Open Gov Plan 3.0

Later this year, the U.S. Government will publish the third National Open Government Action Plan (NAP). This will build on the prior action plans published in 2011 and 2013. Our efforts to improve the management of government records, through things like the Managing Government Records Directive, have been included in these previous plans.

Now, we are soliciting input on this effort from our stakeholders. Please read this post from the Open Government Initiative to see how you can get involved. We look forward to your suggestions and getting them in the next version of the National Open Government Action Plan.

Posted in General | Tagged

Flexible Retentions in the GRS

Here is the next tip from our GRS Team. 

Flexible retentions in the GRS: Your new best friend

Many new GRS disposition instructions look like this:  “Destroy when 3 years old, but longer retention is authorized if required for business use.”  Some reviewers have criticized us for this latitude, and recommended that we state a specific retention period (in the above case, 3 years), then stop.  They object to the elastic clause.  Here’s what we bet is at the bottom of these objections, and why we believe flexibility is really in agencies’ best interests.

We suspect the main objection to retention flexibility is a fear that offices outside the direct sight lines of an agency’s records management function will abuse “longer retention is authorized” as license to never discard anything ever again.  If our guess just tapped into the primal root of your own objection to flexible retention, we have good news.  Flexible retention really is the agency records officer’s new best friend.  If a GRS item has an elastic disposition, as long as you retain records for the minimum time required, you can do one of three things:

  1. You can determine how long your agency has business use for the records. Answering the question  “how long is enough?” is more work than pulling a number out of a hat, and less entertaining than throwing darts at a dartboard, but conversation with subject area experts should get you to a good, defensible answer.  Once you’ve determined the right time period for your agency in excess of the minimum in the GRS, you can publish it without the flexible elastic clause in your records manual and cite the GRS item as your authority.
  1. You can determine that your agency will do just fine with the minimum retention period in the GRS, and not a day longer. Use the GRS item in your agency manual without the flexible elastic clause and cite the GRS item as your authority.
  1. You can do nothing. Let individual offices in your agency determine their own business needs.  We can’t recommend this as a best practice, but we acknowledge it as an option.

And the good news mentioned above?  Did you notice that in all three of these options you do not have to process a records schedule through NARA or ask for a GRS exception?  You have the authority to make choices to best suit your agency.  We think that’s very good news indeed.

Posted in GRS | Tagged , | 2 Comments

Opportunity for Comment: Managing Digital Identity Authentication Records

We are requesting comments on a draft NARA Bulletin entitled “Guidance on Managing Digital Identity Authentication Records.” The draft is available here (.pdf).

This draft Bulletin will provide guidance on the records management requirements related to digital identification records. Specifically, this guidance will provide guidance on managing digital identity authentication-related transactional records, such as digital certificates and Public Key Infrastructure (PKI) files created or used in the course of agency business. This Bulletin will also supersede several of NARA’s records management guidance for PKI digital signature authenticated and secured transaction records.

Agencies use digital identity authentication to protect sensitive records, authenticate employee sign-ins, identify ownership of websites, and many other purposes. They use a wide variety of software. Because of the wide variety of uses and software, the Bulletin provides agencies flexibility in using digital identity authentication technology to manage temporary records. However, when agencies transfer permanent electronic records to NARA, the records must be free of encryption or other forms of security (unless permanent records must be encrypted during transfer to NARA).

Please make your comments about the draft Bulletin by June 12, 2015.  Please comment below or email comments to Lisa Haralampus at Lisa.Haralampus@nara.gov. We will review all the comments we receive. Thank you.

Posted in General | Tagged , , | 2 Comments

Opportunity for Comment: Managing Electronic Messages

We are requesting comments on a draft NARA Bulletin entitled “Guidance on Managing Electronic Messages.

This draft Bulletin applies to text messaging, chat/instant messaging, messaging functionality in social media tools or apps, voice messaging, and similar forms of electronic messaging systems. The Bulletin addresses the new definition for electronic messages and other issues covered in the recent amendments to the Federal Records Act. Overall, it provides basic records management guidance for electronic messages.

NARA Bulletins are designed to provide fundamental guidance to Federal agencies who must then determine the most appropriate ways to incorporate the guidance into their work.

Please make your comments about the draft Bulletin by June 5, 2015. We will review all the comments we receive. Thank you.

Posted in General | Tagged , , , | 6 Comments

Reminder: Capstone GRS Public Meeting

This is a reminder that NARA is holding an open public meeting on Thursday, May 21, 2015, from 10 a.m. to 12 p.m. in the McGowan Theater (basement level), National Archives and Records Administration downtown building, 700 Pennsylvania Avenue, NW to solicit comments on General Records Schedule 6.1: Email Managed under a Capstone Approach.  This is in conjunction with its publication in the Federal Register.

NARA will now also be live-streaming this event for convenience of interested participants and those who may not be in the DC area.  Participants can access the event at the below link.  Questions and comments during the event are encouraged on the live stream page.  Participants can also send questions or comments in advance by 9:00am on the day of the event to request.schedule@nara.gov.

If attending in person, please enter on the Constitution Avenue side of the building, the “Special Events” entrance (which is actually the exit for the general public). Registration information and other additional information on this meeting is published in a separate Federal Register Public meeting Notice.

A copy of the review package comprised of the proposed records disposition schedule, accompanying FAQ, and appraisal memoranda, can be downloaded (.pdf).  To aid in public understanding of this GRS, we also created a White Paper (.pdf) that provides additional background information on the Capstone approach, appraisal of records at NARA, and the development of this general records schedule. So that we can insure all comments are received and considered for the Federal Register comment period, comments must be sent to request.schedule@nara.gov no later than June 1, 2015.

Posted in GRS | Tagged ,

Whatever Happened to GRS Email and Word Processing Files?

Our GRS Team continues to work on updating the General Records Schedules. However, they also will be providing updates on particular questions that they receive. Consider this your GRS Tip of the Month!

Whatever happened to GRS items for electronic mail and word processing files?

NARA enacted a new policy in 1998: all new records schedules must include two items covering “electronic mail and word processing system copies…used solely to generate a recordkeeping copy” of agency records. These items—one for “copies that have no further administrative value after the recordkeeping copy is made,” the other for “copies used for dissemination, revision, or updating” the record copy—enabled disposal of multiple iterations of the same document littering agency electronic servers. NARA applied this new policy to itself, too, and appended these items to most (but not all) GRS schedules when it published GRS Transmittal 8 later that same year.

This requirement was never very popular with either agency records schedulers or NARA appraisers. The items’ sheer repetitiveness made it obvious early on that they were ideal candidates for GRS items. NARA Bulletin 2006-04 rescinded the 1998 policy. These items were removed and replaced by GRS 20, items 13 and 14, in GRS Transmittal 22 in 2010. The GRS 20 items were in turn superseded by GRS 4.3, item 040, in GRS Transmittal 23. The GRS now covers any non-recordkeeping copy in an electronic format.

 

Posted in GRS | Tagged

Records Management Maturity Model

Another item in the OMB/NARA Managing Government Records Directive that we have been working on is item B4. This item called on us to identify a government-wide analytical to help agencies evaluate the effectiveness of their records programs.

We have been working with the Federal Records Council on this project and are now pleased to announce that the Records Management Maturity Model (.xls spreadsheet) and separate user guide (.pdf) are now available on the directive website.

Using an analytical tool such as a maturity model can be a good way to assess your records and information management programs to determine where improvements are needed most. Maturity models provide a framework based on a set of core principles and standards to measure strengths and weaknesses and identify challenges that may undermine effectiveness. It provides a data supported method for planning and assigning resources. There are many good records and information management based models available (both public and private) to choose from. We encourage you to consider these types of tools when assessing your records management program. Feel free to adjust our maturity model to best fit the needs of your program.

Special thanks to the Department of Homeland Security (whose existing RM3i model was used as the starting point for this tool) for their support on this project. Additionally, many thanks to the records officers at the Departments of Justice, Transportation, Interior, and the Securities and Exchange Commission for their contributions to this project. We have also made the maturity model available on the Federal Records Officer Network (FRON).

We are always interested in hearing about new tools and best practices to help agencies.  Also, if you have any questions please leave a comment below or send them to prmd@nara.gov.

Posted in Presidential Memorandum | Tagged

Case for Records Management Course Offering

In response to agency requests, we will host a second offering of The Case for Records Management: Issues for Federal Agency Counsel at Archives I in Washington, DC on Monday, May 11, 2015.

Why attend?

Legal professionals know when business-critical information is missing or inaccessible, an agency risks fines, damage to its reputation, failure to perform its mission and expensive litigation. This half-day briefing by NARA legal and records management staffs will discuss how to build a legally defensible records management program and issues related to e-discovery, records retention and legal holds, and electronic information.

Who should attend?

This briefing is targeted toward general counsels, inspector generals, attorneys and paralegals interested in the management of their own records or are responsible for providing legal direction in Federal agencies regarding agency records management and litigation.

Registration

Because space is limited, attendees must pre-register.  Register at NARA.learn.com or click here:

When:  Monday, May 11, 2015; 9:00 AM – 12:00 PM

Where:  Archives I, Washington, DC – Jefferson Conference Room

Cost:  None

Entry:  Special Events entrance on Constitution Avenue

For persons unable to attend, a recording of a previous briefing is available on our YouTube page:

Part I: Approximately 80 minutes

  • Key points in Federal statutory and regulatory requirements that relate to agency records
  • Best practices in building a defensible records management program
  • Counsel’s role in an agency records management program
  • Challenges and legal issues associated with electronic records

Part II: Approximately 75 minutes

  • The Nexus Between E-Record Keeping and E-Discovery
  • Email, Backup Tapes, Metadata
  • Legal Holds on Records and the Duty of Agency Counsel
  • The Presidential Memorandum and Implementing the Managing Government Records Directive

Posted in Upcoming | Tagged

GRS Project Update

This update comes from the GRS Team.

First, we would like to note that monthly status updates on the GRS project are available on our web page in the “Recent News” section. These status updates include all present and future schedules we are working on or have planned, which GRS Transmittal we expect to issue each schedule in, and the expected month and year of issuance. It also identifies which GRS appraiser is responsible and the current status of the schedule. New monthly updates are usually available sometime the first week of the month. If you have any questions about the status of a schedule, please contact GRS_Team@nara.gov.

We would also like to remind you about the draft Capstone GRS and upcoming public meeting we announced last week.

GRS Project Status

GRS Transmittal 24 is in the home stretch. We are planning to issue this transmittal sometime this June. Currently, four schedules have been signed by the Archivist, one is on its way for signature, and two will come off the Federal Register the beginning of April. The following schedules are planned for GRS Transmittal 24:

2.1 Employee Acquisition Records (DAA-GRS-2014-0002) (pending OPM concurrence)

2.5 Employee Separation Records (DAA-GRS-2014-0004)

2.8 Employee Ethics Records (DAA-GRS-2014-0005)

4.1 Records Management Records (DAA-GRS-2013-0002)

4.2 Information Access and Protection Records (DAA-GRS-2013-0007, DAA-GRS-2015-0002)

6.2 Federal Advisory Committee Records (DAA-GRS-2015-0001)

The next batch of schedules is also well on its way. Three schedules have already gone out for agency review (1.3 Budget Records, 2.4 Employee Compensation and Benefits Records, and 4.4 Library Records). We are currently adjudicating comments on those schedules and want to thank everyone that provided feedback. We really appreciate it and your comments do often result in revisions! Five more schedules are expected to go out for review sometime in April:

2.2 Employee Management Records

2.3 Employee Relations Records

2.6 Employee Training Records

5.4 Facilities, Fleet and Equipment Records

5.5 Mail and Telecommunications Services Records.

So please keep an eye on RM Communications for your chance to review and provide feedback on these draft schedules.

We are also starting work on our final batch of schedules, although these are in the very early stages of development. You may be hearing from us later in the summer or early fall seeking assistance during the development process. This will be the last batch of schedules related to the current update project.

We also want to give everyone a heads up that a survey will be coming out in a few months asking for feedback on the new GRS and how it is working in your agencies.

Posted in GRS | Tagged

DRAFT Capstone GRS Available

General Records Schedule 6.1: Email Managed Under a Capstone Approach 

Given public interest in Federal Government email management, and in conjunction with its publication in the Federal Register, NARA is soliciting comments on General Records Schedule 6.1: Email Managed under a Capstone Approach. To facilitate the comment process, a copy of the review package comprised of the proposed records disposition schedule, accompanying FAQ, and appraisal memoranda, can be downloaded (.pdf).  To aid in public understanding of this GRS, we created a White Paper (.pdf) that provides additional background information on the Capstone approach, appraisal of records at NARA, and the development of this general records schedule.

This records schedule was developed to provide disposition authority for agencies who implement a Capstone approach to managing their email as outlined in NARA Bulletin 2013-02: Guidance on a New Approach to Managing Email Records [Capstone]; and to assist agencies in meeting Goal 1.2 of the Managing Government Records Directive (M-12-18), which requires agencies to manage both permanent and temporary email records in an accessible electronic format by December 31, 2016.

So that we can insure all comments are received and considered, comments must be sent to request.schedule@nara.gov no later than June 1, 2015.

An open public meeting will also be held to solicit comments on this schedule. The meeting will be held on Thursday, May 21, 2015, in the McGowan Theater (basement level), National Archives and Records Administration downtown building, 700 Pennsylvania Avenue, NW (Metrorail’s Yellow or Green lines to the Archives/Navy Memorial station). Please enter on the Constitution Avenue side of the building, the “Special Events” entrance (which is actually the exit for the general public). Additional information on this meeting is published in a separate Federal Register Public meeting Notice.

Posted in Email Management 2.0, GRS | Tagged , ,