Appendix F -- Vital Records

17. VITAL RECORDS

The provisions of the ACF Vital Records Program (VRP) are applicable
agency-wide. The VRP supports the continuation of communications and
information flow as well as the continuation of essential agency
functions. The implementation of this program ensures records that
provide the agency with the information it needs to conduct business
under other than normal operating conditions are identified and
available when needed. Vital records provide an agency with the
information it needs to meet operational responsibilities under abnormal
operating conditions, to resume normal business afterwards (emergency
operating records), and to carry out the agency's essential legal and
financial functions (legal and financial rights), pursuant to 36 CFR
1236.14.

Vital Records are essential agency records needed to meet operational
responsibilities under national or regional emergency or disaster
conditions. Vital records are divided into two categories:

-   [Emergency Operating Records]{.underline} are vital records
    essential to the continued functioning or reconstitution of an
    organization during and after an emergency. Included are emergency
    plans and directive(s), orders of succession, delegations of
    authority, staffing assignments, selected program records needed to
    continue the most critical agency operations, as well as related
    policy or procedural records that assist agency staff in conducting
    operations under emergency conditions and for resuming normal
    operations after an emergency

-   [Legal and Financial Rights Records]{.underline} are vital records
    essential to protect the legal and financial rights of the
    Government and of the individuals directly affected by its
    activities. Examples of these records are records containing proof
    of ownership, financial interest (social security, payroll,
    retirement, insurance, and accounts receivable), legal proceeding
    decisions, contractual obligations, and similar records. These
    records were formerly defined as \"rights-and-interests\" records

    1.  Vital Records Concept of Operations

Through the Vital Records Program, several key processes are implemented
regularly to properly identify records, determine storage, maintenance,
access requirements, and protection of vital records/databases.

*17.1.1 Identification and Maintenance of Vital Records*

Annually, ACF Continuity Program personnel request ACF components to
review their vital files, records and databases to make any updates. The
Vital Records Officer coordinates with the Office of Information
Services (OIS) to provide guidance to ACF components on how to identify,
maintain and store their vital files and records. *\[Note: During COOP
activation and operations, the [Vital Records Officer]{.underline} is
designated the [Records Management Officer]{.underline} (see Section
15.4.1).\]* The primary focus is upon their Emergency Operating Records
which must be accessible at each AOF. Each ACF Component, Program, or
Regional Office is responsible for the identifying requirements to
access their records.

*17.1.2 Back-up and Protection of Vital Records*

Existing ACF IT Disaster Recovery planning identifies that all contents
of the ACF network drives are mirrored at hotsites in Rockville, MD and
Bethesda, MD. The Office of Information Services (OIS) assumes the
responsibility of providing off-site back-up for identified vital files
and records. OIS maintains drive configuration and provides access to
the shared drive during normal operations and COOP operations at the
AOFs. Additionally, on a regular basis, back-up tapes from the ACF
servers are sent to protected facilities at NIH and at facilities in
Chicago, IL.

*17.1.3 Vital Records Training*

The ACF Continuity Manager (or designee) coordinates with the Vital
Records Officer to integrate vital records training into the annual COOP
personnel training. The training instructs COOP team members on how to
identify, maintain vital records, the role vital records plays during a
COOP incident, and how to access vital records at each AOF. In addition
to heightened awareness of vital records, the training enables COOP
personnel to become better managers of vital files, records and
databases within their division(s).

*17.1.4 Maintenance of Vital Records Plan Packet*

The Continuity Manager (or designee) maintains the Vital Records Plan
Packet for ACF. The packet, stored in digital and hardcopy formats,
contains the following:

-   The most current ACF COOP Team Roster with key agency contact
    information

-   Inventory of vital records identified by office components

-   Documentation of electronic access requirements (ACF user ID and
    password)

-   Location of physical keys and access codes for vital records storage

-   Location and directions to each AOF

-   A list of equipment and telecommunications required to access
    specific vital records

-   A copy of the ACF COOP Plan

The electronic version of the Vital Records Plan Packet is located on
the ACF network drive and hardcopy versions of the Packet are located in
ACF staged equipment storage areas at each AOF. The hardcopy packet is
updated annually with the vital records update and the electronic copy
is updated as needed on the network drive and hotsites.

*17.1.5 Periodic Review and Risk Assessment of Vital Records*

Annually, a risk assessment of the vital records is conducted to
identify any irreconcilable risks regarding the identification,
maintenance, securing, and access to vital records. This risk assessment
is scheduled to coincide with COOP related exercises, ensuring that
lessons learned specific to vital records from COOP related exercises
are directly reflected in the risk assessment. Also, access to vital
records is tested semi-annually to ensure the program's capability to
ensure COOP team members have access to vital records.

A periodic review of vital files, records and databases is completed to
coincide with COOP related exercises to identify any emerging issues in
the program. The review of the records is conducted to ensure the
continued effectiveness of the Continuity Manager (or designee) in
facilitating the identification, maintenance, protection, and access to
vital records during COOP operations.

1.  Records Recovery Procedures

Many ACF vital records are stored electronically and on the network
drives; others remain in hard-copy format. For both types of records,
recovery procedures are necessary to restore electronic data and to
restore physical records that may be damaged by fire, water, or other
contaminants. During the operations and reconstitution phases of COOP,
the following processes should be followed to recover damaged records:

-   Notify the Records Management Officer (see Section 15.4.1) and other
    appropriate persons immediately in case of emergency to relate
    details about the nature of the emergency and the level of threat to
    the records

-   Assess the damage to records as soon as possible after the emergency
    and taking steps to stabilize the condition of the records so
    further damage will not occur

-   Assemble a records recovery team of available staff members to
    expedite stabilization of the records (generally only for major
    records disasters)

-   Consult with contractors who provide records disaster recovery
    services if the damage assessment shows a need for their expertise

-   Recover the records and the information that they contain, or
    providing replacement of any lost recorded information when recovery
    is not feasible

-   Resuming normal business using the recovered records and information

-   Create a resource list of disaster recovery firms for your
    geographic area and update the information at least annually

-   Test the records recovery procedures to ensure the recovery runs
    smoothly (including drills on using the equipment, supplies, and
    procedures for vital records recovery)

-   Utilize necessary IT troubleshooting procedures to recover lost
    electronic data from hotsite

-   If troubleshooting lost electronic records fails, retrieve back-up
    tapes from Iron Mountain records storage

Protection and recovery of mission-critical, non-electronic files are
the responsibility of each office, if off-site storage is not practical.
ACF component offices should keep all operational and historical records
in fireproof and waterproof file cabinets, which are available from
several major document protection companies. These cabinets provide
optimal protection for all types of vital records. If vital records,
including electronic media, are damaged by an incident, stabilizing the
environment and removing records will prevent further damage. A contract
service provider under the direction and supervision of the Program
Support Center (PSC), if required, will complete vital record
restoration (dry cleaning and deodorizing).

Following a COOP activation, the Vital Records Officer will contact the
off-site storage locations within the National Archives and Records
Administration (NARA) for delivery of off-site, vital records to the
AOF. In the event that electronic records are unavailable, ensuring
access to hard copy records is critical towards implementing the
essential functions.

1.  Vital Records Inventory

ACF must conduct an inventory of records needed to support emergency
operations. The ACF Vital Records Officer is responsible for conducting
this inventory. In addition, individual ACF components must ensure that
all vital records and systems in their charge are routinely backed up
and maintained at a secured off-site facility. ACF vital records, as
identified by representatives for each essential function, include the
following:

Table 17.3 -- Vital Records Inventory

+------------------------+----------------+--------------+------------+
| Vital File, Record, or | Form of Record | Storage      | M          |
| Database               | (e.g.,         | Location     | aintenance |
|                        | hardcopy,      |              | Frequency  |
|                        | electronic     |              |            |
+========================+================+==============+============+
| ACF COOP Plan          | Elect          | Carried to   | Annually   |
|                        | ronic/Hardcopy | AOF          |            |
+------------------------+----------------+--------------+------------+
| ACF Occupant Emergency | Elect          | Carried to   | Annually   |
| Plan (OEP)             | ronic/Hardcopy | AOF          |            |
+------------------------+----------------+--------------+------------+
| All approved grant     | Elect          | Hotsite/NARA | Annually   |
| applications in the    | ronic/Hardcopy |              |            |
| Office of Community    |                |              |            |
| Service are scanned    |                |              |            |
| and stored offsite     |                |              |            |
+------------------------+----------------+--------------+------------+
| Contracts for security | Elect          | Hotsite      | Annually   |
| services               | ronic/Hardcopy |              |            |
+------------------------+----------------+--------------+------------+
| Contracts with states  | Elect          | Hotsite/NARA | Annually   |
|                        | ronic/Hardcopy |              |            |
+------------------------+----------------+--------------+------------+
| COOP Plans for GATES,  | Elect          | Hotsite/NARA | Annually   |
| AFCARS, CCBIS TANF and | ronic/Hardcopy |              |            |
| the WEB Server         |                |              |            |
+------------------------+----------------+--------------+------------+
| Counsel "getaway bag"  | Elect          | Carried to   | Annually   |
|                        | ronic/Hardcopy | AOF          |            |
+------------------------+----------------+--------------+------------+
| Current grant files    | Elect          | Hotsite/NARA | Annually   |
|                        | ronic/Hardcopy |              |            |
+------------------------+----------------+--------------+------------+
| Delegations of         | Electronic     | Hotsite      | Annually   |
| Authority              |                |              |            |
+------------------------+----------------+--------------+------------+
| Federal register       | Elect          | Hotsite/NARA | As         |
| notices                | ronic/Hardcopy |              | necessary/ |
|                        |                |              | Annually   |
+------------------------+----------------+--------------+------------+
| Form 3971-SF71         | Elect          | Hotsite/NARA | Annually   |
| (perhaps ITAAS backup) | ronic/Hardcopy |              |            |
+------------------------+----------------+--------------+------------+
| Hard copies of         | Hardcopy       | NARA         | Annually   |
| information in PATS    |                |              |            |
+------------------------+----------------+--------------+------------+
| Legal documents (MOUs, | Elect          | Hotsite/NARA | Annually   |
| transmittals)          | ronic/Hardcopy |              |            |
+------------------------+----------------+--------------+------------+
| MOU for Natcher        | Elect          | Hotsite/NARA | Annually   |
|                        | ronic/Hardcopy |              |            |
+------------------------+----------------+--------------+------------+
| MOU for Payment        | Elect          | Carried to   | Annually   |
| Management System      | ronic/Hardcopy | AOF;         |            |
|                        |                |              |            |
|                        |                | Hotsite/NARA |            |
+------------------------+----------------+--------------+------------+
| OA/key contacts phone  | Electronic     | Carried to   | As         |
| list                   |                | AOF          | necessary/ |
|                        |                |              | Annually   |
+------------------------+----------------+--------------+------------+
| Older offline grants   | Hardcopy       | NARA         | Annually   |
| system (might be       |                |              |            |
| useable backup)        |                |              |            |
+------------------------+----------------+--------------+------------+
| OPA fly-away kit       | Electronic     | Carried to   | As         |
| (critical contacts on  |                | AOF          | necessary/ |
| CD)                    |                |              | Annually   |
+------------------------+----------------+--------------+------------+
| ORR Client files       | Elect          | Hotsite/NARA | Annually   |
|                        | ronic/Hardcopy |              |            |
+------------------------+----------------+--------------+------------+
| ORR COOP Plan          | Elect          | Hotsite/NARA | Annually   |
|                        | ronic/Hardcopy |              |            |
+------------------------+----------------+--------------+------------+
| Performance records    | Elect          | Hotsite/NARA | Annually   |
|                        | ronic/Hardcopy |              |            |
+------------------------+----------------+--------------+------------+
| Physical security      | Elect          | Hotsite      | Annually   |
| plans/procedures       | ronic/Hardcopy |              |            |
+------------------------+----------------+--------------+------------+
| Previous Congressional | Electronic     | NARA         | Annually   |
| correspondence, GAO    | (access to HHS |              |            |
| reports, OIG and White | system) or     |              |            |
| House documents        | Hardcopy       |              |            |
+------------------------+----------------+--------------+------------+
| Red Book/Social        | Elect          | Hotsite/NARA | Annually   |
| Security Act           | ronic/Hardcopy |              |            |
+------------------------+----------------+--------------+------------+
| State plans (sent in   | Elect          | Hotsite/NARA | Annually   |
| for ACF review)        | ronic/Hardcopy |              |            |
+------------------------+----------------+--------------+------------+
| Telephone trees        | Elect          | Hotsite/NARA | As         |
|                        | ronic/Hardcopy |              | necessary/ |
|                        |                |              | Annually   |
+------------------------+----------------+--------------+------------+
| Template for reporters | Elect          | Hotsite      | Annually   |
|                        | ronic/Hardcopy |              |            |
+------------------------+----------------+--------------+------------+
| Unsolicited grants log | Elect          | Hotsite/NARA | Annually   |
|                        | ronic/Hardcopy |              |            |
+------------------------+----------------+--------------+------------+
| Volume 45 CFR (4       | Hardcopy       | Hotsite/NARA | Annually   |
| paperback volumes)     |                |              |            |
+------------------------+----------------+--------------+------------+

Additional vital records are stored at off-site NARA facilities; the
current inventory is maintained by the Vital Records Officer.