number of the
document, provide this information to the Records Officer. The Records Officer will retrieve the
record from the FRC and arrange for delivery to the requester. FRCs will provide documents
only to authorized requesters in each agency. These requests must be submitted through the
Records Officer. The FRC will not provide documents directly to unauthorized requesters.
Agencies are required to update and keep current all Authorization to Request Information
forms. Each OPM field office must designate two or more liaison representatives for retrieving
documents from their FRC. The names, addresses, and telephone numbers of these
representatives must be supplied in writing to the FRC.
Authorized representatives submit requests for retrieval of records on OF 11, Reference Request-
-Federal Records Centers. You may also use a letter or memorandum, but use of the form
usually results in faster service. Note that FRCs also accept electronic requests via the Centers
Information Processing System (CIPS) and the new Archives and Records Centers Information
System (ARCIS).
Recently federal agency interaction with FRCs has become increasingly automated by
using the new ARCIS system. ARCIS is a Web-based IT system that allows users to
initiate records reference requests (records recall from FRC via OF 11) online. Agencies
can also view past FRC records activity and the status of records that have been
transferred via SF 135. In the near future, ARCIS will have the ability to accept electronic
SF 135s, enable users to manage who in their agencies has access to their records, and who
has the ability to retire, reference, or return records (see NARA’s ARCIS Web site).
Service will be expedited if the request includes the name of the agency; the name, location, and
telephone number of the person for whom the request is being made; a full description of the
Records Management for OPM Internal Administrative
58
information or records needed; and the agency container number, the FRC location number, and
the transfer number assigned to the records by the center at the time of transfer. The information
on the container, location number, and transfer number is available from the SF 135 prepared at
the time the records were transferred to the center. Any additional information that could aid the
center, such as an index number, must also be included. If there are no security restrictions,
records centers can return a small number of records to OPM by mail or a parcel delivery
service. Some FRCs now offer localized delivery services known as Metro Courier Service, that
can deliver records to an agency within 24 hours of receipt of the request. Consult the agency
records officer to see if you are eligible to receive this service. In special circumstances, we may
ask centers to provide information directly from the records rather than sending the records
themselves. Consult your agency agreement to determine applicable fees for service. (The
Records Center program is now reimbursable and fees will apply).
Requests for service may now be processed in several ways: through ARCIS, CIPS, by
telephone, by fax, or email. The email address is [email protected].
Federal personnel visiting a center, including messengers picking up agency records, must carry
appropriate credentials. In the case of defense-classified documents, written authorization to
examine the records is also required.
6.12.7 Disposal of Records in the Centers
When the records retired to a records center are eligible for destruction, the FRC sends the
submitting agency NA Form 13001, Notice of Eligibility for Disposal, or an equivalent form, at
least 90 days prior to the scheduled date of destruction.
The OPM Records Officer receives these forms. If a National Archives (NA) 13001 form is sent
by mistake to any other than the OPM office, the recipient must immediately forward the form to
the OPM RO.
The Records Officer will immediately notify the FRC if any of the records listed on the NA
13001 Notice of Eligibility for Disposal are subject to either an ongoing or pending litigation
freeze or hold; or if there are other exceptional circumstances which dictate a longer retention for
the records,. The FRC requires written concurrence from OPM’s Records Officer agency before
any records are destroyed.
OPM’s RO may grant FRC prior approval for the destruction of eligible records, usually at the
time of the transfer. Prior written approval reduces paperwork and permits the immediate
destruction of the records at the end of the retention period. The RO with the NARA Appraiser’s
agreement may grant a destruction waiver for specific series of records transferred to centers on
a continuing basis, or for a specific shipment transfer.
Records Management for OPM Internal Administrative
59
6.13 Transferring Permanent Records to the National Archives
The National Archives and Records Administration (NARA) will accept records for permanent
retention if they have sufficient historical or other value to warrant preservation by the Federal
Government
Subsection 6.9, of this directive, Identifying Permanent Records of this Directive shows the types
of records usually classified as permanent.
Certain OPM records listed in the OPM Records Disposition Schedules are classified as
permanent, to be offered to the National Archives after a given amount of time. In addition,
OPM offices may have other records, which they believe, must be retained permanently for
historical purposes. It is important to remember that NARA ultimately decides if a record series
is of permanent value or is temporary.
Permanent records are normally retired to a Federal Records Center before their legal ownership
is transferred to NARA. This is because the retention periods of most permanent records are
long enough to make it economically desirable to move them out of agency office space to less
expensive FRC space when they cease to be active.
In cases where the records are to be transferred to NARA from a FRC, it is NARA’s
responsibility to begin the transfer process by completing its portion of the Standard Form 258
(SF 258) Agreement to Transfer Records to the Archives of the United States, and sending the
form to the OPM’s Records Officer . The RO then completes OPM’s portion of the SF-258,
signs it, and returns the form to NARA. See NARA’s Federal Records Centers Electronic Forms
& Resources Web site for a copy of the SF-258 with Instructions
In cases where records were not retired to an FRC, but are still stored in an OPM office, OPM’s
RO will initiate the transfer of records by completing its portion of the SF 258 and sending the
form to NARA for their approval and signature. Upon the RO obtaining the approved and
signed SF 258, legal ownership of these records passes from OPM to NARA.
See 36 CFR Part 1228 - Disposition of Federal Records
for details on how records in the
National Archives can be used; transfer specifications and standards for different media; and
required documentation to accompany electronic records.
6.13.1 Offering Permanent Records to NARA
OPM’s Records Officer offers permanent OPM records to the National Archives. Offices having
records that they believe must be retained permanently must contact the Records Officer.
Guidelines on transferring records to the National Archives are in 36 CFR, Section 1228 Subpart
L.
Unlike records transferred to the Federal Records Center, the records transferred to the National
Archives become the official property of NARA. Transferring agencies can, however, specify
restrictions on the use of these records, citing appropriate exemptions under the Freedom of
Records Management for OPM Internal Administrative
60
Information Act (FOIA) (see 5 U.S.C. 552).
60
NARA will abide by these restrictions, and will
not relax them without prior clearance of the transferring agency. Also identify the
alphanumeric code designation covering records constituting systems of records subject to the
Privacy Act of 1974 (5 U.S.C. 552a).
Records appraised by NARA as permanent records are transferred to NARA when they are 30
years old, or at any age when --
(1) The originating agency no longer needs to use the records for the purpose for which they
were created, or in its regular current business; or
(2) Agency needs will be satisfied by the use of the records in NARA research rooms or by
copies of the records.
6.13.2 Audiovisual Records
Audiovisual records become obsolete rapidly. Permanently valuable audiovisual records must be
offered directly to the National Archives as soon as OPM no longer uses them on a current basis.
1. Motion Pictures
When transferring motion pictures to the National Archives, the following copies are necessary
for the motion picture preservation, duplication, and reference service:
For agency-sponsored films produced for distribution outside of the agency, include (1) the
original negative or color original, plus separate optical sound track, (2) intermediate master
positive or duplicate negative plus optical sound track, and (3) sound projection print.
For motion pictures produced for internal OPM use, include (1) the original negative or color
original plus sound, and (2) a projection print.
2. Still Pictures
The following are necessary when submitting still photographs to the National Archives:
o For black and white photographs, the original negative, and a captioned print.
o For color photographs, the original color transparency or color negative, a
captioned print, and an inter-negative if one exists.
o For slide sets, the original and a reference set, and the related audio recording
and script if one exists.
o For other pictorial records, such as posters, original artwork, and filmstrips, the
original and a reference print.
60
See Section 8 FOIA, E-Discovery, and Litigation Freezes and Holds.
Records Management for OPM Internal Administrative
61
3. Sound and Video Recordings
For magnetic sound and video recordings, submit the original tape, disc, etc., or the earliest
generation of the recording available. If the video and audio portions are on separate recording
media, make sure that a copy of each is included.
See NARA’s Managing Audiovisual Records: An Instructional Guide (1999).
6.13.3 Machine-Readable Records
1. Magnetic Tape
Computer magnetic tape is a fragile medium, highly susceptible to errors by improper care and
handling. To ensure that permanently valuable information stored on magnetic tape is preserved,
schedule the file for disposition as soon as possible after the tapes are written. When NARA has
determined that a file is worthy of preservation, transfer it to the National Archives as soon as it
becomes inactive, or whenever you can no longer provide proper care or handling of the tapes to
guarantee the preservation of the information that they contain.
The tapes to be transferred to the National Archives must be on open reel magnetic tape or on
tape cartridges. Open reel magnetic tape must be on one-half inch 7 or 9 track tape reels, written
in ASCII or EBCDIC, and the data must be stripped of all extraneous control characters (except
length indicators or marks designating a datum, word, field, block, or file), blocked no higher
than 32,760 bytes per block, at 800, 1600, or 6250 bpi. Tape cartridges must be 18 track 3480-
class cartridges recorded at 37,871 bpi. The open reel magnetic tapes or the tape cartridges must
be new or recertified tapes, which have been passed over a tape cleaner before writing and
rewound under uniform tension. See 36 CFR 1228.270(c).
61
2. Other Magnetic Media
If the data designated for transfer to the National Archives is maintained on a direct access
storage device, it must be transferred to magnetic tape, meeting the specifications in 1 above,
before transferring it to the National Archives.
3. Documentation
Every transfer of electronic records to the National Archives requires documentation. The
content of documentation varies from file to file. The information may be found in paper,
microform, or electronic form. If any of the relevant documentation is in electronic form,
provide it along with the electronic records. Some OPM Records Disposition Schedules
contain
specific instructions concerning documentation that must accompany the transfer of electronic
records.
It is probably easiest to transfer records on Compact-Disk, Read Only Memory (CD-ROM)
because agencies typically have the drives for this media and it is inexpensive. Other acceptable
61
Also, see NARA’s Transfer Of Electronic Records for an overview.
Records Management for OPM Internal Administrative
62
media include magnetic tape and tape cartridges, such as Digital Linear Tape (DLT). You may
also use File Transfer Protocol (FTP).
62
A completed SF 258 (SF 258), Agreement to Transfer Records to the National Archives of the
United States, accompanies the transfer. For electronic records, NARA signs the SF 258 after
the processing is completed, not upon receipt of the records.
Attach a form NA 14097 Technical Description for Transfer of Electronic Records (see Fig. 7 on
the next page), or its equivalent, containing a specific technical description of each file
transferred. The core pieces of required information are:
· name of the file(s)
· technical contact for the file(s)
· form: either 3480 cartridge or, for open reel tape, number of tracks and tape density
· character code (ASCII or EBCDIC)
· type of internal labels (ANSI or IBM Standard)
· internal file names (dataset names)
· record length and block size
· number of records
· date recorded
Include the number of records for each file for verification purposes.
Each file requires a definition of its structure and content. At minimum, this includes a record
layout and a codebook for each field containing coded information. Information in
documentation might be in publications; administrative reports; annual reports; memoranda; user
notes; system guides; inventories or control systems for electronic records; file description;
Privacy Act notices; or manual or automated data dictionaries. For documentation, the
information is more important than the format.
63
Documentation for databases and electronic information systems (EIS) must include the SF 258
and form NA 14028 Information System Description (see figure 8).
64
62
See Transferring Permanent Electronic Records To NARA: Answers To The Top Five Questions.
63
See NARA Bulletin 2005-06, 36 CFR 1228.270 Electronic Records, and 36 CFR 1234.32 Retention and
disposition of electronic records.
64
See Section 7 Electronic Records in this directive for more information about electronic records and electronic
information systems.
Records Management for OPM Internal Administrative
63
TECHNICAL DESCRIPTION FOR TRANSFER OF ELECTRONIC RECORDS
TO THE NATIONAL ARCHIVES
FILE IDENTIFICATION
OFFICIAL FILE TITLE, COMMONLY USED IDENTIFIER, AND/OR DESCRIPTIVE
TITLE:
02. ACRONYM ASSIGNED TO FILE:
RESTRICTIONS ON ACCESS:
04. TITLE/DESCRIPTION OF DOCUMENTATION PROVIDED:
05. FORMAT OF DOCUMENTATION:
Paper
Electronic Format (Specify)
Other (Specify):
06. ELECTRONIC (agency name and address): 07. IDENTIFY TECHNICAL CONTACT(S)
FILE CHARACTERISTICS
08. SHORT TITLE ON EXTERNAL LABEL
10. STORAGE MEDIA UNIT VOLUME
SERIAL NUMBER:
12. DENSITY (CPI/BPI):
09. RETURN STORAGE MEDIA TO AGENCY
AFTER ARCHIVAL PROCESSING:
Yes No
If Yes, Provide Address for Return (if different
from item 06):
11. TYPE OF MEDIA PROVIDED:
Open-Reel Magnetic Tape
3480-Class Tape Cartridge
Other (Specify):
13. NUMBER OF TRACKS:
7 9 18
Other (Specify):
14. FILE ORGANIZATION ON STORAGE
MEDIA
One File on One Media Unit
One File on Multiple Media Units
Multiple Files on One Media Unit
Multiple Files/Multiple Media Units
15. RECORDED LABEL (Internal Label)
IBM OS
IBM DOS
ANSI X 3.27 Standard
No Internal Labels
Other (Specify and Describe)
16. CHARACTER SET
ASCII
EBCDIC
BCD (7 track only)
Binary
Packed Decimal
Other (Specify)
17. DATE FILE COPIED:
18. INTERNAL FILE NAME/IDENTIFIER
(aka Data Set Name):
19. SEQUENCE OF FILE ON
STORAGE MEDIA UNIT:
File of
20. NUMBER OF LOGICAL
RECORDS (Blocking Factor):
21. RECORD TYPE
Fixed Length (F)
Fixed Length Blocked (FB)
Other Than Fixed Length
(Specify Format)
22. LENGTH OF LOGICAL RECORDS
IN CHARACTERS OR BYTES:
24. NUMBER OF LOGICAL
RECORDS:
23. LENGTH OF PHYSICAL RECORDS
IN CHARACTERS OR BYTES:
25. NUMBER OF PHYSICAL
RECORDS (Blocks):
26. AGENCY COMMENTS:
27. FORM PREPARED BY:
Name:
Phone:
28. DATE FORM COMPLETED:
Figure 7. NARA Form 14097, Technical Description for Transfer of Electronic Records
Records Management for OPM Internal Administrative
64
The instructions for completing this form are as follows:
INSTRUCTIONS
GENERAL:
The purpose of this form is to facilitate the transfer of electronic records with continuing or
enduring value to the National Archives. A packet containing additional information on the
transfer of electronic records is available from the National Archives. This form is not intended
to take the place of other required documentation. FIPS PUB 20 contains a discussion of file
documentation. Technical information describing each file is required by 36 CFR, but NA Form
14097 is optional. If there is an alternative reporting format that provides all of this required
information, substitute the report for NA Form 14097. Include the required information as an
attachment to the SF 258. A separate form must be completed for each file. If multiple files
have very similar technical specifications, one form with an attachment that specifically
identifies all of the files covered by the form may be used.
IDENTIFICATION SECTIONS
01. Official Title, Commonly Used
Identifier, and/or Descriptive Title.
Enter the name by which the agency
identifies the file. Consider how the
title would appear in a bibliographic
entry. If there is no official title,
provide a descriptive title.
02. Acronym Assigned to File. Enter the
commonly used abbreviation or
acronym as assigned by the agency.
Often, the acronym as assigned by the
agency. Often, the acronym will be
used on the external (gummed) label of
the storage media unit.
03. Restrictions on Access. Specify any
restrictions that apply to this file - cite
FOIA exemption, and, if b (3), cite
statute, indicate specific columns of
types of records in the file that are
affected; specify length of restriction on
access and method of determining the
date when restrictions end. If there are
no applicable restrictions on access,
please indicate.
04. Title/Description of Documentation
Provided. Documentation is required
for all transfers of electronic records to
the National Archives. Enter the title or
description of the documentation
provided by the agency for the file.
Guidelines are available on the source
and content of documentation. If any
documentation is available in electronic
form, include it in the transfer.
05. Format of Documentation Provide.
Mark all boxes that apply to the transfer
with an "X." If "Electronic Format" is
checked, include a technical description
form for each documentation file in
electronic format. If "Other" is
checked, be as specific as possible in
describing the documentation
transferred.
06. Electronic Records Submitted by.
Enter the name and address of the
agency that is responsible for the
transfer.
07. Identify Technical Contact(s).
Identify the person who will respond to
technical questions about the records if
they arise during archival processing.
FILE CHARACTERISTICS
08. Short Title on External Label of
Storage Media Unit. Enter the short
title that appears on the external
(gummed) label of the storage media
unit(s).
Records Management for OPM Internal Administrative
65
09. Return Storage Media to agency
After Archival Processing. The
National Archives returns the reels or
cartridges included in the transfer to the
agency when two preservation copies
have been created. Check "No" to
indicate that the storage media must not
be returned or provide an address for
return shipment. If yes, Provide
Address for Return (if different from
Item 06).
10. Storage Media Unit Volume Serial
Number. Enter the volume serial
number that uniquely identifies this
tape/tape cartridge. If the file is
recorded on multiple volumes, enter the
first volume serial number in this item
and list others, in sequence, in item 26.
11. Type of Media Provided. To comply
with the transfer standard identified in
36 CFR, a storage media unit must be
an open-reel magnetic tape or 3480 tape
cartridge. Enter an "X" in the
appropriate box. If "Other" is checked,
contact the National Archives prior to
transfer and provide a specific
identification of the storage media used
for transfer.
12. Density (CPI/BPI). Enter an "X" in the
appropriate box to indicate characters or
bytes per inch.
13. Number of Tracks. Enter an "X" in the
appropriate box. For 7 track tapes,
indicate whether the parity is odd or
even in Item 26.
14. File Organization on Storage Media.
If a single file on a single storage media
unit is described, check "One File on
One Media Unit." If a multi-volume file
is described, check "One File on
Multiple Media Units." If more than
one file is on the storage media unit,
check "Multiple Files on One Media
Unit." If the transfer includes multiple
files on multiple files on One media
units, check "Multiple Files on Multiple
Media Units”.
15. Recorded Label (Internal Label).
Enter an "X" in the appropriate box. If
"Other" is checked, provide a specific
description of the internal labels in Item
26.
16. Character Set. Enter an "X" in the
appropriate box. If "Binary" or "Packed
Decimal" is checked, indicate the
characters (bytes) that are stored in
those formats in Item 26.
17. Date File Copied. Enter the date that
appears on internal labels, if the files are
labeled. This is the date the records
were copied onto the storage media
unit(s).
18. Internal File Name/Identifier (aka
Data Set Name). If there is a recorded
label, enter the file identification (e.g.,
Data Set Name) used in the label. File
Names in IBM standard labels must
follow IBM DSN naming conventions.
19. Sequence of File on Storage Media
Unit. If this is the only file on the
storage media unit, enter a "1”. If the
storage media unit contains multiple
files, enter the file's position number on
the storage media unit. See Item 14.
20. Number of Logical Records per Block
(Blocking Factor). If "Fixed Length" is
checked in Item 21, enter the blocking
factor.
21. Record Type. Enter an "X" in the
appropriate box. If "Other Than Fixed
Length" is checked, a specific
description of the format is very
important, especially if the
documentation provided does not
contain a precise description. Use Item
26 to describe "Other" formats.
22. Length of Logical Records in
Characters or Bytes. Enter the logical
record length in bytes or characters. If
the record is not fixed length, enter the
maximum size record, and describe
techniques used to control and indicate
size in Item 26.
Records Management for OPM Internal Administrative
66
23. Length of Physical Records in
Characters or Bytes. Enter the
physical record length in bytes or
characters. If the record is not fixed
length, enter the maximum size record,
and describe techniques used to control
and indicate size in Item 26.
24. Number of Logical Records. Enter the
number of logical records in the file.
This number is usually supplied by the
program which created the file. Labels
are not included in this count. If the last
block is padded with blank records to
fill out the block, please provide a total
record count and a count of records that
contain information.
25. Number of Physical Records (Blocks).
Enter the number of physical records
(blocks). Labels are not included in this
count.
26. Comments. Provide additional
information as necessary or desired. If
the information pertains to another item
on the form, identify the relevant item
number. Files transferred to the
National Archives should not be
software-dependent in accordance with
36 CFR. If there are any exceptions to
this, identify the release and/or level of
any software required to read the file.
Provide attachments if the information
required will not fit in Item 26.
27. Form Prepared By. Enter the name
and phone number (including area code)
of the individual who prepared this
form.
28. Date Form Completed (YY/MM/DD).
Enter date this form was prepared
NA Form 14097 Back MSW(Rev. 8/92)
Records Management for OPM Internal Administrative
67
Information System Description Form
1. SYSTEM TITLE
2. SYSTEM CONTROL NUMBER
3. AGENCY PROGRAM SUPPORTED BY SYSTEM
4. PROGRAM AUTHORITY
5. SYSTEM DESCRIPTION
5A. PURPOSE/FUNCTION OF SYSTEM
5B. SOURCE(S) OF DATA (Include inputs from other systems)
5C. INFORMATION CONTENT
5D. SYSTEM OUTPUTS (Include outputs from other systems)
6. NAME AND ADDRESS OF PRINCIPAL PROGRAM OFFICE SUPPORTED BY THE SYSTEM
(Include room numbers)
7. AGENCY CONTACTS (Names, addresses and phone numbers of system and program personnel who
can provide additional information about the system and the program it supports.)
8. PREVIOUS DISPOSITION JOBS
9A. PREPARER’S NAME
9B. OFFICE NAME AND ADDRESS
9C. PHONE NUMBER
SIGNATURE
DATE
Figure 8. NA Form 14028
65
The following are instructions for completing the Information System Description Form
(NA Form 14028 (-88)).
65
See DFR, Chapter III.
Records Management for OPM Internal Administrative
68
1. The commonly used name and acronym of the system [e.g., Budget System, Grain
Monitoring System]
2. The internal control number assigned to the system for reference, control, or
cataloging purposes [e.g., Information System Inventory Number, ADP Plan
control number]
3. What agency programs or missions does the system support?
4. What laws, directives, etc., authorize these programs?
5. Description has the following sections:
a. Purpose/Function: The reasons for and the requirements met by the system.
b. Sources of Data: The primary sources or providers of data to the system [e.g.,
broadcast license holders, corporations doing business in the U.S.]. Does this
system receive information from other systems, from either within or outside
your agency?
c. Information content: The principal subject matter, data coverage, time span,
geographic coverage, update cycle, whether the system saves superseded
information, major characteristics of the system, and whether the system
contains microdata or summary data.
d. Outputs: The principal products of the system [e.g., reports, tables, charts,
graphic displays, catalogs, correspondence], and an indication of the
frequency of preparation. Is information from this system transferred to other
systems?
6. Self-explanatory.
7. Self-explanatory.
8. Citations of previous NARA disposition jobs approving disposition of
components [e.g., input forms. printouts, COM, output reports] of the system.
9. Self-explanatory.
Records Management for OPM Internal Administrative
69
6.14 Disposing of Temporary Records
Federal regulations state (at 36 CFR 1228.58(b) that temporary records to be destroyed
are usually sold as wastepaper. In many areas, the GSA has negotiated standard regional
contracts for the sale of waste paper. In these cases, call your GSA representative to
make arrangements for the sale of waste paper. Where no such contract is in effect, or
where the records are too far from the GSA office having the contract, GSA can assist in
negotiating such a contract.
Defense-classified records may be sold as waste paper only if adequate safeguards are
taken to prevent any disclosure of the information in the records before their pulping,
shredding, or other destruction. This mutilation must occur before the sale, unless the
records remain under the observation of an authorized Federal official or employee until
their mutilation. Records bearing "secret" or higher classification must be burned,
shredded, pulped, or macerated so that the record content cannot be restored. Contact the
OPM Records Officer for additional guidelines on the handling of defense-classified
records.
Administratively confidential records, including Privacy Act records, must be pulped or
macerated by the contractor under the witnessing supervision of a Federal employee.
Contractor employees authorized by OPM may also be employed to witness the
destruction of records. At Headquarters, administratively confidential records are placed
in special "burn bags”, which are available from GSA Advantage. When they are ready
to be removed, contact the Facilities Management office in Facilities, Security &
Contracting for their removal. For the destruction of both restricted and unrestricted
temporary records, see
36 CFR 1228.58, Destruction of temporary records.
You must dispose of temporary records in accordance with the instructions below.
a. Sale or salvage of unrestricted records:
(1) Paper records. Paper records to be destroyed normally must be sold as
wastepaper or otherwise salvaged. All sales must follow the established
procedures for the sale of surplus personal property.
66
The contract for sale
must prohibit the resale of all records for use as records or documents.
(2) Records on electronic and other media. Records other than paper records
(audio, visual, and electronic records on physical media data tapes, disks, and
diskettes) may be salvaged and sold in the same manner and under the same
conditions as paper records.
b. Destruction of unrestricted records: According to 36 CFR 1228.58
,
unrestricted records that OPM cannot sell or otherwise salvage must be destroyed
by burning, pulping, shredding, macerating, or other suitable means.
66
See 41 CFR 102-38, Sale of Personal Property.
Records Management for OPM Internal Administrative
70
c. Destruction of classified or otherwise restricted records: The following
requirements apply to records that are restricted because they are national security
classified or exempted from disclosure by statute, including the Privacy Act, or
regulation:
(1) Paper records. For paper records, OPM or its wastepaper contractor must
definitively destroy the information contained in the records by one of the
means specified in paragraph (b) above and their destruction must be
witnessed either by a Federal employee or, if authorized by OPM, by a
contractor employee.
(2) Electronic records. Electronic records scheduled for destruction must be
destroyed in a manner that ensures protection of any sensitive, proprietary, or
national security information. Magnetic recording media previously used for
electronic records containing sensitive, proprietary, or national security
information must not be reused if the previously recorded information can be
compromised in any way by reuse of the media.
You must obtain written approval from NARA before donating temporary records
eligible for disposal to an appropriate person, organization, institution, corporation, or
government (including a foreign government) that has requested them. Records that are
not eligible for disposal cannot be donated. See 36 CFR 1228.60 for details.
See also:
36 CFR 1228 Subpart A, Records Disposition Programs
36 CFR 1228 Subpart D, Implementing Schedules
6.15 Disposition of Personal Papers and Extra Copies of Federal Records
Removal or destruction of Federal records may only occur with the authorization of
NARA-approved records schedules or general records schedules. Criminal penalties
may be imposed for the unlawful removal or destruction of Federal records. In addition,
employees have a legal responsibility to inform responsible officials of any actual or
threatened unlawful loss or removal of official records. See NARA’s publication
Documenting Your Public Service.
Federal officials must be aware of the requirement for identifying and maintaining
personal papers separately from official records. The following section provides
guidelines for carrying out this requirement.
6.15.1 Official and Personal Records Defined
Official records are materials made or received either under Federal law or in connection
with the transaction of public business. Federal records are legally defined in 44 U.S.C.
3301 to include:
Records Management for OPM Internal Administrative
71
all books, papers, maps, photographs, machine readable materials, or other
documentary materials, regardless of physical form or characteristics, made or
received by an agency of the United States Government under Federal law or
in connection with the transaction of public business and preserved or
appropriate for preservation by that agency or its legitimate successor as
evidence of the organization, functions, policies, decisions, procedures,
operations, or other activities of the Government or because of the
informational value of data in them. Library and museum material made or
acquired and preserved solely for reference or exhibition purposes, extra
copies of documents preserved only for convenience of reference, and stocks
of publications and of processed documents are not included.
A legal definition of personal papers, and standards for their maintenance, are given at 36
CFR 1222.36:
Personal papers are documentary materials, or any reasonably segregable
portion thereof, of a private or nonpublic character that do not relate to or
have an effect upon the conduct of agency business. P ersonal papers are
excluded from the definition of Federal records and are not owned by the
Government. Examples of personal papers include: ( 1) materials
accumulated by an official before joining Government service; (2) materials
relating solely to an individual's private affairs, such as outside business
pursuits, professional affiliations, or private political associations; and, (3)
diaries, journals, personal correspondence, or other personal notes that are not
prepared or received in the process of transacting official business.
Employees who leave OPM may take their personal papers with them. However, they
must take care not to remove any official records from the office. Personal papers must
be kept separate from official records. If information about private matters and agency
business appears in the same document, the document must be copied at the time of
receipt, with the personal information deleted, and treated as an official record.
6.15.2 Extra Copies of Official Records
The legal definition of records specifically excludes "extra copies of documents
preserved only for convenience of reference." These extra copies are nonrecord material,
which may be destroyed without NARA approval.
Although these materials cannot be considered personal papers, a Government official
may accumulate for convenience of reference extra copies of papers and other materials,
which he or she has drafted, reviewed, or otherwise acted upon. When deposited in a
research institution, extra copies can serve the needs of historical scholarship.
Government officials may be permitted to retain these extra copies, provided that the
retention would not: (1) diminish the official records of the agency; (2) violate
confidentiality required by national security, privacy, or other interests protected by law;
or (3) exceed normal administrative economies. See 36 CFR 1222.34(f)(2).
Records Management for OPM Internal Administrative
72
6.15.3 Penalties for the Unlawful Removal of Records
Federal Agencies are required to notify agency officials that: (1) the alienation and
destruction of records in agency custody is governed by specific provisions of Title 44
U.S.C., Chapter 33, and (2) criminal penalties are provided for the unlawful removal or
destruction of Federal records (18 U.S.C. 2071) and for the unlawful disclosure of certain
information pertaining to the national security (18 U.S.C. 793, 794, and 798).
Heads of Federal Agencies are required to notify the Archivist of the United States of any
actual or threatened unlawful removal or destruction of records in their custody. The
Archivist is responsible for assisting agency heads in initiating action through the
Attorney General for the recovery of records unlawfully removed. See 36 CFR
1228.104, Reporting.
7. ELECTRONIC RECORDS
7.1 Definition of Electronic Records
An electronic record is any information that is recorded in a form that only a computer
can process and that satisfies the definition of a Federal record (see 44 U.S.C. 3301;
67
Section 4, Records Creation and Receipt; and Appendix B, Glossary).
Electronic records may include data files and databases, machine-readable indices, word
processing files, electronic spreadsheets, web records, records generated from VOIP,
iPad, and other state of the art electronic systems, electronic mail and electronic
messages, as well as other text or numeric information requiring the use of a computer or
other electronic device to create, retrieve, analyze, transmit, or delete records.
Electronic records also may include records derived from Internet Web sites and Web 2.0
applications such as blogs, wikis, Web portals, mashups (e.g., Google Maps; see
Glossary), microblogs (e.g., Twitter), and videoblogs (e.g., YouTube).
68
7.2 Electronic Records Management Controls
OPM is required to manage its electronic records in accordance with 36 CFR 1234,
Electronic Records Management. The following types of records management controls
are needed to ensure that Federal records in electronic information systems provide
adequate and proper documentation of agency business for as long as the information is
needed. These controls must be incorporated into the electronic information system or
integrated into a recordkeeping system that is external to the information system itself.
These controls are:
67
Also see 36 CFR 1234.2, Definitions.
68
See Implications Of Recent Web Technologies For NARA Web Guidance for a discussion of these and
other web technologies. See also 44 U.S.C. 3501(207)(e).
Records Management for OPM Internal Administrative
73
· Reliability: Controls to ensure a full and accurate representation of the transactions,
activities, or facts to which they attest and can be depended on in the course of
subsequent transactions or activities.
· Authenticity: Controls to protect against unauthorized addition, deletion, alteration,
use, and concealment.
· Integrity: Controls, such as audit trails, to ensure that records are complete and
unaltered.
· Usability: Mechanisms to ensure that records can be located, retrieved, presented,
and interpreted.
· Content: Mechanisms to preserve the information contained within the record itself
that was produced by the creator of the record.
· Context: Mechanisms to implement cross-references to related records that show the
organizational, functional, and operational circumstances about the record, which
will vary depending on the business, legal, and regulatory requirements of the
business activity.
· Structure: Controls to ensure the maintenance of the physical and logical format of
the records and the relationships between the data elements.
The records management controls must be planned and implemented in the system as part
of the capital planning and systems development life cycle processes.
All records in the system must be retrievable and usable for as long as the NARA-
approved retention period dictates. If the records will need to be retained beyond the
planned life of the system in which the records are originally created or captured, the
migration of records and their associated metadata to new storage media or formats must
be planned and budgeted, in order to avoid loss due to media decay or technological
obsolescence. See 36 CFR 1234.30 for more information.
A standard interchange format (e.g., ASCII or XML) must be provided when needed to
permit the exchange of electronic documents between offices using different software or
operating systems.
7.3 Electronic Recordkeeping Systems
Recordkeeping systems, whether electronic or paper-based, must be cost effective, easy
to use, provide the required information when needed, and retain the records for the
required length of time. Electronic records stored outside an approved electronic
recordkeeping system are more vulnerable to undetected alteration or loss of information
than are paper record systems. Every time an electronic word processing document,
spreadsheet, or database is opened, the record can be altered, assuming that the user
Records Management for OPM Internal Administrative
74
possesses the proper password and rights. Even those without passwords and rights can
gain access to electronic records by exploiting security weaknesses.
Electronic Recordkeeping systems remove these vulnerabilities. Careful management of
procedures and equipment for electronic records is required to ensure the continuing
accuracy and availability of the information.
Recordkeeping functionality may be built into the electronic information system or
records can be transferred to an electronic recordkeeping repository, such as a DoD-
5015.2 STD-certified product. The following functionalities are necessary for electronic
recordkeeping:
· Declare records. Assign unique identifiers to records.
· Capture records. Import records from other sources, manually enter records into
the system, or link records to other systems.
· Organize records. Associate records with an approved records schedule and
disposition instruction.
· Maintain records security. Prevent the unauthorized access, modification, or
deletion of declared records, and ensure that appropriate audit trails are in place to
track use of the records.
· Manage access and retrieval. Establish the appropriate rights for users to access
the records and facilitate the search and retrieval of records.
· Preserve records. Ensure that all records in the system are retrievable and usable
for as long as needed to conduct agency business and to meet NARA-approved
dispositions.
· Carry out disposition. Identify and transfer permanent records to NARA based on
approved records schedules. Identify and delete temporary records that are
eligible for disposal. Halt the disposition of records through the application of
records holds or freezes when required.
· Ensure that backup systems are in place. System and file backup processes and
media do not provide the appropriate recordkeeping functionalities and must not
be used as the agency electronic recordkeeping system.
7.4 Electronic Mail Records
69
Perhaps the most ubiquitous form of electronic record is electronic mail, or email.
Because email messages are so easy to send and receive, they are difficult to manage.
69
See 36 CFR 1234.24, Standards for managing electronic mail.
Records Management for OPM Internal Administrative
75
Unless strict email recordkeeping procedures are established, it quickly becomes very
difficult to integrate email records into recordkeeping systems.
70
The most important fact about email is that each email message may be a record.
Like other electronic records, the best way to determine whether an individual email is a
record is to decide whether it fulfills the definition of a record in 44 U.S.C. 3301.
71
Another way is to ask yourself the following questions:
· Is an email that you sent or received related to your duties as an OPM employee or
contractor?
· Does an email that you received call on you to take an action or make a decision on
behalf of OPM?
· Does an email that you sent explain, justify, or document an action or decision
relating to your duties or the duties of another employee or contractor at OPM?
If you answered “yes” to any of these questions, the email is a record. If you answered
“no” to them all, the email is not a record.
7.4.1 Email Records Management Systems
At present OPM has no automated system for managing email as records. NARA
encourages agencies to implement an email records management system.
72
Such systems must have the capacity to:
· Group email records into classifications that reflect the agency’s business
functions.
· Schedule and provide for the disposition of email records.
· Ensure ease of access to email records.
· Retain email records and their transmission and receipt data for the entirety of the
appropriate retention periods.
· Permit the transfer of permanent email records to NARA.
73
Email applications such as Outlook, may only be used as an email “records management
system” for emails with very short retention periods of 180 days or less. These would be
classified as transitory records (see Glossary entry). Since most of OPM’s email records
70
See 36 CFR 1234.24(a)(4) and (b).
71
See 36 CFR 1234.2, Definitions, 1234.10, Agency responsibilities, and 1234.24, Standards for managing
electronic mail records.
72
See 36 CFR 1234.24(b)(3)(i).
73
See 36 CFR 1228.270, Electronic records.
Records Management for OPM Internal Administrative
76
do not fit in this transitory category, OPM personnel and contracts must print out, file the
email, its attachment, and transmission, and receipt data.
74
7.4.2 Email Records Management FAQs
75
a. Emails as Records
When are email messages records?
Treat email messages the same way you treat paper correspondence. An email
message is a record if it documents the OPM mission, provides evidence of an
OPM business transaction, or matches the definition of a record found at 44
U.S.C. 3301.
Do I have to manage incoming and outgoing email as records?
Yes, you need to manage both incoming and outgoing email. The reason is that
both sender and recipient of email messages are responsible for documenting their
activities and those of their organizations.
Is it appropriate to conduct OPM business using email?
You should use email to conduct OPM business only when you are reasonably
sure that the message will not be altered after transmission. Consider the nature
and sensitivity of the message, the technology involved, and the people with
whom you are communicating when you decide to use email for business. And
you must be mindful to handle all Personally Identifiable Information,
appropriately.
Can I use a non-OPM account to send or receive OPM email?
No, you cannot not use any outside email system to conduct official agency
business.
76
Are instant messages (IM) records?
Yes, in certain circumstances. If the messages substantiate your work, you must
treat them the same way you would any email record. You need to capture the
text of the message, as well as who the message is to or from, and the date and
time. Also, due to the informal and sometimes cryptic nature of IM, it may be
necessary to transcribe or capture the message in another format much as you
would for a telephone conversation or other verbal communication if it is needed
74
See 36 CFR 1234.24(b)(2), 1234.24(b)(3)(ii), and 1234.24(c).
75
These FAQs are based on the Environmental Protection Agency’s Frequent Questions About Email And
Records.
76
See 36 CFR 1234.24(a)(4).
Records Management for OPM Internal Administrative
77
to document your activities. Finally, it is important to be careful if you use a non-
OPM IM product to communicate with external users, as doing so could result in
unauthorized disclosure of information.
77
If an email record is sent to several recipients, which copy is the official record?
If you take any official action related to a message, and if the message is needed
for adequate and complete documentation of the action, the message is a record in
your office, regardless of whether copies are retained elsewhere. If the record is
already in your office's official files, then your copy is not a record and you may
delete it. If you receive a message only for information and do not take action
related to it, your copy is not a record and may be deleted when you no longer
need it.
Do these email guidelines apply to OPM contractors?
Yes, these guidelines apply to OPM contractors as well as OPM employees.
b. Saving Complete Email Messages
Are there special requirements for retaining email messages as records?
The basic requirements that apply to all records apply to email records as well.
However, there are some specific requirements for records made or received
through email. You must make sure that:
1. The email record includes transmission data that identifies the sender
and the recipients and the date and time the message was sent or
received;
2. When an email is sent to a distribution list, information identifying all
parties on the list is retained for as long as the message is retained; and
3. If the email system uses codes or aliases to identify senders or
recipients, a record of their real names is kept for as long as any record
containing only the codes or aliases. For example, if you are
communicating with someone via the Internet (e.g., a grantee or
researcher), and their email address does not indicate who he or she is
(e.g., the address is JerryR@...), then a record must be kept of who they
are.
Must I keep attachments to an email message? Are they records as well?
Yes, email attachments are considered records and must be kept. If a message
qualifies as part of the documentation of your activities, you must ensure that
77
See also: NARA's Frequently Asked Questions About Instant Messaging.
Records Management for OPM Internal Administrative
78
related items that provide context for the message are maintained as well. This
includes attachments. You must keep them under the same conditions you would
if they were paper attachments to a paper memo or incoming letter.
If my outgoing message is a record, should I ask for a return receipt to make sure
the intended recipient received it?
It is not necessary to ask for a return receipt or read receipt in email any more
than it is necessary in hard copy. We don't send all letters by certified mail. If it
is important to document the time that a message was opened, then treat your
email as if it were certified mail and request the recipient to use the read receipt
feature.
Do I need to retain both the original message and the reply?
Yes. The simplest way to ensure comprehension of email messages is to
incorporate the original message in any reply and maintain them as a unit. If
emails are sent back and forth and the most recent message has the entire
sequence of messages, you need to keep the original email with attachment and
then the final comprehensive message – which includes the previous messages
and replies, and transmission and receipt data such as the sender, recipients, date,
and time that are necessary for a complete record.
c. Keeping Email Messages
How long do I need to keep email records?
Keep email records in accordance with your office's file plan and the OPM
records schedules.
What if the message does not qualify as a record?
Delete emails that are not records when they are no longer of use.
Where do I keep Email records?
Because OPM does not have an email electronic records management system,
emails must be printed out and filed in accordance with the schedule associated
with the record.
Records Management for OPM Internal Administrative
79
Consequently, OPM offices must establish a print-and-file system for email
records.
78
You may maintain very short-term email records in OPM’s email
system. These short-term records must have a retention period of less than 180
days.
79
Can email records be kept on backup tapes or disks?
No. Backups created to facilitate restoration of a system or file in case of
accidental or unintentional loss are generally ill suited for recordkeeping
purposes.
80
Do I need to retain both an electronic and hard copy of the same email message?
OPM does not have an electronic recordkeeping system for email. Therefore, the
email must be printed and kept as a record in accordance with the appropriation
disposition schedule. If it is a transitory record, then you may delete the email
after 180 days.
For guidance on transferring permanent email records to NARA, see NARA’s Expanding
Acceptable Transfer Requirements: Transfer Instructions for Existing Email Messages
with Attachments.
7.4.3 Multiple E-Mail Accounts and Personal E-Mail accounts
Having multiple E-Mail accounts and the use of personal e-mail accounts to conduct
agency business are not authorized at OPM.
7.5 Maintaining Electronic Information Systems
An Electronic Information System is an automated system that contains and provides
access to Federal records and other information. This information may be administrative
or programmatic and whose functions include collecting, storing, assembling, processing,
transmitting, and disseminating information electronically according to defined
procedures.
81
The Records Officer, together with the Records Coordinators, must conduct annual
inventories of OPM’s electronic information systems and review the systems for
conformance to established agency procedures, standards, and policies as part of the
periodic reviews required by 44 U.S.C. 3506. The review must determine if the records
have been properly identified and described, and if the schedule descriptions and
80
See 36 CFR 1234.24(c). Email may be stored in electronic off-line storage that meets the requirements
of 36 CFR 1234.30(a).
80
See 36 CFR 1234.24(c). Email may be stored in electronic off-line storage that meets the requirements
of 36 CFR 1234.30(a).
80
See 36 CFR 1234.24(c). Email may be stored in electronic off-line storage that meets the requirements
of 36 CFR 1234.30(a).
81
See NARA Bulletins 2006-02 and 2008-03.
Records Management for OPM Internal Administrative
80
retention periods reflect the current informational content and use. If the annual
inventory reveals substantial discrepancies in record identification, description, or
retention periods, Records Coordinators must submit an SF 115, Request for Records
Disposition Authority, to the Records Officer.
For more information, see NARA Bulletin 2010-02, Continuing Agency Responsibilities
for Managing Electronic Records, particularly Attachment 1, Techniques for Scheduling
agency Electronic Records Systems.
82
7.6 Storing and Testing Permanent Electronic Records
You must maintain the storage and test areas for electronic records storage media
containing permanent and unscheduled records in compliance with 36 CFR 1234.30 and
36 CFR 1228.270.
7.7 Disposition of Electronic Records
OPM's policy on the disposition of electronic records is as follows:
If an electronic record is converted to paper and the paper record is used to indicate
concurrences and final signature, then this is considered the official record copy of
that particular action. You must maintain, destroy, or archive the paper record in
accordance with OPM's approved disposition schedule for that particular record series.
You may delete the information on the electronic medium when it is no longer needed to
create hard copies.
If an electronic record is not converted to paper, then the electronic record becomes
the record copy. You must maintain the electronic record for the same period of time as
if it were hard copy. If the electronic record is a temporary record, it must be destroyed
after it has reached the end of its retention period.
83
You must transfer permanent
electronic records to NARA in accordance with 36 CFR 1234.22(a)(4) and
36 CFR
1228.270(b), and retain a copy of the records until you receive official notification that
NARA has assumed responsibility for continuing preservation of the records.
84
7.7.1 Decommissioning Legacy Systems
7.8 Using Electronic Media to Transfer Records to the National Archives
You must use only media that are sound and free from defects for transfers to the
National Archives of the United States. When permanent electronic records may be
disseminated through multiple electronic media (e.g., magnetic tape, CD-ROM) or
mechanisms (e.g., File Transfer Protocol (FTP)), OPM and NARA must agree on the
82
See also NARA’s Tips For Scheduling Electronic Databases.
83
See 36 CFR 1234.34 Destruction of Electronic Records.
84
See also General Records Schedule 20 Electronic Records and NARA’s Electronic Records Management
(ERM) Guidance On The Web.
Records Management for OPM Internal Administrative
81
most appropriate medium or method for transfer of the records to the National
Archives.
85
7.9 Use of Compact Disk-Read Only memory (CD-ROM) and Optical Disk
Systems to Store and Transfer Federal Records
The following contains NARA’s policies on the use of CD-ROM and optical disk
technology to transfer electronic records to the National Archives. They apply only to
those CD-ROM's that contain the record copies of documents that have been scheduled
for transfer to and preservation in the National Archives in accordance with a NARA-
approved records schedule. They do not apply to the use of CD-ROM for electronic
publishing, in which the CD-ROM is used instead of paper for document publishing.
OPM organizations must contact OPM's Records Officer (Office of the Chief Information
Officer) whenever they plan to use CD-ROM or optical disk systems to store or transfer
records
7.9.1 CD-ROM Policy
NARA accepts electronic records for transfer to the National Archives using CD-ROM
provided they are:
· In conformance with the International Standards Organization (ISO) 9660 standard;
· In compliance with the American Standard Code for Information Interchange
(ASCII) standard as defined in the Federal Information Processing Standard 1-2
(11/14/-84);
o Not dependent on control characters or codes that are not defined in the
ASCII character set;
· Not compressed unless the software to decompress the files is provided;
· Individually addressable; and
· In compliance with the documentation requirements of 36 CFR 1228.270(c)(2).
In some cases, permanently valuable electronic records exist on CD-ROM and also on
other media such as magnetic tape. In these cases, OPM and NARA will mutually agree
on the most appropriate medium for transferring the records to the National Archives.
OPM will transfer the necessary documentation for the files contained on the CD-ROM's
that are being accessioned into the Center for Electronic Records.
NARA assumes responsibility for the preservation of CD-ROM files that meet the above
criteria. When requested, NARA will provide access to any electronic records preserved
in the National Archives and will replicate them on any medium offered by NARA for
85
See 36 CFR 1228.270(b-e), Electronic Records, and 36 CFR, 1234 Electronic Records Management, for
more information.
Records Management for OPM Internal Administrative
82
copies of accessioned electronic records, subject to legal restrictions. Legal restrictions
include copyright, licensing, or special distribution arrangements. NARA will provide
copies of any copyrighted software contained on a CD-ROM only when there is an
applicable license or the software has been placed in the public domain.
7.9.2 Optical Disk System Policy
NARA has encouraged Federal Agencies to use optical disk technology to enhance their
information management operations. It recognizes the potential benefits of this
technology for storing and retrieving large quantities of information.
NARA will accept permanent records for transfer to the National Archive on the
following types of optical media:
1. Optical disks that meet the criteria listed in Subsection 7.9.1 CD-ROM Policy;
2. Analog videodiscs that typically contain photographs, provided they do not require
any interactive software or non-standardized equipment. Original photographs
appraised as permanent and copied onto a videodisc must be scheduled for transfer
to the National Archives along with a copy of the videodisc; and
3. Audio compact disks.
7.9.3 OPM Policy
1. Permanent Records
OPM may use CD-ROM and optical disk systems for the storage and retrieval of
permanent records while the records are in OPM's legal custody. After permanent
records are copied onto CD-ROM or an optical disk, if the records are no longer needed
for current business in OPM, the records must be transferred to a Federal records center
or, in the case of records on electronic media, to the National Archives.
2. Temporary Records
Records appraised by NARA as temporary may be stored on any medium, including CD-
ROM and optical disks that ensures maintenance of the information until the retention
period expires. NARA approval is not required to convert such temporary records to CD-
ROM or optical disks and disposal of the original paper or other media.
3. OPM Must Obtain NARA Approval To:
a. Destroy original permanent or unscheduled records after copying onto CD-
ROM or optical disks. Approval for destruction will depend on the usefulness
of the form transferred to NARA by comparing it to the original and the nature
of the media used to transfer the records to NARA.
The transfer of permanent records stored on CD-ROM or optical disks to the
legal custody of the National Archives must be on a medium acceptable to
NARA at the time of transfer. OPM must certify that the CD-ROMs or optical
Records Management for OPM Internal Administrative
83
disks meet the requirements listed in Subsection 7.9.1 above, or that OPM will
convert the images to a medium that meets the standards specified in 36 CFR
Part 1228, Subpart B – Scheduling Records, before transfer to NARA's legal
custody.
b. Transfer permanent records in CD-ROM or optical disk format to the
National Archives. (This requirement does not apply to records that are already
scheduled in electronic format for transfer to the National Archives.)
c. Disposition schedule videodiscs and audio compact disks
7.10 Scanned Records
As part of NARA’s electronic government (e-Gov) initiative, and in cooperation with
other Federal Agencies, NARA issued guidance to supplement requirements in 36 CFR
1228.270, Electronic Records, for transferring permanent electronic records to NARA.
This guidance expands currently acceptable formats to enable the transfer of existing
scanned images of textual records to NARA. The guidance does not apply to "born
digital" images or scanned images of primarily non-textual records (e.g., maps and
photographs).
Scanned images are a priority electronic records format identified by NARA and partner
agencies as part of the Electronic Records Management (ERM) initiative.
86
A major goal
of this initiative is to provide the tools for agencies to access electronic records for as
long as required and to transfer permanent electronic records to NARA for preservation
and future use by the Government and citizens. Scanned images are the second of three
formats examined under this ERM e-Gov initiative; the other priority formats include
email with attachments and electronic records in Adobe's Portable Document Format
(PDF).
Subsections 7.10.1 through 7.10.5 below provide transfer requirements specifically for
existing scanned images that have been appraised or scheduled for permanent retention in
electronic (i.e., scanned) form. These requirements address acceptable scanned image
file formats, image quality specifications, transfer documentation, and related information
on how to transfer these records to NARA. If you have existing permanent scanned
images that do not meet the image quality specifications in this guidance, contact the
OPM Records Officer.
7.10.1 Transferring Scanned Records to NARA
NARA will accept transfers of scanned images that have been scheduled as permanent
records on an SF 115, Request for Records Disposition Authority. To facilitate
86
See NARA’s Electronic Records Management Initiative (ERM). NARA’s partner agencies in the
Initiative are EPA (Enterprise-wide ERM) and the Department of Defense (Electronic Information
Management Standards).
Records Management for OPM Internal Administrative
84
preservation processing and future access to these records, agencies must comply with
the following minimum requirements.
87
Image File Format
NARA will accept scanned images in the following file formats:
Tagged Image File Format (TIFF), in 'II' format, versions 4.0 (April 1987), 5.0
(October 1988), and 6.0 (June 1992).
Graphics Interchange Format (GIF), versions 87a (June 1987), and 89a (July
1990).
Basic Image Interchange Format (BIIF), International Standards Organization
(ISO) Standard 12087-5, Part 5 (December 1998).
Portable Network Graphics (PNG), version 1.0 (October 1996).
NARA will periodically update this set of acceptable formats and versions.
NARA prefers uncompressed images. With prior consultation between NARA
and the transferring agency, NARA may accept compressed images created using
a lossless compression method (e.g., ITU Group 4, LZW) when it is impractical
or technically impossible to transfer uncompressed files (e.g., due to limitations
on bandwidth or storage media capacities). NARA will not accept images created
using lossy compression
88
techniques because the potential information loss that
can result from compression can make such images unsuitable for archival
preservation.
(See NARA’s Frequently Asked Questions (FAQ) About Digital Audio and Video
Records for more information about lossy compression)
7.10.2 Expanding Acceptable Transfer Requirements: Transfer Instructions for
Existing Permanent Electronic Records Scanned Images of Textual Records
A. Acceptable Image Quality Specifications
Scanned images of textual records transferred to NARA must meet minimum
requirements for scanning resolution and pixel (bit) depth to support archival
preservation and continued use. See http://www.archives.gov/records-
mgmt/initiatives/scanned-textual.html for specifics,
B. Transfer Documentation
87
See NARA’s Expanding Acceptable Transfer Requirements: Transfer Instructions For Existing
Permanent Electronic Records Scanned Images Of Textual Records, and Transferring Permanent Electronic
Records To NARA- Answers To The Top 5 Questions (NARA).
88
Lossy compression is a method of reducing the size of a file by discarding data without rendering the
resulting file unusable. Lossless compression accomplishes the same thing without loss of data.
Records Management for OPM Internal Administrative
85
This subsection supplements the transfer documentation requirements in 36 CFR
1228.270(e) to ensure that transfers of scanned images of textual records are clearly
identified and described. Agencies must also submit a signed SF 258, Agreement to
Transfer Records to the National Archives of the United States, as required by 36 CFR
1228.272. See http://www.archives.gov/records-mgmt/initiatives/scanned-textual.html
for specifics.
For inspections conducted after the effective date of this directive, you must use one of
the quality sampling methods presented in the American National Standards Institute
(ANSI)/Association for Information and Image Management (AIIM) standard, Sampling
Procedures for Inspection by Attributes of Images in Electronic Image Management and
Micrographic Systems (ANSI/AIIM TR34-1996).
7.10.4 Transfer Mechanisms
89
You must transfer scanned images to NARA as uncompressed files and un-aggregated
files. In addition to the approved transfer media listed in 36 CFR 1228.270(c), you may
transfer records on Digital Linear Tape (DLT) Type IV or through File Transfer Protocol
(FTP).90 See http://www.archives.gov/records-mgmt/initiatives/scanned-textual.html for
specifics.
7.10.5 Portable Document Format (PDF)
PDF is a file format that is used for representing two-dimensional documents in a manner
independent of the application software, hardware, and operating system. Each PDF file
comprises a complete description of a fixed-layout two-dimensional document that
includes the text, fonts, images, and graphics that compose the documents. Lately, three-
dimensional drawings can be embedded to PDF documents with Acrobat 3D using U3D
or PRC and various other data formats.
Using these advanced versions of PDF has presented problems for the long-term and
permanent storage of scanned images. Some functionalities and features recently added
to the PDF format are proprietary and support for them cannot be guaranteed over the
long term. Therefore, NARA has adopted PDF/A-1, or archival PDF, as the preferred
version for images scanned in PDF format.
91
7.10.6 Levels of Access
NARA will provide access to the creating agency and to all researchers requesting
scanned images accessioned from Federal Agencies, subject to review of content for
FOIA exemptions as is feasible. While compliance with these requirements will improve
future access to accessioned scanned images, NARA's ability to provide access to certain
89
See Transfer Of Electronic Records (NARA) and 36 CFR 1228.270, Electronic Records.
90
See 36 CFR 270(c)(3) File Transfer Protocol for details.
91
See NARA’s Frequently Asked Questions (FAQs) About Transferring Permanent Records In PDF/A-1
To NARA. It is important to recognize that NARA has indicated that PDF/A-1 is the preferred version of
PDF, not the preferred imaging format.
Records Management for OPM Internal Administrative
86
records will vary according to their hardware and software dependencies. At present,
NARA provides users with a copy of fully releasable electronic record files on any of the
media currently approved by NARA. For scanned images transferred to NARA, the user
is responsible for obtaining the necessary hardware and software to view the records. See
http://www.archives.gov/records-mgmt/initiatives/scanned-textual.html for specifics,
Records Management for OPM Internal Administrative
87
7.10.7 Contact Information
For assistance in scheduling scanned images, or to discuss how to handle permanent
scanned images that do not meet the specifications in 36 CFR 1228.270(c)(3), contact the
OPM Records Officer in the Office of the Chief Information Officer, who will then
contact the agency appraisal archivist in the Life Cycle Management Division of the
National Archives in writing prior to the transfer of scanned images. This can be done by
sending the Life Cycle Management Division a copy of the SF 135 submitted for FRC
approval before transferring the unscheduled records to the FRC. Be sure to include on
the SF 135 the date you notified the Life Cycle Management Division, or include the
number of a pending SF 115, Request for Disposition Authority. The Life Cycle
Management Division’s address is 8601 Adelphi Road, Room 2200, College Park, MD
20740.
7.11 Managing Web Records
92
Web site operations are an integral part of OPM’s programmatic, outreach, and
communications activities. The creation of Web sites and their maintenance result in the
creation of Web-based records. Most of these records are electronic, but there may be a
few paper records as well. Managing OPM’s Web records properly is essential to
effective Web site operations, especially the mitigation of the risks any agency, including
OPM, faces by using the Web to carry out its business. It is the policy of OPM that using
the World Wide Web is strongly encouraged in that it provides employees, the general
public and stakeholders with a powerful tool to promote transparency, convey
information quickly and efficiently on a broad range of topics relating to its mission,
activities, objectives, policies and programs. The policy applies to all OPM World Wide
Web and other internet content created/maintained by employees, contractors, and/or
their assigns. OPM has identified 13 policy positions to implement best practices with
regard to establishment, maintenance and administration of its social media. The entire
web policy can be accessed on the intranet.
Communications & Public Liaison (CPL) will serve as the website owner and final
authority on all content.
Program offices are responsible for assuring all content proposed for posting comply
with this policy and all other related public publishing policies. They will also establish a
process to identify information that is appropriate for posting to websites and ensure it is
consistently applied. Program offices will:
· Ensure all information placed on publicly accessible websites is properly
reviewed for security, levels of sensitivity and other concerns before it is released.
· Ensure approved OPM security and privacy notices and applicable disclaimers are
used on all websites under their purview.
92
See NARA Guidance On Managing Web Records.
Records Management for OPM Internal Administrative
88
· Ensure all information placed on publicly accessible websites is appropriate for
worldwide dissemination and does not place national security, OPM personnel
and assets, mission effectiveness, or the privacy of individuals at an unacceptable
level of risk.
· Ensure procedures are established for management oversight and regular
functional review of the website.
· Ensure operational integrity and security of the computer and network supporting
the website is maintained.
· Ensure that reasonable efforts are made to verify the accuracy, consistency,
appropriateness, and timeliness of all information placed on the website.
· Provide the necessary resources to adequately support website operations to
include funding, equipping, staffing and training.
· Provide a mechanism for feedback reporting within the program offices, to
include "Lessons Learned" suitable for all OPM program offices.
The Chief Information Officer (CIO) and Communications & Public Liaison (CPL)
will monitor website compliance with these policies as part of their oversight of agency
web information resource management and may remove content that does not comply
with this policy and current agency operating procedures and guidelines. The CIO and
offices within the CIO’s charge will:
· Provide policy and procedural guidance with respect to establishing, operating
and maintaining websites.
· Maintain liaison with the CPL to provide policy oversight and guidance to ensure
the effective dissemination of personnel information via the Internet.
· Provide technical support consistent with existing CIO responsibilities.
· Develop and maintain training guidance and requirements that address
information security on the Web.
· Approve and publish instructions and publications, as necessary, to guide, direct,
or help website activities, consistent with this policy.
· Provide a mechanism for feedback reporting across OPM, to include "Lessons
Learned" and the identification of useful automated tools to aid in the conduct of
multi-disciplinary security assessments of websites.
· Promote compliance with this policy.
Records Management for OPM Internal Administrative
89
· Establish information management procedures consist with the Federal Records
Act as amended, 44 USC and 36 CFR, the Privacy Act (PA), the Paperwork
Reduction Act (PRA) and other applicable guidance.
Office of General Counsel will provide legal guidance regarding the interpretation of
OMB policy and the rules of law applicable to records management, as necessary..
NARA Guidance on Managing Web Records is intended to assist Records Officers and
other staff with Web records management duties, as well as webmasters, IT staff, and
others with a role in Web site management.
The Guidance contains valuable information on the following:
· How agencies are currently using the Web
· Who has Web-records responsibilities
· Statutory and regulatory requirements applicable to agency Web records
management
· What Federal Web site-related records are, and how they are managed,
· How to determine what Federal Web site-related records are “trustworthy.”
· Risk assessment
· Risk mitigation
· Web site-related records scheduling
7.12 Social Media and Records Management
Social media applications (i.e., blogs, wikis, game developedia, Facebook, and
YouTube), are relatively recent tools developed since the advent of the Internet. These
applications have made possible a dynamic and democratic proliferation of data and
information not previously possible. The rise in use of these tools by Federal Agencies
poses a challenge to records management. Materials posted on third party sites and
agency blogs may also constitute Federal Records. . NARA has issued guidance on
creating Web 2.0 policy.
Federal Agencies are already required by 44 U.S.C. Chapters 31 and 35, Office of
Management and Budget (OMB) Circular A-130 and NARA regulations in 36 CFR
Chapter XII, Subchapter B to have an effective and comprehensive records management
program for all of their records. To the extent that these new Social Media applications
produce Federal records, these statutes, regulations and guidance will apply to them as
well.
OPM’s Records Management Division will ensure that there are updates to legacy
records schedules and that unscheduled electronic records, including Web 2.0
applications, are properly scheduled. OPM Records Management seeks to build records
management services into software applications and adopt electronic recordkeeping,
Records Management for OPM Internal Administrative
90
electronic content management, and electronic archiving practices to address social
networking services. OPM’s Records Management Division advocates appointing
knowledge counsels as points of contact in each headquarters or regional component and
to function as a resident expert and repository of information on the IT and recordkeeping
practices of the agency.
To aid OPM staff and contractors in managing records derived from Social Media
applications, this Directive relies on NARA guidance.
93
Specifically, we refer OPM staff
and contractors with records management duties to NARA’s publication titled
Implications of Recent Web Technologies for NARA Web Guidance.
This publication contains information and guidance about:
· Web Portals (i.e., OPM’s THEO)
· Really Simple Syndication (RSS) Feeds
· Web Logs, or Blogs, and
· Wikis
These four technologies are described and compared on the following bases:
· Interactive aspects
· Collaboration
· Aggregation
· Incremental content, and
· Content replication.
Other items of interest discussed in the guidance are:
· Some Example Questions for Content Managers,
· Responsibilities,
· Risk Assessment,
· Scheduling, and
· Transfer Instructions.
There is also a helpful Glossary at the end of the guidance.
93
See Implications Of Recent Web Technologies For NARA Web Guidance.
Records Management for OPM Internal Administrative
91
All Federal agencies, OPM included, must continue to manage content created with these
and other applications in compliance with NARA's records management guidance,
including its Web management and transfer policies.
7.13 Cloud Computing
Records Management for OPM Internal Administrative
92
FOIA, E-DISCOVERY, AND LITIGATION FREEZES AND HOLDS
8.1 Records Management and the Freedom of Information Act (FOIA)
The Freedom of Information Act (FOIA), 5 U.S.C. 552, gives the public the right to
request access to Federal agency records or information. All Federal agencies, OPM
included, are required to disclose agency records to the public unless the records are
protected by one or more of FOIA's nine exemptions or three exclusions. The nine
exemption categories (see 5 U.S.C. 552(b)) that authorize government agencies to
withhold information are:
1. classified information for national defense or foreign policy;
2. internal personnel rules and practices;
3. information that is exempt under other laws (i.e., personally identifiable
information [PII] as defined in the Privacy Act of 1974);
4. trade secrets and confidential business information;
5. inter-agency or intra-agency memoranda or letters that are protected by legal
privileges;
6. personnel and medical files;
7. law enforcement records or information;
8. information concerning bank supervision; and
9. geological and geophysical information.
8.1.1 Access to Certain Records Without a FOIA Request
OPM makes certain records available without requiring a FOIA request. Such records
include the agency's Annual FOIA Report, which can be found at www.opm.gov/efoia,
and other documents, which can be found in the agency's Electronic Reading Room,
located at www.opm.gov/efoia/html/reading.asp.
OPM's Freedom of Information Act Web page provides access to a list of Freedom of
Information Act (FOIA) Contacts within OPM and a link to the U.S. Department of
Justice FOIA and Privacy Act Web pages.
8.1.2 Time for Response
FOIA requirements (at 5 U.S.C. 552(a)(6)(A)(i)) demand that Federal agencies make a
determination within 20 business days whether to disclose or deny the records requested.
Records Management for OPM Internal Administrative
93
Other processing methods specific to OPM and fees for searching, reviewing, and
copying can be found at OPM’s Freedom of Information Act Reference Guide Web page.
8.2 Records Management and Electronic Discovery
Electronic discovery, or e-discovery, refers to the process of discovery in civil litigation
of records in electronic format, also referred to as electronically stored information, or
ESI. The increased production and persistence of electronic records has prompted
Congress and Federal courts to recognize the need to account for electronic records in
discovery proceedings. This process of recognition resulted in several amendments to the
Federal Rules of Civil Procedure. Chief among them were amendments to Rule
26(b)(2)(B), 26(f), and 37(f):
94
· 26(b)(2)(B) – The party from whom discovery is sought must demonstrate to the
court’s satisfaction that the information requested is not reasonably accessible.
· 26(f) – The requirement that both parties to a civil action meet and confer early in
the pre-trial proceedings to establish ground rules for the scope (online, nearline,
or offline) and format (PDF, TIFF, etc.) of the ESI and how the records will be
accessed or searched.
· 37(f) – The party from whom the discovery is sought will not be penalized for its
failure to produce ESI because it was destroyed as the result of the routine, good-
faith operation of an electronic information system. In other words, if the party
has an established electronic records management system wherein electronic
records are routinely scheduled, destroyed, or transferred to NARA ownership,
the destruction of these records will not result in court sanctions. Rule 37(f)
assumes the records were destroyed not only before a civil action took place, but
before there was reason for the party to believe that such an action was in the
offing.
8.2.1 E-Discovery Responsibilities
Recent case law and best practices dictate that OPM recognize that it has a continuing
responsibility to monitor compliance with electronic records preservation instructions
issued by the Department of Justice or the OPM Office of General Counsel (OGC).
OPM’s response to e-discovery demands must be as quick as possible. To achieve this
rapid response ability, it is the responsibility of the Chief Information Officer, the Chief
of Records Management, the OPM Records Officer, and Headquarters and Field Office
94
The Federal Rules of Civil Procedure can be found at 28 U.S.C. Judiciary and Judicial Procedure –
Appendix.
Records Management for OPM Internal Administrative
94
Records Coordinators to establish an agency-wide ability to initiate electronic records
preservation actions.
95
Both record and non-record documentary materials in paper or electronic format
frequently become the subject of litigation. Employees create and maintain an increasing
portion of business information using computers. This electronically stored information
(ESI) must be managed alongside traditional paper records to ensure compliance with
Federal laws and records management regulations. While not all papers or ESI are agency
records, they may nevertheless be relevant evidence subject to discovery that is
compelled or sanctioned by a court or administrative tribunal in litigation. Unmanaged
and unidentified ESI residing on OPM computers also poses a threat to the Agency's
ability to document and reconstruct business and decision-making processes.
The purpose of this policy is to prescribe Agency-wide enterprise policies and
responsibilities related to the retention of record and non-record documentary materials,
including ESI, for discovery or other litigation-related purposes.
2. REFERENCES
http://theo.opm.gov/policies/AMS44-3%20(converted).pdf (OPM’s Records
Management Handbook (May 2003))
36 CFR 1222.12(b)(1) Definition of “Documentary Materials”
Federal Rules of Civil Procedure:
a. Chapter III, Pleadings and Motions, Rule 16, Pre-Trial Conferences; Scheduling;
Management.
b. Chapter V, Depositions and Discovery, Rule 26(a), General Provisions Governing
Discovery; Duty of Disclosure; Required Disclosures; Methods to Discover Additional
Matter.
3. SCOPE
The retention policy set forth herein applies to all employees and contractors of OPM and
applies to all documentary materials, including record and non-record ESI made, sent, or
received in the transaction of OPM business.
4. DEFINITIONS
Discovery: Discovery is the process of identifying, locating, securing and producing
evidence, including testimony, , information, and materials for utilization in the legal
process. The term is also used to describe the process of reviewing all materials which
may be potentially relevant to the issues at hand and/or which may need to be disclosed
95
See Baron, Jason R. and Daniel MacDonald. E-Discovery & The New Federal Rules Of Civil Procedure:
What Agencies Need To Know, The Rocky Mountain Record Special Edition (NARA: XIV, 2).
Records Management for OPM Internal Administrative
95
to other parties, and of evaluating evidence to prove or disprove facts, theories or
allegations. There are several formalized methods of conducting discovery, the most
common of which are interrogatories, requests for production of documents and
depositions.
Electronic Discovery (e-discovery): The process of collecting, preparing, reviewing, and
producing ESI in the context of the legal process. See Discovery.
Electronic Record: Information recorded in a form that requires a computer or other
machine to process it and that otherwise satisfies the definition of a record.
Electronically Stored Information (“ESI”): Any information that is created, received,
maintained or stored on local workstations, laptops, central servers, personal digital
assistants, cell phones, or in other electronic media. Examples include, but are not limited
to: electronic mail (“email”), calendars, word processing documents and spreadsheets,
databases, videos, video files, digital images, audio files, text messages, voicemails,
activity logs, etc. ESI includes metadata.
Preservation Obligation: The obligation of agencies, managers and individual employees
to ensure the preservation of documentary materials that might be or might become
relevant to pending or threatened litigation. If the documentary material was created in
electronic format, it must be preserved in that original native format.
Litigation Hold: The procedure for locating and ensuring the retention of ESI subject to a
preservation obligation. See Appendix A for litigation hold procedures/guidelines.
Record: All books, papers, maps, photographs, machine-readable materials, or other
documentary materials, regardless of physical form or characteristics, made or received
by an agency of the United States Government under Federal law or in connection with
the transaction of public business and preserved or appropriate for preservation by that
agency or its legitimate successor as evidence of the organization, functions, policies,
decisions, procedures, operations, or other activities of the Government or because of the
informational value of data in them. Library and museum material made or acquired and
preserved solely for reference or exhibition purposes, extra copies of documents
preserved only for convenience of reference and stocks of publications and of processed
documents are not included. (44 U.S.C. 3301)
5. POLICY
The retention period for ESI will be consistent with the National Archives and Records
Administration (“NARA”) general records schedules or OPM-specific records retention
schedules, as well as Agency policies for records management or with Agency policies
for maintaining and retaining data on backup media for purposes such as disaster
recovery.
ESI that constitutes a "record" is subject to OPM's records management policies and to
the records retention schedules that have been established for each Programoffice. Any
ESI containing information that documents the business of the OPM and is, therefore, an
Records Management for OPM Internal Administrative
96
“agency record,” must be moved to an auditable file structure, such as an electronic file
designated as containing a record series, or a paper document file in an auditable paper
series, in accordance with its applicable Records Disposition Schedule. Records not
properly scheduled for disposition may not be destroyed. Records may be destroyed only
in accordance with NARA approved records disposition schedules.
A litigation hold for described documents or ESI overrides any records retention schedule
or any other agency policy that may otherwise call for the transfer, disposal, or
destruction of the relevant documents or ESI until the hold has been removed by the
Office of the General Counsel (“OGC”), Office of Inspector General (“OIG”), or other
authorized authority that ordered the hold. A litigation hold is generally accompanied by
a records search for all responsive information. Records searches initiated pursuant to a
hold must be coordinated with agency officials, including the relevant program officials,
the information technology (“IT”) staff in the Office of the Chief Information Officer
(“OCIO”), and the OPM Records Officer. Each unit head within the affected
organization is responsible for notifying its subordinate activities that a hold exists or has
been removed. See litigation hold guidelines in Appendix A.
Many IT organizations back up email and other ESI for the purpose of restoring
electronic systems in the event of disaster. Any decision concerning retention periods for
electronic backup media should be established based upon consideration of reasonably
anticipated business needs for data recovery in the event of system failure, as well as
upon legal considerations such as the extent the agency or component has otherwise
archived the ESI. However, backup tapes are not ideally suited as a record retention
mechanism because of the difficulty and expense of reconstituting them to readable
format. Thus, agencies are encouraged to seek true archiving solutions for ESI.
Additionally, email archived to the individual workstation should not be considered part
of the institutional backup – but a part of the individual’s filing system. However, such
individually maintained material is potentially discoverable, and therefore may be the
subject of a litigation hold.
6. SANCTIONS
Failure to comply with this policy in preserving documents and ESI can result in
unfavorable discovery orders, sanctions against the Government, disadvantage to the
government's position in litigation or judgment against the Government. It can also result
in monetary or other contempt sanctions against individuals who failed to take
appropriate steps to locate and segregate information subject to litigation hold. In
extreme cases, agency performance based action or disciplinary sanction may be
warranted under 5 U.S.C. 4301, et seq. or 5 U.S.C. 7501, et seq.
Records Management for OPM Internal Administrative
97
7. RESPONSIBILITIES
a. Director, OPM
b. Chief Information Officer (CIO)
c. OPM Records Officer
d. Information Technology (IT) staff
e. Office of the General Counsel (OGC)
f. Office of the Inspector General (OIG)
g. OPM Human Resource Office
h. Department of Justice (DOJ)
i. Key Individuals
a. Office of the Chief Information Officer will:
· Advise on records management issues and develop Agency-wide records
management policies, procedures, guidance, and training.
· Advise on backup media management and retention policies, procedures,
guidance, and training.
· Work with program, OGC and OIG staff to help ensure that paper and electronic
records and other non-record documentary materials, including ESI, are
accessible for e-discovery purposes.
b. Program Office Heads will:
· Advise on backup media management and retention policies, procedures,
guidance, and training.
· Cooperate with OGC, OIG and OCIO in locating and preserving paper and
electronic records as well as non-record ESI subject to a litigation hold.
c. Agency/Staff Office Records Officers will:
· Develop and maintain the mission area, agency, and staff office records
management program in conformance with the Agency's policies and standards.
· Work with program, IT, and OGC staff to help ensure that paper and electronic
records are accessible for e-discovery purposes.
d. OPM Employees will:
· Maintain paper and electronic records and non-record ESI according to prescribed
Agency policy and procedures, including litigation holds.
Records Management for OPM Internal Administrative
98
e. OGC will:
· With regard to litigation holds initiated by OGC, work with program, IT, and
Records Management staff to help ensure that paper and electronic records, as
well as non-record ESI, is accessible for e-discovery purposes.
· Ensure that the OPM Records Officer is notified of all litigation hold requests and
hold removals.
f. OIG will:
· With regard to litigation holds initiated by OIG, work with program, IT, and
Records Management staff to help ensure that paper and electronic records, as
well as non-record ESI, is accessible for e-discovery purposes.
· Ensure that the OPM Records Officer is notified of all litigation hold requests and
hold removals.
Records Management for OPM Internal Administrative
99
Appendix A
DOCUMENTARY MATERIAL HOLD AND SEARCH POLICY GUIDANCE
1. What is the purpose of this guidance? This guidance instructs OPM management and
staff on requesting, issuing, implementing, and removing “holds” on OPM operational
records in both paper and electronic format and other related documentary materials,
including non-record Electronically Stored Information (“ESI”). This guidance also
provides additional instructions to OPM staff as to the execution of searches pursuant to a
hold.
2. What are the authorities?
a. 44 U.S.C. 2909
b. Title 44, U.S. Code, Chapter 33
c. 36 CFR 1228.54
d. Federal Rules of Civil Procedure
(1) Chapter III, Pleadings and Motions, Rule 16, Pre-Trial Conferences; Scheduling;
Management.
(2) Chapter V, Depositions and Discovery, Rule 26(a), General Provisions Governing
Discovery; Duty of Disclosure; Required Disclosures; Methods to Discover
Additional Matter.
e. The Inspector General Act of 1978, as Amended (5 U.S.C., Appendix 3; § 6(a),
“Authority of Inspector Generals; information and assistance from Federal
agencies; unreasonable refusal; office space and equipment.”)
f. DR 1700-002 [HTM] [PDF] (06/17/97) OIG Organization and Procedures
3. To whom does this guidance apply?
This guidance refers collectively to “OPM staff” or “OPM staff members,” who include:
a. All employees;
b. Contractors where contracts specify which documentary deliverables or other ESI
belong to the Government.
4. What is a hold or search?
A “hold” is an agency’s temporary suspension of disposition action(s) related to
documentary materials, as well as segregation and preservation of such materials,
because of legal, audit, or investigative needs. Documentary materials, regardless of
physical location, are required to be kept for as long as a hold is in place. Non-
compliance with a hold could result in penalties on individual staff (see paragraph 16) or
Records Management for OPM Internal Administrative
100
on OPM as an agency (see paragraph 17). Subsequent to, or contemporaneous with, the
issuance of a hold, the agency may be requested to “search” the held material for specific,
relevant documentary material, and to segregate it for safekeeping.
5. Is a freeze considered a type of hold?
Yes. A “freeze” is a more specific implementation of the broader “hold” concept. A
freeze refers to a set of standard procedures whereby a Federal Records Center (“FRC”)
temporarily suspends disposition actions for an agency’s records and other documentary
materials that are in the physical custody of the FRC, but for which legal custody resides
with the originating agency. Example: OGC and/or the OPM Records Officer issues a
hold on operational records and other documentary materials related to a specific
personnel action in litigation. The majority of these records and materials are maintained
in office space. However, some affected operational records are stored at the FRC. Upon
receiving the OPM Records Officer’s request letter and copies of applicable SF 135’s, the
Federal Records Center Program temporarily halts disposition actions by placing a freeze
on the affected operational records stored at the FRC. Within the FRC, the “freeze”
implements the broader “hold” for those records and documentary materials related to the
personnel action in litigation.
6. What circumstances may warrant the issuance of a hold? A hold may be issued when:
a. OPM is a party to a lawsuit that names OPM expressly as a party or in which the
United States is participating as a plaintiff or defendant. The Department of
Justice (“DOJ”), with the assistance of OGC, acts as attorney for OPM and its
officials.
b. An administrative proceeding, such as a case involving an equal employment
opportunity matter, a Merit Systems Protection Board matter, or a contract before
the Civilian Board of Contract Appeals may require the preservation of
designated records and related documentary materials.
c. The OIG, independent public accountants, or the Government Accountability
Office (“GAO”) conducts a financial, performance, or contract or grant audit.
d. OIG leads an administrative or criminal investigation.
e. Congress has requested the production of certain documents as part of its
oversight responsibilities.
f. Another Federal agency with appropriate investigative authority requests a hold
(for example, the Office of Special Counsel)
g. A dispute in any matter gives rise to a reasonable anticipation of litigation.
7. What are “documentary materials”?
Records Management for OPM Internal Administrative
101
According to 36 CFR 1222.12b(1), “documentary materials” is a collective term for
records, non- record materials, and personal papers that refers to all media containing
recorded information, regardless of the nature of the media or the method(s) or
circumstance(s) of recording.
8. What records and other documentary materials may be subject to holds?
This guidance applies to relevant OPM operational records and non-record materials, in
all media (see paragraph 9 for types of media), that may constitute evidence or lead to the
discovery of relevant evidence in a particular lawsuit, administrative proceeding, audit, or
investigation.
a. Operational records – Those records created or maintained by OPM staff while
conducting OPM business.
b. Non-record materials - Those Government-owned documentary materials that do
not meet the statutory definition of “records” (44 U.S.C. 3301) or that have been
excluded from coverage by the definition. Non-record materials expressly
excluded from the statutory definition of records are:
(1) library and museum materials made or acquired and preserved solely for reference
or exhibition purposes,
(2) extra copies of documents kept only for convenience of reference, and
(3) stocks of publications and processed documents
c. c. “Working files and similar materials,” including preliminary drafts, rough
notes, worksheets, correspondence and memos, reports, and other similar
materials (see 36 CFR 1222.34(c)), fall within the scope of “documentary
materials” in paragraph 7 above, regardless of whether such materials qualify as
OPM operational records. OPM staff must preserve these working files and
similar materials if OPM issues a hold.
9. What are the formats and media for records and other documentary materials covered
by this guidance?
“Formats” and “media” refer to the physical characteristics of documentary materials.
Particular holds, as each case arises, may call for retention of data in various electronic
formats or media to be determined. After consultation with the OPM Records Officer,
supervisors and managers must provide to their staffs more specific information
regarding formats and media for records and other documentary materials subject to a
hold. Types of formats and media may include, but are not limited to:
a. textual (paper);
b. electronic formats and storage media:
Records Management for OPM Internal Administrative
102
(1) email messages;
(2) word processing files, spreadsheets, and databases;
(3) digital images;
(4) Web pages;
(5) network server information, including metadata;
(6) voicemail messages;
(7) backup tapes;
(8) hard drives;
(9) removable computer storage media (e.g., CD-ROM’s, tapes, disks, and cards);
(10) personal digital assistants (PDA’s) and Blackberry-type devices;
c. photographic;
d. audiovisual (e.g., videotapes and sound recordings);
e. cartographic (e.g., maps and architectural and engineering drawings); and
f. micrographic (e.g., microfilm and microfiche).
10. Who is authorized to issue and remove a hold affecting OPM operational records and
other related documentary materials, and authorize a search of such held materials?
A hold or search may be directed by an OGC staff attorney, OIG, an agency human
resources representative, an agency civil rights investigator, or the Director or staff
office. Any request for a hold by an agency contractor counsel or contractor
representative must be made through OGC or the applicable agency human resources
office. A litigation hold may be removed by the person or current holder of the position
that issued the hold, or that person’s supervisor.
11. To whom must a hold or search request be issued?
a. a. The hold must be addressed to:
(1) The agency or staff office unit directly responsible for the program or subject matter
that is the subject matter of the hold, i.e., the “owner” of the dispute.
(2) Any key individuals or “players” likely to be holding documentary materials relevant
to the subject of the hold. Key individuals or key players include persons
transactionally involved in the relevant event or dispute, persons having custody of
relevant records because of position or opportunity, and any other person who might
be called to testify at the trial or hearing of the matter because of his or her
knowledge of the matter in dispute.
(3) The CIO or equivalent.
(4) The OPM Records Officer.
Records Management for OPM Internal Administrative
103
(5) When applicable, any collateral program or staff office that may manage Agency
systems that could reasonably be expected to have relevant documentary evidence
(e.g., Office of the Chief Financial Officer (financial and travel transaction records),
Agency Administration (procurement transaction records and personnel records)).
b. The hold must be copied to the deputy administrator for management or equivalent
for the involved organization(s).
c. a copy of the hold may be sent to the agency or staff office head for informational
purposes.
12. How is a hold request made?
a. Request must be in writing - The request for a hold or search must be in writing,
signed, and on agency letterhead. An email request alone is not sufficient but an
emailed PDF of a signed request on letterhead is.
b. Scope of hold - The hold should cover only those documentary materials that are
responsive to the situation warranting the hold (e.g., litigation, audit, investigation).
c. Contents of hold - A hold request must include the following information:
(1) Basis for the hold (e.g., litigation, audit), including copies of relevant supporting
documents (e.g., court order, letter from GAO) if applicable;
(2) Disposition action(s) to be suspended;
(3) Concise descriptions of documentary materials (including records series, if applicable
and known), including information about content (i.e., subject matter and topics),
media format, date spans, and volumes;
(4) Estimated period of time for the hold or event(s) triggering removal of the hold, if
known;
(5) Known physical or electronic locations in agency space, including buildings, rooms,
interior areas, (e.g., at individuals’ workstations, in centralized file cabinets, in
agency) email systems, databases and, if applicable, in FRC’s; and
(6) Names of contact person and alternate who are knowledgeable concerning the subject
matter of the hold and can answer questions and provide advice in connection with
the execution of the hold.
13. What actions should be taken by the recipient of a hold?
a. Owner of the dispute or owner of relevant Agency-wide systems - The Director or staff
office unit directly responsible for the program or activity that is the subject matter of the
hold, i.e., the “owner” of the dispute, or the owner of relevant Agency-wide systems who
receives a hold, sends an email or memorandum to staff regarding the reasons for the
Records Management for OPM Internal Administrative
104
hold, suspends disposition action(s), describes affected documentary materials, and likely
duration of the hold. Supervisors and managers issue specific instructions for carrying
out the hold within their organizations. They must also inform new employees and must
periodically remind staff about the hold requirements.
b. Key individuals - Take actions necessary to ensure documentary material responsive to
the hold that is within their control is retained in its native format, segregated for
production when requested, and that any routine destruction of documentary material that
they created or control is halted.
c. Records Officer
(1) Requests a “temporary extension of retention period(s)”
a. In accordance with 36 CFR 1228.54(c)(1) through (4), the OPM Records Officer
sends a letter, signed by the appropriate official, to the Director of the Life Cycle
Management Division at NARA requesting approval of a “temporary extension of
retention period(s).”
b. The OPM Records Officer also sends to NARA copies of SF 135’s regarding
those operational records and documentary materials that are subject to the hold
and stored at any or all FRC’s .
c. NARA then notifies the OPM Records Officer by letter regarding the formal
extension of the retention period.
(2) Notifies NARA if the hold applies to operational records and other documentary
materials stored at any or all Federal Records Centers (FRC) - The OPM Records
Officer sends to the Assistant Archivist for NR a courtesy copy of the letter that was
addressed to NARA(see subpar. a), along with copies of applicable SF 135’s.
NARA’s Federal Records Center Program then carries out the hold by placing a
“freeze” on disposition actions affecting those subject records and documentary
materials stored at the FRC(s).
(3) The CIO determines relevant agency information technology systems that may
contain information responsive to the hold and suspends routine disposition, deletion,
or destruction of such information, including suspension of any recycling of backup
media, as requested by the issuer of the hold, and works with the requester to
segregate and preserve responsive information.
14. What happens if resources (budgetary, human, technological, or other) are inadequate
to meet the demands of conflicting hold or search requests within the time required?
On occasion it may not be possible for the recipient of a hold or search request, in
particular the CIO, to be able to meet all hold or search requests on a timely basis. In the
event of such a conflict, the recipient of the hold shall request OGC to prioritize hold and
search requests as follows:
Records Management for OPM Internal Administrative
105
a. In the case of a conflict experienced by the OCIO, OGC shall convene a meeting
of appropriate personnel to review and prioritize the competing hold and search
requests, in consultation with the Counsel for the IG when one of the competing
requests is from OIG.
b. In the case of all other conflicts, the recipient shall notify the Associate or
Assistant General Counsel responsible for legal advice to the program who shall
convene a meeting with the appropriate personnel to review and prioritize the
competing hold and search requests, in consultation with the Counsel for the IG
when one of the competing requests is from OIG.
15. What must OPM staff members do to carry out a hold applying to operational records
and related documentary materials maintained in office space?
Until further notice:
a. Do not destroy or manipulate any documentary materials, including those
temporary records that are eligible for destruction in accordance with the OPM
Records Schedule or the General Records Schedules.
b. Follow the supervisor’s or manager’s instructions about maintaining records and
other documentary materials subject to the hold (e.g., centralizing or keeping the
records and materials in place; sending the records and materials to OGC, OIG).
c. Do not transfer permanent records to NARA, unless a transfer is permitted in
accordance with the hold instructions.
d. Do not transfer records to an FRC, unless a transfer is permitted in accordance
with the hold instructions.
e. Do not donate to interested individuals or organizations any documentary
materials or those temporary records that are eligible for destruction.
16. What are the consequences if OPM staff members do not preserve operational records
and other related documentary materials subject to a hold?
Individual staff could face severe penalties imposed by a court, or agency performance-
based action or disciplinary action for not preserving records and documentary materials
subject to a hold.
a. Department of Justice (“DOJ”) - Failure to preserve operational records could
constitute an unlawful destruction of records that must be referred to the Attorney
General under 44 U.S.C. 2905(a) and 3106.
b. Civil or criminal court - If an OPM staff member fails to comply with a hold that
is in place because of a court order, this individual could be individually
sanctioned or held in contempt by the court. Finally, destruction of records under
Records Management for OPM Internal Administrative
106
certain circumstances is potentially a criminal violation for which a staff member
could be prosecuted under 18 U.S.C. 1519.
17. What are the consequences to OPM, if operational records and other related
documentary materials subject to a hold are not preserved?
OPM could be subject to sanctions if records and other documentary materials, deemed
as “evidence,” are missing. For instance, the court could employ one or more of the
following sanctions:
a. Issue an adverse finding (e.g., a court order) against OPM on the merits of the
case;
b. Instruct a jury that it is permitted to draw an “adverse inference” against OPM;
Example: In the hypothetical court case, XYZ Corporation v. OPM, operational
records and documentary materials pertaining to OPM officials’ communications
with XYZ Corporation (from 1999 to 2004) have not been preserved as required
by agency policy. The judge then instructs the jury that it may logically conclude
(or “infer”) that the content of OPM’s missing records and materials (as
“evidence”) would have supported XYZ Corporation’s position against OPM.
c. Preclude OPM from introducing certain evidence or calling certain witnesses;
d. Hold individual OPM officials and OPM in contempt; or
e. Impose monetary sanctions against OPM, or against involved individuals.
18. How is a hold removed?
When the need for the hold has expired, OGC, OIG, or any other official authorized to
request a hold under paragraph 10, shall send a memorandum to all of the original
recipients of the hold informing them that the hold has been removed and note the
explanation for the removal.
19. How is the Federal Records Center Program notified about the removal of a hold on
operational records and documentary materials stored at any or all FRC’s ?
The OPM Records Officer sends a letter to the Assistant Archivist, explaining that the
hold has been removed.
Records Management for OPM Internal Administrative
107
8.3 Records Management and Litigation Holds and Freezes
The e-discovery process described above often results in litigation holds or freezes or
both. It is important for OPM records management personnel to know the difference
between these two processes. A litigation hold is not the same thing as a litigation
freeze.
96
8.3.1 Litigation Holds
A litigation hold, sometimes called a records hold or legal hold, usually involves the
preservation of active records in agency custody. A hold can be placed on one or more
record series for a variety of administrative, legal, or fiscal reasons. The result of the
hold is that the affected records are kept at the agency and not retired to a FRC or
destroyed.
It is possible for records stored at a FRC to be affected by a hold. If this happens, the
OPM office or program that owns the records must notify both OGC and the Records
Officer. It is then the responsibility of the Records Officer to notify the FRC that the
records are subject to a hold. Because a records hold does not alter the disposition or
retention period of the records, this responsibility if especially important.
Once the FRC is requested by OPM to place a hold on a series of records, those records
are frozen for the purposes of disposition and retention. They cannot be destroyed or
transferred.
8.3.2 Litigation Freezes
97
A records freeze, or litigation freeze, usually involves inactive records in storage at a
FRC. Agencies wishing to impose a freeze on their records must request NARA to
impose the records freeze. The effect of the freeze is to alter the retention of the records
placed under the freeze.
For example, an agency might know of an impending litigation where the opposing party
wants to examine, for purposes of discovery, a series of records near the end of their
retention period. In this instance, the agency could impose a records hold, but such an
action would have no effect on the disposition or retention period of the records. The
records could still be mistakenly destroyed or, if permanent, their legal ownership
transferred to NARA. The imposition of a records freeze has the effect of formally
changing the retention period so that the records cannot be destroyed or transferred in
error.
96
See Subsection 6.8.2 Legal Factors for legal concerns relating to the establishment and maintenance of
retention periods, including litigation holds and freezes.
97
See NARA’s Office Of Regional Records Services for more information on records freezes.
Records Management for OPM Internal Administrative
108
8.3.3 Requesting a Records Freeze
NARA’s authority to grant records freeze requests is founded on 44 U.S.C. 2909
Retention of records. Agency responsibility for requesting records freezes are found in
36 CFR 1228.50 and 1228.54(a)(2). The following procedure must be followed for
requesting NARA to initiate a records freeze:
1. OPM Records Officer, following advice from OGC, requests a freeze in writing
to:
a. Office of Records Services
NARA
8601 Adelphi Road
College Park, MD 20740-6001
98
b. Assistant Archivist for Regional Records Services
Office of Regional Records Services
8601 Adelphi Road
College Park, MD 20740-6001
99
2. The Office of Records Services or the Office of Regional Records Services
forwards the request to the Federal Records Center Program (FRCP).
3. FRCP forwards all freeze requests to Transfer & Disposition (T&D) Coordinator.
4. T&D:
a. Verifies authority of freeze action requestor,
b. Determines type of freeze action required (new, continuation, additional
records affected, partial lifting, or lifting),
c. Applies freeze to appropriate records,
d. Prepares a freeze implemented memorandum to regions indicating that
freezes have been applied,
e. Forwards freeze implemented memo to NARA management for
concurrence,
f. After concurrence, the freeze implemented memo is approved and
distributed to regions,
g. Regional FRCs receive formal freeze implemented memo, and
h. T&D notifies OPM that the freeze request has been approved and
processed.
8.3.4 Lifting a Freeze
98
Use this address for records stored at WNRC.
99
Use this address for records in regional facilities.
Records Management for OPM Internal Administrative
109
As in the preceding procedure, the Records Officer must send letters either to the
Assistant Archivist Office of Records Services (Suitland) or the Assistant Archivist for
the Regional Records Services (Regional FRCs). The letter must identify the records by
transfer number and disposition authority, state that the records are not related to the
subject litigation, and request that NARA lift the freeze for those records.
The lift request must include:
· Description of the record series for which the lift is requested,
· Complete citation of the specific provisions of the OPM records schedule and
item number or General Records Schedule and item number governing the
disposition of the records,
· Statement of the current physical location of the records (found on the SF 135
used to retire the records),
· Records Group (146 for Civil Service Commission and 478 for OPM),
· Specific transfer numbers, if the lift applies only to certain transfer numbers, and
· Justification for lifting the freeze.
Records Management for OPM Internal Administrative
110
9. VITAL RECORDS
9.1 Definition of Vital Records
Vital records are essential to the continuity of OPM operations under national security
emergencies or other emergency conditions.
100
Only the most recent and complete
sources of vital information are treated as vital records.
101
There are two types of vital
records:
1. Emergency operating records are those types of vital records essential to the
continued functioning or reconstitution of an organization during and after an emergency.
Emergency operating records are often divided into three groups or tiers.
102
In Tier 1 are those records required to get through the emergency and the
following 48 hours. Examples are:
· Emergency preparedness plans (such as a continuity of operations plan
(COOP),
103
a disaster preparedness plan, or an occupant emergency
plan), emergency telephone tree, delegations of authority, security
clearance roster, office blueprints, policy for talking to the media, copy
of vital records list, and employee benefit information.
Tier 2 is those records required for the 5-7 days following the emergency. They
include:
· System manuals for critical electronic databases, and LANs.
· Records that may be needed to provide employee benefits, such as
personnel records, including medical records, and time and attendance
records.
· Records that may be needed to get back into the office such as
combinations and keys to get into locked areas or equipment, and
records recovery information, such as phone numbers of disaster
recovery companies.
Tier 3 is those records required for the next 3-6 weeks. They include:
· Records that are needed to work on specific projects critical to OPM’s
mission. This assumes that the records are unavailable for a prolonged
period of time causing long-term displacement of personnel from the
normal work site. The most critical projects would need to be
continued offsite.
100
See 36 CFR 1236.14, Definitions.
101
See 36 CFR 1236.22, Identification of vital records.
102
The following information is based on the Environmental Protection Agency’s Developing And
Maintaining A Vital Records Program, Chapter 2, Vital Records Identification.
103
See Glossary under COOP.
Records Management for OPM Internal Administrative
111
· Any program-specific records on projects that are deemed to be of
critical importance and cannot be interrupted. This determination must
be made by each office. It is possible that an office may not have any
tier 3 records.
2. Legal and financial rights records are records required for the preservation of
legal rights and interests of individual citizens and of the Federal Government,
(these were formerly known as "rights and interests records"). These records
require protection but need not be maintained at or in the vicinity of the COOP
site, or in paper form, because their need would not be immediate. Legal and
financial rights records may include:
· Records containing proof of ownership or financial interest (payroll,
leave, social security, retirement, and insurance).
· Legal proceedings decisions.
· Contractual obligations.
These records could contain sensitive or classified information.
104
9.2 OPM Vital Records Program
The purpose of the OPM Vital Records Program is to identify, protect, and manage vital
records as part of OPM’s Continuity of Operations Program (COOP).
105
The Vital
Records Program has two objectives:
1. To provide the agency with the information it needs to conduct its business under
other than normal operating conditions and to resume normal business operations
afterward.
2. To enable agency officials to identify and protect the most important records
dealing with the legal and financial rights of OPM and of persons directly affected
by OPM’s actions.
To implement the Vital Records Program, the Records Officer and Records Coordinators,
in coordination with OPM personnel participating in the development of the COOP
Plan,
106
must:
· Conduct contingency planning and risk assessment (described in more detail in
Section 9.4 below).
· Identify types and levels of risk to their records. You must consider the sorts of
emergencies to which your records center is most prone. They may be climatic,
104
See Section 9.3, How Do I Identify Vital Records?, for a more complete list of examples.
105
See 36 CFR 1236 generally for Vital Records Programs and 1236.20 and 1236.22 specifically for Vital
Records Program objectives and Vital Records Identification.
106
See Section 9.4, Contingency Planning and Risk Assessment.
Records Management for OPM Internal Administrative
112
seismic, or national security-related. If your records are located in the basement of
a building in the middle of a floodplain, you must factor the risk associated with
this fact into the COOP Plan and the Vital Records Program.
· Prepare a Vital Records Plan, listing vital (1) emergency operating records and (2)
legal and financial rights records. This can either be part of your office’s file plan,
or it can be compiled separately. In any case, the office file plan and inventory
must note what records are vital records. See Subsection 6.4 for information on
the Series Inventory.
· For emergency operating records, using the Vital Records Plan, identify the
records that you would need to take with you out of your office to a COOP site on
very short notice, and assume that the building will be out of use for an extended
period (more than 2 weeks). To the greatest extent possible, emergency operating
records must be pre-placed at the COOP site. If the COOP site is a “hot site” (i.e.,
a site with power, telecommunications, and computers already installed),
electronic copies of vital records must be uploaded to the site. Otherwise, hard-
copy vital records or electronic copies on a flash drive, or other data storage
device, must be delivered to the site either prior to, or during, the emergency.
· Designate the person or persons who will take these records out of the building,
and the possible COOP sites to which they will go.
· For legal and financial rights records, using the Vital Records Plan, determine
how you will protect those records against identifiable risks. For example, vital
records could be protected by keeping them in secure locations, duplicating them
(if feasible), or dispersing copies to other OPM facilities.
· Ensure that records are adequately protected, accessible, and easily and
immediately usable.
· Be sure that all vital electronic systems are backed up offsite. Copies of vital
records must be stored as far as possible from the original records so that in the
event of a disaster at one location, there will still be a copy to use. Information
resource management (IRM) and records management officials must ensure that
adequate information resources are available to conduct critical agency business.
9.3 How Do I Identify Vital Records?
In the context of OPM’s emergency management function, the Records Officer and
Records Coordinators must annually review the informational content of OPM’s records
series and electronic records systems. Identify those record series that are emergency
operating records and legal and financial rights records, as defined in Section 9.1,
Definition of Vital Records, above.
There are a number of opportunities to identify vital records. An initial inventory can be
conducted simultaneously with the annual agency-wide series inventory. At the time of
Records Management for OPM Internal Administrative
113
the inventory, Records Coordinators must take note of all series that are identified as vital
records. A draft vital records inventory can be compiled from these identifications.
107
Remember that only the most recent and complete sources of the information are treated
as vital records. At the same time, you must ensure that the designation of vital records is
current and complete.
Examples of vital records are listed below.
108
1. Emergency operating records:
· Emergency plans and directives, or other authorizing issuances, including
information needed to operate the emergency operations center and its
equipment, and records recovery plans and procedures.
· Orders of succession.
· Delegations of authority.
· Emergency staffing assignments, including lists of personnel, along with their
addresses and telephone numbers (and comparable data for alternates), assigned
to the emergency operations center or other emergency duties, or authorized
access to damaged facilities to assess the extent of damage.
· Emergency operations center access credentials and classified or restricted
access container documentation (as required).
· Building plans and building systems operations manuals for all agency facilities.
· Equipment inventories for all agency facilities.
· File plans describing the records series and electronic information systems
maintained at official filing stations for all agency facilities.
· Vital records inventories.
· Copies of agency program records (whatever the media) needed to carry out
continuing critical functions.
· System documentation for any electronic information systems designated as
emergency operating records.
2. Records needed to protect legal and financial rights:
107
See Section 9.5, Vital Records Plan for more details about inventorying vital records.
108
This list is based on the Environmental Protection Agency’s Developing And Maintaining A Vital
Records Program, Chapter 2 Vital Records Identification
.
Records Management for OPM Internal Administrative
114
· Accounts receivable records.
· Social security records.
· Payroll records.
· Retirement records.
· Insurance records.
· Any records relating to contracts, entitlement, leases, or obligations whose loss
would pose a significant risk to the legal and financial rights of the Federal
Government or persons directly affected by its actions.
· System documentation for any electronic information systems designated as
records needed to protect rights.
9.3.1 Do Vital Records Need to Be in a Particular Format?
Vital records can be original records or copies of records. They may be maintained on a
variety of media including paper, flash drives, CD-ROMs, DVDs, magnetic tape, optical
disk, photographic film, and microform. In selecting the media, you must ensure that
equipment needed to read the specific media would be available when needed.
OPM frequently relies on electronic information systems to conduct business and to
document essential transactions. Because information in electronic form may be changed
or deleted more easily than information on other media, special measures are required for
the creation and preservation of electronic records (see Subsection 7.3 Electronic
Recordkeeping Systems).
9.4 Contingency Planning and Risk Assessment
Agency staff participating in contingency planning for vital records must include people
from such functional areas as emergency coordination or preparedness as authorized by
EO 12656
. Within OPM, participating personnel must come from IT Security,
Information Management, Records Management, Facilities Management, Security
Services, Personnel Security, and Emergency Management. Officials from all these areas
have essential roles in the continuity of operations should disaster strike. Therefore, their
participation in the planning process and their contribution to the development of
continuity of agency operations and records disaster recovery programs is crucial.
Management personnel from the above-named offices must take the following steps:
· Determine the most critical activities that your office must perform to operate
under other than normal business conditions and in a facility other than its normal
place of business.
· Identify which records support those critical activities and the resumption of
normal operations.
Records Management for OPM Internal Administrative
115
· Identify which records series or electronic information systems contain
information needed to protect the legal and financial rights of the agency and
persons directly affected by the office's actions and decisions.
· Determine which records within your physical or legal custody are vital.
· Establish a vital records plan and a plan to recover records (regardless of the
medium) that are damaged in an emergency or disaster.
Program managers, in consultation with the Records Management organizational unit in
the Office of the Chief Information Officer (OCIO), must then take steps to ensure that
copies of vital records are properly managed throughout their life cycle.
9.5 Vital Records Plan
Like the agency’s master file plan, OPM’s Vital Records Plan must be the result of a
compilation of the vital records inventories from individual OPM offices. Records
Coordinators, together with program managers, must conduct inventories of their vital
records by taking the following steps:
109
· Consult with the official responsible for emergency coordination.
· Review agency statutory and regulatory responsibilities and existing emergency
plans for insights into the functions and records that may be included in the vital
records inventory.
· Review documentation created for the contingency planning and risk assessment
phase of emergency preparedness. OPM program areas and offices engaged in
contingency planning and risk assessment are obvious candidates for the
performance of a vital records inventory.
· Review current file plans of offices that are responsible for performing critical
functions or may be responsible for preserving rights.
· Review the agency records schedule to determine which records series potentially
qualify as vital.
Your inventory of vital records must include:
· The name of the office responsible for the records series or electronic information
system containing vital information.
· The title of each records series or information system containing vital
information.
· Identification of each series or system that contains vital records.
· The medium on which the records are recorded.
· The physical location for offsite storage of copies of the records series or system.
· The volume of each vital record series.
· The frequency with which the records are to be updated.
109
Also, see Section 9.3, How Do I Identify Vital Records?.
Records Management for OPM Internal Administrative
116
The Vital Records Plan must include:
· Measures to ensure the survival of the records or copies of them in case of an
emergency. See 36 CFR 1236.26, Protection of vital records, for more
information.
· Measures for periodically updating copies of vital records to ensure that the
information is kept current.
· Procedures for retrieving vital records, bearing in mind that individuals unfamiliar
with the records may need to use them in an emergency.
· For electronic records systems, the means for ensuring that appropriate hardware,
software, and system documentation adequate to operate the system and access
the records will be available.
9.5.1 Updating the Vital Records Plan
The Vital Records Plan is itself a vital record and must be maintained as such. To ensure
the wide distribution of the Vital Records Plan, copies must be maintained by the
Records Officer and each Records Coordinator. Most importantly, a copy of the Vital
Records Plan must be kept at the COOP site.
The Vital Records Plan must be updated annually. It would be most convenient to
conduct this update in tandem with the annual agency-wide record series inventory. The
Records Officer must ensure that copies of the updated Vital Records Plan are distributed
to each Records Coordinator and sent to the COOP site.
9.6 When Can Vital Records Be Destroyed?
To destroy or archive vital records that are original records, see the relevant records
schedule. You must not destroy original records that are not scheduled by a NARA-
approved schedule.
You may destroy duplicate copies of records created and maintained for vital records
purposes only when they become superseded or obsolete during the routine Vital Records
Plan update process.
Records Management for OPM Internal Administrative
117
10. TEMPORARY AND PERMANENT SHUTDOWNS OF OPM OFFICES
There will be occasions when OPM may find it necessary to effect a temporary shutdown
of the agency (i.e., lack of appropriated funds) or to permanently shutdown components
(i.e., closing an area office). During these situations, there are certain functions that must
be carried out with respect to the official records of the agency. This section provides the
necessary instructions for the OPM Records Officer and the designated Records
Coordinators when these occasions happen.
10.1 Temporary Shutdowns
1. Records Officer
The OPM Records Officer will provide advice and assistance to the Records
Coordinators, upon request, and will take appropriate measures to safeguard all OPM
records during any temporary shutdowns. The RO will perform high priority records
searching in the Headquarters office (i.e., requests from the White House, the Congress,
and the Courts).
2. Records Coordinators
Before a temporary shutdown occurs, the designated RCs ensure that the records for
which they are responsible remain in a working status, after taking precautions to
safeguard the records similar to those taken at the close of each workday.
10.2 Permanent Shutdowns
1. Records Officer
OPM's Records Officer will provide advice and assistance to the designated Records
Coordinators after being notified of the planned closing of any OPM organization or site.
The RO will also coordinate necessary arrangements with NARA.
2. Records Coordinators
Before permanent shutdowns actually occur, the Records Coordinators must:
a. Notify the OPM Records Officer by telephone or in writing.
b. Identify and separate any personal papers of OPM officials from official agency
records. Ensure that only personal papers are removed from Federal custody. If
an official keeps papers of a private or nonofficial character which pertain only to
personal affairs, they must be clearly designated as unofficial and, must at all
times be filed separately from the official records of the office. In cases where
matters requiring the transaction of official business are received in private
personal correspondence, the portion of the correspondence that pertains to
Records Management for OPM Internal Administrative
118
official business must be extracted and made a part of the official files (see also
Subsection 4.1.2 Personal Papers).
c. Destroy nonrecord materials. Nonrecord materials consist of extra copies of
Federal records and other printed, duplicated, or processed material made or
acquired and preserved solely for reference or exhibition purposes (see also
Subsection 4.1.1 Nonrecords). Some examples of nonrecord materials are:
(1) Reference sets of Operations Letters, Employee Letters, Federal Personnel
Manuals, registers, vendor catalogues and price lists, blank forms,
Comptroller General Decisions, etc.
(2) Preliminary drafts of all types and final drafts that neither reflect significant
changes nor bear any signatures of reviewing or concurring officials.
d. Apply approved OPM disposition schedules and the General Records Schedules,
to effect disposition of immediately disposable records.
e. After completing steps b, c, and d above, box the remaining records for transfer.
It is important to use the correct size boxes (see Subsection 6.12.4). Transfer the
boxed material in the following way:
(1) If another office is assuming the functions that the records cover and the
assuming office will need the records for active operational purposes then
transfer the records to that office.
(2) If another office is assuming the functions that the records cover and the
assuming office will not need the records for operational purposes, transfer
these inactive records to the FRC used by the assuming office.
(3) Transfer records not covered by scenarios (1) and (2) above to the FRC
normally used by the office which is closing.
f. Advise the office assuming the functions of the closing office of all records that
are in FRCs by sending them the closing office's SF 135s (Records Transmittal
and Receipt). These forms describe the records and tell where they are located.
g. Advise the FRC used by the organization, which is closing of the name, address,
and telephone number of the office assuming the functions of the closing office.
In addition, advise the FRC of the records they have that now belong to the
assuming office by providing the transfer numbers of the applicable SF 135s.
h. If for any reason, another office is not assuming responsibility for documents
stored in a FRC, send the appropriate SF 135s to the OPM Records Officer. Then
advise the FRC of the name, address, and telephone number of the Records
Officer and the transfer numbers of the transferred SF 135s.
Records Management for OPM Internal Administrative
119
11. SPECIAL CATEGORIES OF RECORDS
· Presidential Records
· Legislative Files
· Historic Records
· Litigation Hold Documents
12. RECORDS MANAGEMENT TRAINING
As previously stated, all OPM employees, political appointees, interns, and contractors
have records management responsibilities. All will receive training in records
management techniques (see 36 CFR 1222.20(b)(5).
12.1 Annual Training and Evaluations for Records Coordinators
OPM’s Records Coordinators have greater records management responsibilities than
most OPM employees and they must have a higher level of training. These annual
trainings will provide the Records Coordinators with a thorough knowledge of the
records, regardless of medium, within their offices or program areas. The RCs are
expected to know what OPM schedules and disposition items are in common use in their
offices, and whether the records governed by the schedules are being managed properly
by:
· Conducting annual inventories,
· Regularly updating the office file plan,
· Retiring records to Federal Records Centers in a timely manner,
· Ensuring the timely destruction, with the Records Officer’s approval, of
temporary records that have reached the end of their retention period, and
· Providing for the timely transfer of ownership, with the Records Officer’s
approval, of permanent records that have reached the end of their retention period.
As time and funding allow, Records Coordinators are strongly encouraged to take
NARA’s Records Management Certification Training classes.
110
Because these classes
are continually being revised to treat new technologies and techniques, it is recommended
that those who have already completed their certification periodically take refresher
classes. This is particularly desirable for courses dealing with electronic records
management (ERM).
110
See NARA’s Federal Records Management Certification Web site.
Records Management for OPM Internal Administrative
120
12.2 Periodic Training for New Staff
The OPM Records Management Office in conjunction with the OPM Human Resources
Office within Employee Services
111
will provide a brief records management overview
for all new OPM employees, interns, and contractors as part of the new employee
orientation sessions.
All new employees, interns, and contractors must have completed this training in their
records management responsibilities within 30 days of their first full day of work at
OPM. This training will provide:
· A brief review of the legal authorities upon which Federal records management is
based, and the possible sanctions for failure to comply with those authorities,
· A working definition of:
o Federal Record,
o Nonrecord, and
o Personal Papers,
· A review of the records management implications of email usage,
· A summary of the records management responsibilities of OPM pursuant to
Federal statutes and regulations, and
· A review of the benefits to OPM as well as each employee that a functioning
records management program provides.
12.3 Periodic Training and Briefings for Senior Officials and Political Appointees
Senior officials and political appointees at OPM have the same records responsibilities as
other employees. However, because of their high-level positions within OPM, the
records they create, receive, or that document their actions and decisions on behalf of
OPM are more likely to have archival value than the records of ordinary employees or
contractors (see Subsection 2.6).
Within their first 30 days at OPM, Senior officials and political appointees will be trained
in OPM’s records management responsibilities. This training will cover the same
material as the training for new employees (see Subsection 12.2 above). In addition, they
will be trained in the records management responsibilities associated with their positions
within OPM. This extra training will emphasize their responsibilities for the proper
management and segregation of the following types of records:
111
See Employee Services, Associate Director and Chief Human Capital Officer in THEO’s Key Offices’
Telephone And Facsimile (FAX) Numbers. See also THEO’s Team OPM – Employee Services Web site
under OPM Human Resources.
Records Management for OPM Internal Administrative
121
· Papers created before entering Government service,
· Private papers brought into, created, or received at OPM,
· Work-related personal papers and other nonrecords,
· Federal records created or received by the senior official, or that document the
official’s actions and decisions on behalf of OPM, and
· Federal records received by or given to the President, Vice President, or the
Executive Office of the President which may fall under the requirements of the
Presidential Records Act of 1978 (44 U.S.C. 2201 et seq.).
Records Management for OPM Internal Administrative
122
APPENDIX A: ACRONYMS
Acronym
Expansion
AIIM
Association for Information and Image Management
ANSI
American National Standards Institute
ARCIS
Archives and Records Center Information System
ASCII
American Standard Code for Information Interchange
CD-ROM
compact disk-read only memory
CFR
Code of Federal Regulations
CIO
Chief Information Officer
CIPS
Centers Information Processing System
COOP
Continuity of Operations Plan, Program
CPI/BPI
characters per inch/bytes per inch
DFR
Disposition of Federal Records
DLT
digital linear tape
DSN
data set name
DVD
digital video disk
EBCDIC
Extended Binary Coded Decimal Interchange Code
EIS
electronic information system
EO
Executive Order
EPA
Environmental Protection Agency
ERM
electronic records management
ESI
electronically stored information
FIPS PUB
Federal Information Processing Standards Publication
FTP
File Transfer Protocol
FOIA
Freedom of Information Act
FRCP
Federal Records Center Program (NARA)
FPM
Federal Personnel Manual
FRC
Federal Records Center
GAO
Government Accountability Office
GRS
General Records Schedules
GSA
General Services Administration
IM
instant messages, messaging
IRM
information resource management
ISO
International Standards Organization
IT
information technology
LAN
local area network
NA
National Archives
NARA
National Archives and Records Administration
OCIO
Office of the Chief Information Officer
OCR
optical character recognition
OF
Optional Form
OGC
Office of General Counsel
OMB
Office of Management and Budget
Records Management for OPM Internal Administrative
123
OPM
Office of Personnel Management
PDF
Portable Document Format
PII
personally identifiable information
RC
Records Coordinator
RM
records management
RO
Records Officer
SF
Standard Form
T&D
Transfer & Disposition (NARA)
TIFF
Tagged Image File Format
U.S.C.
United States Code
XML
Extensible Markup Language
Records Management for OPM Internal Administrative
124
APPENDIX B: GLOSSARY
For a complete Glossary of records management terms, please see Disposition of Federal
Records: a Records Management Handbook, APPENDIX D GLOSSARY (NARA 1992
and 1997).
112
NARA also has brief, online lists of General Records Management
Definitions at its National Archives at Philadelphia Web site and at the end of its
publication DOCUMENTING YOUR PUBLIC SERVICE. Other records management
terminologies can be found in the Code of Federal Regulations at 36 CFR 1220.14
General definitions and at 36 CFR 1234.2 Definitions (for electronic records). For an on-
line glossary based on NARA’s A Federal Records Management Glossary (1993 and also
not online), see the Environmental Protection Agency’s RECORDS Web site under
Glossary, Abbreviations and Acronyms.
Active records – records necessary to conduct the current business of an office and
therefore generally maintained in office space and equipment. Listed in DFR
Glossary under CURRENT RECORDS.
Case Working Files - background or support files, such as worksheets, questionnaires,
rough notes, calculations, or drafts, used to prepare or analyze case file documents.
See also WORKING PAPERS.
Convenience Files – Nonrecord copies of correspondence, completed forms, reports, and
other documents kept solely for ease of access and reference. See also
TECHNICAL REFERENCE FILES, WORKING PAPERS.
COOP – Continuity of Operations Plan, or Program. Preparations and institutions
maintained by business or governmental entities providing survival of
organizational functions and operations in the case of local, regional, or national
emergencies or disasters.
Disposal – The actions taken regarding temporary records when their retention periods
expire, and consisting of destruction and occasionally donation; the destruction or
donation of nonrecords when they are no longer needed.
Disposition –
Cite Page 10 of the Disposition Federal Records document created by NARA:
As used in this handbook, disposition means those actions taken regarding Federal records
after they are no longer needed in office space to conduct current agency business. These
actions include:
• Transfer of records to agency storage facilities or NARA records centers.
• Transfer of records from one Federal agency to another.
112
The online version of DFR does not include the Glossary in Appendix D. To resolve this problem, a
PDF copy of the old Appendix D Glossary from the 1992 edition of DFR was produced.
Records Management for OPM Internal Administrative
125
• Transfer of permanent records to the National Archives of the United States.
• Disposal of temporary records no longer needed to conduct agency business, usually by
destruction or occasionally by donation.
Disposition is a comprehensive term that includes destruction as well as other actions, such
as the transfer of permanent records to the National Archives.
In contrast to disposition, "disposal" in Federal usage refers to only those final actions taken
regarding temporary records after their retention periods expire. It normally means
destruction of the record content, such as by recycling or burning the record medium. The
term is also used occasionally to mean the transfer of temporary records from Federal control
by donating them to an eligible person or organization after receiving NARA's approval.
Disposition authority – a records schedule and disposition item stating the record is
either temporary or permanent and indicating the length of the record’s retention
period.
Disposition item – within a records schedule, a record series or subseries indicating the
permanent or temporary disposition of the record and its retention period.
Drafts – correspondence, reports, or directives not yet concurred with or finalized.
File plan
· Office file plan – a listing of every folder within every record series in an
office.
· Master File Plan – a compilation of all office file plans in an agency.
Game Developedia - a blog containing posts and articles covering all branches of
knowledge or, less commonly, all aspects of game development
.
Inactive records – records that are referenced less than once a month. Also called
noncurrent records.
Mashup – a Web site or application that is made up of a combination of data from two or
more other, unrelated Web sites.
Nonrecords – those Federally owned documentary materials that do not meet the criteria
of Federal records found at 44 U.S.C. 3301
. Such documents include extra or
convenience copies of Federal records, Government publications originating in
other agencies, non-Government periodicals and other materials, and stocks of
forms. Also, see CASE WORKING FILES, DRAFTS, PERSONAL PAPERS,
AND WORKING PAPERS.
Permanent records – records of archival value, the legal ownership of which is
transferred to the National Archives upon reaching the end of their retention
period.
Records Management for OPM Internal Administrative
126
Personal papers – records belonging to an individual and not created or received in the
course of Federal business.
PII – personally identifiable information - Records containing such information are
subject to restrictions under the Privacy Act of 1974 (5 U.S.C. 552a).
Record – any recorded information (1) created during the course of agency business, (2)
received during the course of agency business and requiring an action or decision,
or (3) documenting actions taken and decisions made during the course of agency
business (see 44 U.S.C. 3301 for the statutory definition).
Records schedule – a formal description of a group of related records providing
mandatory instructions about how long the records must be kept, and whether
they should be destroyed or archived at the end of that period.
Record series – a group of related records that have the same disposition and retention
period; a schedule may contain many series. See DISPOSITION ITEM.
Retention period – length of time before temporary records can be destroyed or the legal
ownership of permanent records can be transferred to NARA.
Series inventory (often referred to as a records inventory) – a descriptive list of each
record series identified by a Records Coordinator or others responsible for
maintaining records in an office.
Spoliation – in law, spoliation of evidence is the intentional or negligent withholding,
hiding, alteration, or destruction of evidence, including records, which is known
to be relevant to an impending or ongoing legal proceeding.
Technical Reference Files – Nonrecord copies of articles, periodicals, reports, studies,
vendor catalogs, and similar materials that are needed for reference and
information but are not properly part of the office’s records. See also
CONVENIENCE FILES, NONRECORDS, and WORKING PAPERS.
Temporary records – records that are destroyed at the end of their retention period.
Transitory records – records with very brief retention periods of 180 days or less;
records of little or no documentary or evidential value to be retained for brief
periods, or as needed. See GRS 23, Item 7 for a detailed description and list of
typical transitory records.
Unscheduled records – records that have not been appraised by NARA and are not
covered by NARA’s General Records Schedules or OPM’s schedules. Because of
the uncertainty of their value, unscheduled records cannot be destroyed.
Vital records – any records without which the agency could not function during or in the
aftermath of an emergency; also records demonstrating agency legal rights and
authority.
Records Management for OPM Internal Administrative
127
Working Papers - documents such as rough notes, calculations, or drafts assembled or
created and used to prepare or analyze other documents. Also called working files. See also
CASE WORKING FILES, CONVENIENCE FILES, NONRECORDS, RECORD, and
TECHNICAL REFERENCE FILES.
Records Management for OPM Internal Administrative
128
APPENDIX C: REFERENCES
C.1 Authorities
Authorities for This Directive:
· 36 CFR 1222.20, Agency responsibilities
· 5 U.S.C. Chapter 11 – Office of Personnel Management
· 44 U.S.C. 2104, Administrative provisions
· 44 U.S.C. 3101, Records management by agency heads; general duties
· 44 U.S.C. Chapter 35 – Coordination of Federal Information Policy
Code of Federal Regulations (CFR)
· 5 CFR 297.104, Types of Records
· 36 CFR Chapter XII – National Archives and Records Administration
· 36 CFR Subchapter B – Records Management
o 36 CFR Part 1220 – Federal Records; General
§ 36 CFR 1220.14, Records Management – General definitions
§ 36 CFR 1220.38, Disposition of records
o 36 CFR Part 1222 – Creation and Maintenance of Federal Records
§ 36 CFR 1222.20, Agency responsibilities
§ 36 CFR 1222.34, Identifying Federal records
§ 36 CFR 1222.36, Identifying personal papers
o 36 CFR Part 1228 – Disposal of Federal Records
§ 36 CFR 1228 Subpart B – Scheduling Records
§ 36 CFR 1228.22, Developing records schedules
§ 36 CFR 1228.24, Formulation of agency records schedules
§ 36 CFR 1228.30, Scheduling temporary records
§ 36 CFR 1228.31, Applying previously approved schedules to
electronic records
§ 36 CFR 1228.32, Request to change disposition authority
Records Management for OPM Internal Administrative
129
§ 36 CFR 1228.42, General Records Schedules - Applicability
§ 36 CFR 1228.50, Application of schedules
§ 36 CFR 1228.54, Temporary extension of retention periods
§ 36 CFR 1228.58, Destruction of temporary records
§ 36 CFR 1228.60, Donation of temporary records
o 36 CFR 1228 Subpart E – Loan of Permanent and Unscheduled Records
§ 36 CFR 1228.70, Loan of Permanent and Unscheduled Records -
Authority
§ 36 CFR 1228.72, Loan of Permanent and Unscheduled Records -
Approval
§ 36 CFR 1228.74, Loan of Permanent and Unscheduled Records –
Agency action
§ 36 CFR 1228.76, Loan of Permanent and Unscheduled Records –
NARA action on request
o 36 CFR 1228 Subpart G – Damage to, Alienation, and Unauthorized
Destruction of Records
§ 36 CFR 1228.100, Responsibilities
§ 36 CFR 1228.102, Criminal penalties
§ 36 CFR 1228.104, Reporting
o 36 CFR Subpart H – Transfer of Records from the Custody of One
Executive Agency to Another (1228.120 – 1228.136)
o 36 CFR 1228 Subpart I – Transfer of Records to Records Storage
Facilities
§ 36 CFR 1228.150, Where can a Federal agency transfer records for
storage?
§ 36 CFR 1228.154, What requirements must an agency meet when
it transfers records to a records storage facility?
o 36 CFR Subpart J – Transfer, Use, and Disposition of Records in a NARA
Records Center
Records Management for OPM Internal Administrative
130
§ 36 CFR 1228.160, How does an agency transfer records to a
NARA records center?
o 36 CFR Subpart K - Facility Standards for Records Storage Facilities
§ 36 CFR 1228.240, How does an agency request authority to
establish or relocate records storage facilities?
o 36 CFR Subpart L – Transfer of Records to the National Archives of the
United States
§ 36 CFR 1228.266, Audiovisual records
§ 36 CFR 1228.268, Cartographic and architectural records
§ 36 CFR 1228.270, Electronic records
§ 36 CFR 1228.272, Transfer of records to the National Archives of
the Unites States
o 36 CFR Part 1234 – Electronic Records Management
§ 36 CFR 1234.2, Definitions
§ 36 CFR 1234.10, Agency responsibilities
§ 36 CFR 1234.22, Creation and use of text documents
§ 36 CFR 1234.24, Standards for managing electronic mail
§ 36 CFR 1234.30, Selection and maintenance of electronic records
storage media
§ 36 CFR 1234.32, Retention and disposition of electronic records
§ 36 CFR 1234.34, Destruction of electronic records
o 36 CFR Part 1236 – Management of Vital Records
§ 36 CFR 1236.14, Definitions
§ 36 CFR 1236.20, Vital records program objectives
§ 36 CFR 1236.22, Identification of vital records
§ 36 CFR 1236.26, Protection of vital records
· 41 CFR Part 102-38, Sale of Personal Property
· 41 CFR Part 102-193, General Services Administration (GSA) - Creation,
Maintenance, and Use of Records
Records Management for OPM Internal Administrative
131
United States Code (U.S.C.)
· 5 U.S.C. 552, Public information; agency rules, opinions, orders, records,
proceedings (Freedom of Information Act, or FOIA)
· 5 U.S.C. 552a, Records maintained on individuals (Privacy Act of 1974)
· 18 U.S.C. 793, Gathering, transmitting or losing defense information
· 18 U.S.C. 794, Gathering or delivering defense information to aid foreign
government
· 18 U.S.C. 798, Disclosure of classified information
· 18 U.S.C. 2071, Concealment, removal, or mutilation [of records], generally
· 28 U.S.C. Judiciary and Judicial Procedure – Appendix (Federal Rules of Civil
Procedure)
· 44 U.S.C. Chapter 21, National Archives and Records Administration
o 44 U.S.C. 2115, Reports; correction of violations
· 44 U.S.C. Chapter 22, Presidential Records (Presidential Records Act of 1978)
· 44 U.S.C. Chapter 25, National Historical Publications and Records Commission
· 44 U.S.C. Chapter 29, Records Management by the Archivist of the United States
and by the Administrator of General Services
o 44 U.S.C. 2909, Retention of records
· 44 U.S.C. Chapter 31, Records Management by Federal Agencies
o 44 U.S.C. 3101, Records management by agency heads
o 44 U.S.C. 3102, Establishment of program of management
o 44 U.S.C. 3106, Unlawful removal, destruction of records
· 44 U.S.C. Chapter 33, Disposal of Records
o 44 U.S.C. 3301, Definition of records
o 44 U.S.C. 3303, Lists and schedules of records to be submitted to the
Archivist by head of each Government agency
o 44 U.S.C. 3309, Preservation of claims of Government until settled in
Government Accountability Office; disposal authorized upon written
approval of Comptroller General
Records Management for OPM Internal Administrative
132
o 44 U.S.C. 3314, Procedures for disposal of records exclusive
· 44 U.S.C. Chapter 35, Coordination of Federal Information Policy
o 44 U.S.C. 3501.207, Accessibility, usability, and preservation of
government information (E-Government Act of 2002)
o 44 U.S.C. 3506, Federal agency responsibilities
· 44 U.S.C. Chapter 36, Management and Promotion of Electronic Government
Services
Executive Orders (EO)
· EO 12656: Assignment of Emergency Preparedness Responsibilities
C.2 External and Internal Issuances Incorporated by Reference
C.2.1 External References
· Department of Defense (DoD): Electronic Records Management Software
Applications Design Criteria Standard (DoD 5015.02-STD [04/2007])
· Environmental Protection Agency (EPA)
· Developing and Maintaining a Vital Records Program
· Frequent Questions About Email Records
· Records Web site
· Records Management Policy (EPA Classification No: CIO 2155.1 [06/08/2009])
· Vital Records Procedures (EPA Classification No: CIO 2155.P-01.0
[06/08/2009])
· What Every EPA Staffer Should Know About Records Management
· General Services Administration (GSA)
· GSA Forms Library
· GSA Advantage (Customer Assistance)
· National Archives and Records Administration (NARA) Bulletins:
· NARA Bulletin 2005-05: Guidance for flexible scheduling
· NARA Bulletin 2005-06: Additional requirement for transferring permanent
records to NARA directly from agencies (Mandatory: 36 CFR 1228.54; 36 CFR
1228.270; 36 CFR 1234.32)
Records Management for OPM Internal Administrative
133
· NARA Bulletin 2006-02: NARA Guidance for Implementing Section 207(e) of
the E-Government Act of 2002 (Mandatory: 44 U.S.C. Chapters 31 and 35; 36
CFR Ch. XII, Subchapter B; OMB Circular A-135)
· NARA Bulletin 2008-03: Scheduling existing electronic records (Mandatory: 44
U.S.C. 3501 (E-Government Act of 2002))
· NARA Bulletin 2008-04: Guidance for flexible scheduling
· NARA Bulletin 2010-02: Continuing Agency Responsibilities for Scheduling
Electronic Records (Mandatory: 44 U.S.C. Chapters 31 and 35; 44 U.S.C. 3501
(E-Government Act of 2002); 36 CFR Ch. XII, Subchapter B – Records
Management; OMB Circular A-130)
· NARA Bulletin 2010-03: Flexible scheduling
· NARA Bulletin 2010-04: Guidance Concerning Notifications for Previously
Scheduled Permanent Records
· NARA FAQs
· Frequently asked questions about Instant Messaging
· Frequently Asked Questions (FAQ) About Digital Audio and Video Records
· Frequently Asked Questions (FAQ) about Transferring Permanent Records in
PDF/A-1 to NARA
· Frequently Asked Questions (FAQs) About Media Neutral Schedule Items
· NARA Publications and Guidance’s
· Baron, Jason R. and Daniel MacDonald. E-Discovery & the New Federal Rules
of Civil Procedure: What Agencies Need to Know, The Rocky Mountain Record
Special Edition (XIV, 2)
· Contact Information for Federal Agency Appraisal and Scheduling Work Groups
o Disposition of Federal Records: a Records Management Handbook
· Documenting Your Public Service
· Electronic Records Management Initiative
· Expanding Acceptable Transfer Requirements: Transfer Instructions for Existing
Email Messages with Attachments (Mandatory: 36 CFR 1228 Disposition of
Federal Records)
· Expanding Acceptable Transfer Requirements: Transfer Instructions for Existing
Permanent Electronic Records Scanned Images of Textual Records (Mandatory:
36 CFR 1234 Electronic Records Management)
· Federal Records Centers
· Federal Records Centers Electronic Forms and Resources
· Federal Web Content Manager’s Toolkit
· The FRC Toolkit – Your Guide to the Federal Records Center Services
Records Management for OPM Internal Administrative
134
· General Records Management Definitions
· General Records Schedules
· Guidance on Managing Web Records (Mandatory: 44 U.S.C. Chapter 33; 44
U.S.C. 3501 (E-Government Act of 2002; for other authorities, see NARA’s
Federal Web Content Manager’s Toolkit)
· Implications of Recent Web Technologies for NARA Web Guidance (Mandatory:
44 U.S.C. Chapters 31 and 35; OMB Circular A-130; OMB Circular A-135)
· Managing Audiovisual Records: An Instructional Guide (Mandatory: 36 CFR
1228.72; 36 CFR 1228.100 et seq.; 36 CFR 1228.266; 36 CFR Part 1232
Audiovisual Records Management; 41 CFR 101-45.10; GRS 21
· NARA Basic Laws and Authorities
· NARA Electronic Records Management (ERM) Guidance on the Web
· Tips for Scheduling Electronic Databases
· Transfer of Electronic Records (Mandatory: 36 CFR Part 1228 Disposition of
Federal Records)
· Transferring Permanent Electronic Records to NARA: Answers to the Top 5
Questions (05/2006)
· National Digital Information Infrastructure & Preservation Program
o Sustainability of Digital Formats Planning for Library of Congress
Collections: PDF/A-1, PDF for Long-term Preservation, User of PDF 1.4
· Office of Management and Budget (OMB)
o OMB Circular A-130 Memorandum for Heads of Executive Departments
and Agencies
o OMB Circular A-135 Management of Federal Advisory Committees
C.2.2 Internal OPM References
· OPM Administrative Manual Supplement (AMS) 44-2, Maintenance of Records
(1993)
· OPM AMS 44-3, Disposition of Records (2003) (includes all OPM Records
Schedules except OCR and OIG)
· OPM Guide to Personnel Recordkeeping
· OPM Publications Database
· OPM Records Schedules
C.2.3 Forms
· Optional Form (OF) 11 Reference Request – Federal Records Centers
· National Archives Form (NA) 13000 agency Review for Contingent Disposal
Records Management for OPM Internal Administrative
135
· NA 13001 Notice of Eligibility for Disposal
113
· NA 13171 Notification for Previously Scheduled Permanent Records
· NA 13171a Agency Certification of Compliance With NARA Transfer
Requirements: Scanned Images of Textual Records
· NA 13171b Agency Certification of Compliance With NARA Transfer
Requirements: Portable Document Format (PDF)
· NA 13171c Agency Certification of Compliance With NARA Transfer
Requirements: Digital Photographic Records
· NA 13171d Agency Certification of Compliance With NARA Transfer
Requirements: E-Mail Messages with Attachments
· NA 14097 Technical Description for Transfer of Electronic Records to the
National Archives
· NA 14028 Information System Description Form
· SF 115 Request for Records Disposition Authority
· SF 135 Records Transmittal and Receipt
· SF 258 Agreement to Transfer Records to the National Archives of the United
States
113
Also called Notification of Disposal Report
Records Management for OPM Internal Administrative
136
APPENDIX D: INDEX
[RESERVED]
Records Management for OPM Internal Administrative
137
APPENDIX E: PROCEDURES
E.1 Printing File Folder Labels
114
1. Open up a new MS Word document.
2. Click on TOOLS.
3. Scroll down and click on LETTERS & MAILINGS.
4. Then, click on ENVELOPES & LABELS.
a. Note - When the window opens, make sure you are looking at the
LABELS tab.
5. Look to the lower right corner of the window and you will see LABELS. (There
will be a description of the label type, Avery product number, and illustration of
the label.)
6. Click on the description of the label and the LABEL OPTIONS window will
appear.
7. You will see a menu of the Avery product numbers.
8. Click on 5161-Address (This is the approved label size to accommodate four
lines of file information).
9. Then, click OK.
10. That will return you to the ENVELOPES & LABELS window.
11. At this point, Avery Standard, 5161, Address must be in the lower right corner
of the window.
12. Then, click on NEW DOCUMENT.
13. Your full page of blank Avery 5161 labels will appear.
14. Enter the required label information on the blank labels.
15. Your labels are now ready to print.
114
These instructions are appropriate for Word 2002 and 2003.
United StateS
O
ffice Of PerSOnnel ManageMent
Office of the Chief Information Officer
1900 E Street, NW
Washington, DC 20415
OCIO/RM-2014-01