In this first installment of our series on the new Guide to Inventorying, Scheduling, and Disposition of Federal Records (ISD) we explain the record status of working files and copies. For more information see the Records Basics section of the ISD.
Working files and copies can be challenging to contend with in a digital recordkeeping environment. Are they records or aren’t they?
The key to identifying when a working file is a record is laid out in 36 CFR 1222.12(c).
Working files are records when:
- They were circulated or made available to employees, other than the creator, for official purposes such as approval, comment, action, recommendation, follow-up, or to communicate with agency staff about agency business; AND
- They contain unique information, such as substantive annotations or comments that adds to a proper understanding of the agency’s formulation and execution of basic policies, decisions, actions, or responsibilities.
Sometimes working files include drafts, or copies, of documents.
Copies are records when:
- They are used to conduct business
- They have a function or purpose that is different from other versions of the record
- They are posted on a website (internally or externally)
Working files and copies that are records must have a NARA-approved disposition authority.
If you have any questions, please contact your agency’s assigned appraiser.
