Update to OMB Circular A-130

The Office of Management and Budget (OMB) released the updated Circular No. A-130, Managing Federal Information as a Strategic Resource late last week. The Circular details policy updates regarding records management, information governance, open data, cybersecurity, privacy, and acquisitions. The Circular had been under revision for several years, and now complements NARA’s regulations and many of the goals and targets outlined in the OMB/NARA Managing Government Records Directive (M-12-18).

Records management is featured more prominently in the new A-130. For example, the Circular states Federal agencies shall:

  • Institute records management programs to document agency activities
  • Ensure the ability to access, retrieve, and manage records throughout their lifecycle
    regardless of form or medium
  • Manage electronic records in accordance with Government-wide requirements
  • Manage all permanent electronic records electronically to the fullest extent possible
  • Manage all email records electronically and retaining them in an appropriate electronic system that supports records management and litigation requirements
  • Submit records retention schedules to NARA for approval in a timely fashion
  • Ensure the proper disposition of Federal records in accordance with an approved records retention schedule
  • Provide training and guidance, as appropriate, to all agency employees and contractors
    regarding their Federal records management responsibilities
  • Designate a Senior Agency Official for Records Management (SAORM) who has overall agency-wide responsibility for records management

Additionally, the Circular requires NARA to:

  • Administer the Federal Records Act and NARA regulations
  • Continue to develop regulations relating to electronic records management
  • Work with agencies to ensure the transfer of permanent Federal electronic records in digital or electronic form to the greatest extent possible
  • Ensure agency compliance with records management requirements, provide records management training, and facilitate public access to high-value Government records
  • Serve as the Executive Agent for the Controlled Unclassified Information (CUI) program (NARA’s Information Security Oversight Office (ISOO))
  • Work with CIO Council to assess how the Federal Records Act impacts information resources management activities

Beyond records management, the Circular has many impacts on information management. We look forward to working with agencies in implementing the goals of the Circular.

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