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Electronic Records Electronic Records Management (ERM)Management (ERM)

Scheduling Information Scheduling Information Systems With the National Systems With the National ArchivesArchives

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ERM AuthoritiesERM Authorities

NARA, 36 CFR 1234, Electronic Records Management

NARA, 36 CFR 1228.270, Disposition of Federal Records

GSA, Title 41 CFR, Part 102-193: Creation, Maintenance, and Use of Records

OMB Circular A-130, Management of Federal Information Resources,

E-Government Act of 2002 (as amended)

The Paperwork Reduction Act (1995)

Government Paperwork Elimination Act

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OverviewOverview

NARA requires that all Federal Agency’s throughout the Federal Government Schedule their various Information Systems. It is estimated that your offices may need a period of approximately six months to complete the suggested scheduling steps involved in scheduling systems and an additional six months for NARA to approve the schedules. As you can see, the earlier one gets started in the process the better.

This guidance is meant to provide you with some suggested procedures, form(s) (primarily NARA Form SF 115), and assistance for this important NARA requirement.

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Basic Steps

(1) Conduct a system’s inventory of all Information Systems throughout your Agency. You may need input from system implementation personnel your CIO Office for their assistance. In some cases the CIO Office may have a knowledge of the various Systems and point of contacts (POC).

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Purpose of the InventoryPurpose of the Inventory

The purpose of this information systems inventory is to establish current status of electronic records (and information systems) maintained in your computing environment. It may very well be necessary to update and implement a revised Electronic Records Disposition Schedule (ERDS) which allows the Agency to legally dispose of temporary records and effect timely transfer of permanent records to NARA.

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Basic Steps (Cont.)

(2) Meet with your office management/staff to discuss and draft respective records disposition instructions. If records that will be maintained in your information systems have been previously scheduled, refer to your Disposition Schedules and start with retention periods stated there. Once your office management/staff reaches consensus on the disposition instructions, send recommendations package to your Agency Records Division for review. Once this is cleared by the Records Division the recommendations should be sent General Counsel (GC) Office or the Legal Office to ensure recommended disposition takes into account possible legal holds levied on your records of which neither, your office or Records Office may not be aware of.

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Basic Steps (Cont.)

(3) Once GC clears dispositions instructions, revise if necessary and resubmit package to the Records Office.

(4) The Records Staff should finalize the package by completing an SF 115, Request for Records Disposition Authority, and submit package to NARA for approval

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What are the benefits of using records What are the benefits of using records schedules?schedules?

Using records schedules:

Ensures that the important records are organized and maintained in such a way as to be easily retrieved and identifiable as evidence of the program's activities, especially in the event of an audit, a Freedom of Information Act (FOIA) request, or a discovery in a lawsuit.

Conserves office space and equipment by using filing cabinets to store only active paper records and conserves server space by using tapes, disks, and other off-line storage media for electronic records.

Saves money by moving inactive files to off-site storage areas until they are ready

for final disposition. Helps preserve those records that are valuable for historical or other research

purposes. Controls the growth of records in offices through the systematic disposition of

unneeded records.

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What is an agency schedule?What is an agency schedule?

Agencies are required by law to develop records schedules for all of their records not covered by the GRS (44 U.S.C. 3303). After reviewing their records, agencies submit the schedules for NARA approval on an SF 115, Request for Records Disposition Authority.

The SF 115 contains descriptions of record series or systems and disposition instructions for each. These instructions specify when the series is to be cut off, when eligible records are to be moved to off-site storage, when eligible temporary records must be destroyed or deleted, and when permanent records are to be transferred to the National Archives.

Schedules may not be implemented until NARA has approved them. Some schedules, especially those containing records relating to financial management, claims, and other related matters, must also be approved by the General Accounting Office (GAO) (44 U.S.C. 3309) before NARA will approve them.

Once approved by NARA, retention periods in the schedules are mandatory and authorize the systematic removal of unneeded records from Federal offices.

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What is an Agency schedule (Cont)

Once the inventory is completed and submitted to the Electronic Records (E-Records) manager, the process involves coordination between the E-Records manager, system owners, and the National Archives and Records Administration (NARA) to:

Draft disposition instructions, and; Schedule site visits by the archivist to check systems, records,

and resolve any issues

Afterwards, the scheduling of the disposition instructions goes through an approval process by NARA (and GAO if financial system/records) before they can be incorporated into the ERDS and made mandatory.

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SchedulesSchedules

Does Your Agency have Disposition Schedules

General Records Schedules (GRS)

GRS 20, Electronic Records

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The End

Questions, Comments, Assistance????

Contact Ken Matthews

E-Records Project Manager

chapkenmat@gmail.com