Roles and Responsibilities for Records Management Programs

We frequently receive questions about the roles and responsibilities for Senior Agency Officials for Records Management (SAORM) and Agency Records Officers. This post is intended to clarify their differences.

The head of each agency has overall responsibility for establishing and maintaining an active and efficient records management program. NARA recognizes two formally designated officials that carry out program responsibilities on behalf of the Agency Head — the SAORM and Agency Records Officer.

We released NARA Bulletin 2017-02 to consolidate SAORM requirements from previous directives and guidance. The Bulletin provides an in-depth explanation of SAORM responsibilities for ensuring agency compliance with all applicable records management statutes, regulations, and NARA and Office of Management and Budget (OMB) policies.

SAORMs serve as an executive sponsor with broad responsibility for the agency records management program. The incumbent primarily operates at the strategic level to establish an agency records management program’s vision, goals, and objectives in alignment with NARA and agency-specific strategic plans. SAORMs ensure their records management programs receive adequate resources to complete their mission.

Agency Records Officers manage and implement agency records management programs. Their focus is primarily operational, ensuring that the agency is in compliance with the  foundational requirements for records management. Agency Records Officers work closely with NARA and serve as records management advisors to SAORMs.

Due to many variables such as organizational size, structure, culture, or other elements, an Agency Records Officer may be required to perform more of the strategic, high-level SAORM responsibilities referenced above. In other limited instances, there are micro agencies that have an Agency Records Officer that also serves as the SAORM.

SAORM and ARO Responsibilities: 

The table below is a list of primary SAORM and Agency Records Officer responsibilities. They are derived from existing regulations, policies, and current practices, including 44 U.S.C. Chapter 31, 36 CFR SubChapter B, and NARA Bulletin 2017-02.

Item Senior Agency Official for Records Management Agency Records Officer
1. Provides agencies with a clear vision and strategic direction to modernize agency records management program(s). Interprets and advises senior agency officials on existing, new, or potential records management statutes, regulations, or other legal requirements impacting the agency. May also be responsible for strategic direction in micro agencies.
2. Ensures adequate records management resources are embedded into the agency’s Strategic Information Resources Management (IRM) Plan Integrates records management and archival requirements into the design, development, and implementation of electronic information systems.
3. Provides adequate budgetary and personnel resources to implement an efficient and effective agency records management program. Works with internal stakeholders to identify budgetary, personnel, and system requirements. Participates in the Capital Planning and Investment Control process.
4. Establishes, where appropriate, agency-level records management program offices to ensure adequate management of routine mission support functions. Manages department-level and/or agency-level records management program office(s). Routine mission functions may include the transfer of permanent records to NARA, records storage and retrieval, development and update of records schedules, management of litigation holds or records freezes, and administration of internal program evaluations, including performance measurements where possible.
5. Ensures the designation of records management responsibilities in each program (mission area) and administrative area to ensure the incorporation of record-keeping requirements and records maintenance, storage, and disposition practices into agency programs, processes, systems, and procedures. Implements and assesses each program area’s record-keeping practices, including but not limited to records maintenance, storage, and disposition practices into agency programs, processes, systems, and procedures.
6. Ensures agency staff are informed of and receive training on their records management responsibilities. Develops and administers agency-wide records management training. See NARA Bulletin 2017-02.
7. Issues agency directives, policies, and initiatives supporting OMB and NARA Directive goals and subsequent guidance for transitioning towards a fully electronic government. Carries out records management modernization initiatives resulting from new records management directives, policies, or standards.
8. Ensures agency compliance with NARA requirements for electronic records, including the electronic management of all permanent electronic records to the fullest extent possible for eventual transfer and accessioning by NARA. Monitors and reports compliance with NARA and agency-specific requirements for the management and transfer of permanent electronic records.
9. Directs agency efforts across program areas to ensure email records are managed electronically and retained in an appropriate electronic information system that supports records management and litigation requirements, including the capability to identify, retrieve, and retain the records consistent with NARA-approved disposition authorities and regulatory exceptions. Establish procedures and guidance for email records. Coordinates with IT to ensure systems adhere to records management retention and disposition policies.
10. Ensures policies, procedures, and systems are in place and configured to protects records against unauthorized removal or loss. Coordinates with IT to ensure records management considerations for systems access and security controls are implemented. Participates in agency reporting processes involving unauthorized removal or loss of records and formally notifies NARA.
11. Directs the use of agency-wide records management internal controls, self-assessments, and remediation plans. Implement agency-wide records management internal controls to ensure records, regardless of format or medium, are properly organized, classified or indexed, and made available for use. Oversees self-assessment and remediation activities.
12. Reviews NARA’s annual Records Management Self-Assessment analysis and risk ratings to determine vulnerabilities and identify plans for improvement. Supports SAORMS and/or leads in gathering data and developing responses to NARA’s oversight and reporting activities.

Additional information on records management responsibilities can be found in OPM’s Records and Information Management, 0308 Position Classification Flysheet, and OMB Circular No. A-130, Managing Information as a Strategic Resource, paragraph 5(h).

Language identifying roles and responsibilities for SAORMs and Agency Records Officers will be considered in future updates to NARA regulations.

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One thought on “Roles and Responsibilities for Records Management Programs

  1. Great post and very timely as agencies prepare their 2017 RMSA and email submissions! Thank you!

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