doc_fn:    draftord/241/g241x-1.html
DocType:   Draft
ID:        DOE G 241.X-1
Title:     Electronic Records Management Guide
Summary:
Org:       HR
Date_Issue: 03/10/1998
Date_Close:
VdkVgwKey: draftord-2
Directive: 241.X
Text:

          DATE:     March 11, 1998

          TO:       DIRECTIVES POINTS OF CONTACT

          FROM:     HOWARD LANDON        /s/
                    OFFICE OF INFORMATION, RESOURCES AND RECORDS
          MANAGEMENT (HR-41)

          SUBJECT:  DOE G 241.X-1, ELECTRONIC RECORDS MANAGEMENT GUIDE for Use
          with 36 CFR Chapter XII - Part 1234

The attached revised Guide, developed by the Office of Information Management (HR-4), is
being forwarded for  review and comment by your organization.  Its purpose is to provide
guidance to assist in the implementation of 36 CFR - Part 1234, Electronic Records
Management.  The revision updates and formally brings into the Directives System guidance that
had previously been circulated within the Department's records management community.

Comments on the proposed revision  are due by April 11, 1998.  MAJOR ISSUES and
SUGGESTED COMMENTS should be designated as such when submitted.  MAJOR ISSUES
shall be limited to instances where the directive in its entirety, or one or more of its
requirements, would have an adverse effect on DOE policy objectives, mission accomplishment,
economy, efficiency, or other management concerns that would preclude its publication.  The
following procedures shall be followed for the submission of comments:

Headquarters and Field Elements:

Submit comments to Howard Landon, by mail to HR-41, Room 8F-084, FORRESTAL; by
facsimile to (202) 586-1972; or by e-mail to howard.landon@hq.doe.gov. 

If there are any questions concerning the content of the draft DOE G 241.X-1, contact Mr.
Landon at (202) 586-6344.  Contact Ms. Gail Cephas at (202) 586-1049 for questions pertaining
to the Directives System or the processing of this draft directive.

Attachment

 DOE G 241.X-1

                                 

                       ELECTRONIC RECORDS
                       MANAGEMENT GUIDE 
                          FOR USE WITH
                 36 CFR CHAPTER XII - PART 1234 

                   U.S. DEPARTMENT OF ENERGY
         Deputy Assistant Secretary for Human Resources
                                

                                             Distribution:                                Initiated By:
                                                  All Departmental Elements                         Office of Human Resources and
                                                  Administration                                                                 
                                                  

                  ELECTRONIC RECORDS MANAGEMENT

   1. PURPOSE. This Guide implements 36 Code of Federal Regulations (CFR) Part 1234,
   "Electronic Records Management," and provides non-mandatory guidance for the
   organization, maintenance, and disposition of electronic records.  These regulatory
   requirements may not be disregarded because of any omission, or explanation provided in
   this Guide.  Nothing in this Guide is intended to revoke, modify, change, add, or impose
   new requirements not otherwise imposed by regulation.

   2. APPLICABILITY.  This Guide is intended for use by all DOE Elements (including their
   contractors) for electronic records maintenance and disposition. 

   3. IMPLEMENTATION.  To implement this Guide, DOE Elements may discontinue
   electronic records systems currently in place at their respective next scheduled cutoff date. 
   Electronic records lacking scheduled cutoff dates should have such dates established for
   adoption of the guidelines presented in this Guide.

   4. EXPLANATION OF CHANGES.  DOE is required to establish and maintain an electronic
   records scheduling program in accordance with 44 United States Code (U.S.C.) 3102,
   3301, and 3303 to control the creation and disposition of records accumulated. 
   Accordingly, records disposition schedules are under development for each series of
   electronic records in DOE or contractor custody.  The schedules describe the various
   electronic records series and provide instructions for their cutoff, retirement to a Federal
   records center, destruction, or permanent retention.  This Guide recommends procedures
   for the management of electronic records from their creation through their disposition.

   5. REGULATIONS.  

         a. Requirements. 36 Code of Federal Regulations PART 1234, "Electronic Records
      Management." contains the primary regulations imposing requirements on the
      Department's electronic records.  These regulatory requirements may not be
      disregarded because of any omission, or explanation provided in this Guide.  Nothing is
      this Guide is intended to revoke, modify, change, add, or impose new requirements not
      otherwise imposed by regulation.

         b. Reporting.  This Guide provides information to assist in complying with regulations.

         c. Assistance.  For information regarding this Guide, contact Howard Landon, (202) 586-
      6344.

   6. CRIMINAL PENALTIES.  In Title 18 U.S.C. Chapter 101, Records and Reports, Section
   2071, "Concealment, Removal, or Mutilation," criminal penalties are provided for willful
   and unlawful concealment, removal, mutilation, obliteration, falsification, or destruction of
   Federal records.

   7. FORMS.  Use of the following forms is appropriate: 

         a. "Records Maintenance and Disposition Instructions," DOE F 1324.14 (Optional),

         b. "Records Transmittal and Receipt" (Standard Form 135), and 

         c. "Request for Records Disposition Authority (Standard Form 115).

   8. CLASSIFIED RECORDS.  Approved electronic records disposition schedules are required
   for classified electronic records.  Classified information in electronic form is a record. 
   Classification requirements must be followed regarding any aspect of the creation,
   maintenance, or disposition of classified electronic records.  For the security requirements
   and procedures affecting classified electronic records, see DOE O 471.2, INFORMATION
   SECURITY PROGRAM; DOE M 471.2-1, MANUAL FOR CLASSIFIED MATTER
   PROTECTION AND CONTROL; and their accompanying contractor requirements
   documents. 

   9. TRAINING.  This Guide should be of use to those interested in obtaining additional
   information concerning implementation of the regulatory requirements that affect
   electronic records management.  Instructors may also find this Guide useful in
   supplementing other training provided in this subject matter area. 

      10.   SUMMARY.  This Guide consists of five chapters that explain and recommend systems
      and techniques for use in managing electronic records.

                            CONTENTS

              
CHAPTER I, OVERVIEW

                   1.   Purpose. . . . . . . . . . . . . . . . . . . . . .I-1
              2.   Authority. . . . . . . . . . . . . . . . . . . . .I-1
                   3.   Implementation and Management. . . . . . . . . . .I-1
              4.   Summary. . . . . . . . . . . . . . . . . . . . . .I-1
              5.   References . . . . . . . . . . . . . . . . . . . .I-1
              6.   Definitions. . . . . . . . . . . . . . . . . . . .I-2

CHAPTER II, CREATION AND RECEIPT

                   1.   Creation of Electronic Records . . . . . . . . . II-1
                   2.   Receipt of Electronic Records. . . . . . . . . . II-2
                   3.   Authentication/approval. . . . . . . . . . . . . II-3
                   4.   Submission of Electronic Records . . . . . . . . II-3

CHAPTER III, USE AND MAINTENANCE

              1.   Records Storage and Maintenance. . . . . . . . .III-1
                   2.   Records Retrieval. . . . . . . . . . . . . . . .III-2
                   3.   Records Protection . . . . . . . . . . . . . . .III-2
                   4.   Records Security . . . . . . . . . . . . . . . .III-2
                   5.   Judicial Use . . . . . . . . . . . . . . . . . .III-3

CHAPTER IV, DISPOSITION

                   1.   Inventorying Electronic Records. . . . . . . . . IV-1
                   2.   Applying General Records Schedules . . . . . . . IV-1
                   3.   Scheduling Records . . . . . . . . . . . . . . . IV-2
                   4.   Schedules. . . . . . . . . . . . . . . . . . . . IV-3
                   5.   Disposition of Unique Electronic Records . . . . IV-3

CHAPTER V, SPECIAL ISSUES

              1.   Legal Admissibility. . . . . . . . . . . . . . . .V-1
              2.   Multiple Copies, Revisions, Drafts, and Backups. .V-1
              3.   Imaging Systems. . . . . . . . . . . . . . . . . .V-2
              4.   Quality Assurance/ Records . . . . . . . . . . . .V-3
              5.   Voice Mail . . . . . . . . . . . . . . . . . . . .V-3
              6.   Audio/Video Conferencing/Recordings. . . . . . . .V-4
              7.   Data Portability/Migration . . . . . . . . . . . .V-4
                   8.   E-mail Records . . . . . . . . . . . . . . . . . .V-5
                   9.   Electronic Record System Documentation . . . . . .V-8
                   10.  Information Systems as Records . . . . . . . . . V-10
                   11.  Complex Electronic Records . . . . . . . . . . . V-11

ATTACHMENT 1, DISPOSITION ISSUES FOR PARTICULAR KINDS
OF ELECTRONIC RECORDS. . . . . . . . . . . . . . . . . . . . .1-1
                            CHAPTER I

                             OVERVIEW
                                
   1. BACKGROUND.  Methods of creating, capturing, editing, maintaining, transmitting,
   retrieving, and storing Federal records are continuously changing.  The result is an increase
   in the volume and complexity of electronically created and stored information. 
   Records can now be found on a variety of electronic media floppy disks, hard disks,
   network disk drives, optical disks, and magnetic tapes.  Records may include text,
   graphics, sound recordings, or video recordings generated from a variety of software. 
   Complex records may be composed of multiple computer files stored in multiple locations
   across the computing environment.  The proliferation of electronic information has resulted
   in electronic copies of record and nonrecord material existing simultaneously on stand-
   alone workstations, local area networks, and computer system backup tapes.

      Electronic information and its proliferation must be managed properly to ensure that
    electronic records and nonrecords are protected and retained in accordance with approved
   records disposition schedules.  To achieve this goal, records managers should coordinate
   their programs with originators of electronic records, organizational administrators,
   program managers, and computer systems managers.  The intent is to ensure that all
   electronic information  including drafts of documents, deleted files, and extraneous copies
   of records and nonrecord material are identified and properly dispositioned.  The chapters
   in this Guide address the creation, receipt, use, maintenance, and disposition of electronic
   records.  This information may be useful in developing and implementing professional
   records management programs.

2. AUTHORITY.

           a.   44 U.S.C. 3101, "Records Management by Agency Heads,"  requires the head of
        each Federal agency to make and preserve records containing adequate and proper
        documentation of the organization, functions, policies, decisions, procedures, and
        essential transactions of the agency.  These records furnish the information
        necessary to protect the legal and financial rights of the Government and persons
        directly affected by the agency's activities.

           b.   44 U.S.C. 3102, "Establishment of Program Management," requires the head of
        each Federal agency to establish and maintain an active, continuing program for the
        economical and efficient management of the agency's records.

           c.   36 CFR Chapter XII - Subchapter B prescribes policies for Federal agencies'
        records management programs relating to records creation and maintenance,
        adequate documentation, and proper records disposition.
 
           d.   36 CFR 1234, "Electronic Records Management," establishes the basic
        requirements related to the creation, maintenance, use, and disposition of electronic
               records.       

   3. IMPLEMENTATION AND MANAGEMENT.  When developing records management
   programs, records managers should consider the issues and concepts presented in this
   Guide.  Performing program assessments, conducting records inventories, and providing
   training courses are examples of activities that can benefit from this guidance. 

   4. REFERENCES.  Guidance from several Federal agencies was used in the development of
   this Guide.  These agencies include the DOE, the National Archives and Records
   Administration (NARA), the General Services Administration (GSA), and the Office of
   Management and Budget (OMB).  In addition to the references authorizing records
   management programs (this chapter, Paragraph 2, "Authority"), the following references
   provide useful information:

           a.   Title 18 U.S.C., Chapter 101, "Records and Reports," Section 2071, "Concealment,
        Removal, or Mutilation," provides criminal penalties regarding the misuse of
                    Federal records.    

           b.   Title 44 U.S.C 2901, "Definitions," Paragraph (2) defines records management.

      c.   44 U.S.C. 3301, "Definition of records."

           d.   Title 44 U.S.C., Chapter 33, "Disposal of Records," Section 3303, "Lists and
        Schedules of Records to be Submitted to the Archivist by Head of each
        Government Agency," provides procedures for the proper disposition of Federal
        records.
   
           e.   36 CFR 1228, "Disposition of Federal Records," provides policies and establishes
        standards, procedures, and techniques for the disposition of Federal records.

           f.   36 CFR 1234, "Electronic Records Management," establishes the basic
        requirements related to the creation, maintenance, use, and disposition of electronic
        records.

           g.   General Records Schedule (GRS) 20, "Electronic Records," provides disposition
        authority for certain types of electronic records and specific hard-copy (paper) or
        microform records that are integrally related to electronic records.

           h.   GRS 23, "Records Common to Most Offices Within Agencies," provides
        disposition authority for records common to most offices within agencies.

           i.   OMB Circular A-130, Appendix III, "Security of Federal Automated Information
        Resources," establishes policy for the management of Federal information
        resources.

           j.   NARA, "Managing Electronic Records" (Instructional Guide Series), contains
        directions to ensure proper recordkeeping for electronic information systems,
        including system documentation, such as operational procedures, data integrity
        controls, database definitions, and computer code documentation.

           k.   DOE O 200.1, INFORMATION MANAGEMENT PROGRAM, of 9-30-96, 
        provides policy and requirements for managing information in the Department.
   
           l.   DOE G 1324.5B.1, IMPLEMENTATION GUIDE FOR USE WITH 36 CFR
        CHAPTER XII SUBCHAPTER B RECORDS MANAGEMENT, of 7-19-96,
        which provides guidance for the organization, maintenance and disposition of
        records for the Department of Energy.

           m.   "Computer Security Act of 1987" (40 U.S.C. 759; Public Law 100-235) provides
        for a computer standards program within the NIST, to provide for (among other
        purposes) Government-wide computer security, and security training for persons
        involved in the management, operation, and use of Federal computer systems.

           n.   U.S. Department of Commerce, National Institute of Standards and Technology,
        Federal Information Processing Standards are published to improve the use and
        management of computers and automatic data processing systems in the Federal
        Government.

5. DEFINITIONS.

           a.   Accession.  The transfer of the legal and physical custody of permanent records
        from an agency to the National Archives.

           b.   Administrative Records.  Records accumulated by an individual offices that relate
        to the office's internal administration or housekeeping activities rather than to its
        assigned mission functions.  In general, these records relate to office organization,
        staffing, procedures, and communications; expenditure of funds, including budget
        records; day-to-day administration of office personnel including training and travel;
        supplies office services, and equipment requests and receipts; and the use of office
        space and utilities.  Administrative records may also include copies of internal
        activity and workload reports (including work progress, statistical, and narrative
        reports prepared in the office and forwarded to higher levels) and other materials
        that do not serve as unique documentation of the office's programs.

           c.   Administrative Value.  The usefulness of records in conducting an agency's current
        business.  Includes fiscal value and legal value, which are analyzed separately when
        records are evaluated for disposition.

           d.   Audiovisual Records.  Materials that meet the definition of a Federal record and
        that are in pictorial or aural form, including still and motion pictures, graphic
        materials, sound and video recordings, and combinations of media, such as
        slide-tape productions. 

           e.   Authentication.  The act of attesting that the information contained in a record is a
        legible, complete, and accurate representation of work performed.

           f.   Backup.  A copy of a computer file to be used if the original is lost, damaged, or
        destroyed.

           g.   Codebook.  In electronic records, a guidebook identifying and explaining the codes
        used in a computer file or database.

           h.   Copy.  In electronic records, the result or action of reading electronic data from a
        source, leaving the source data unchanged, and writing the same data elsewhere on
        a medium that may differ from the source.

           I.   Database.  In electronic records, a set of data, consisting of at least one file or a
        group of files, usually stored in one location, which may be made available to
        several users at the same time for various applications.

           j.   Data File.  An organized collection of related data, usually arranged in logical
        records that are stored together and treated as a unit; related numeric, textual, or
        graphic information that is organized in a strictly prescribed form and format.

           k.   Discoverable.  Recorded information that may be obtained by litigation
        opponent(s).

           l.   Disposition.  Actions taken regarding records no longer needed in current office
        space.  These actions include transfer to agency storage facilities or Federal records
        centers, transfer from one Federal agency to another, transfer of permanent records
        to the National Archives, and disposal of temporary records.

           m.   Disposition Authority.  Legal approval empowering an agency to transfer
        permanent records to the National Archives or carry out the disposal of temporary
        records.
   
           n.   Electronic Records.  Any information stored in a form that only a computer can
        read or process and that satisfies the definition of a Federal record.

           o.   E-mail Record.  An abbreviation for electronic mail; a message sent or received via
        an electronic mail system with its transmission/receipt data and attachments and
        that meets the criteria of a Federal record.

           p.   File Layout.  In electronic records, the arrangement and structure of data in a file,
        including the sequence and use of its components.

           q.   Information System.  A discrete set of information resources organized for the
        collection, processing, maintenance, transmission, and dissemination of
        information, in accordance with defined procedures.

           r.   Media.  The physical forms of recorded information, including film, computer
        disks, computer tapes, and any other materials on which information can be
        recorded.

           s.   Nonrecord.  U.S. Government-owned informational materials excluded from the
        legal definition of records.  Includes extra copies of documents kept only for
        convenient reference, stocks of publications and processed documents, and library
        or museum materials intended solely for reference or exhibition.  Also called
        nonrecord materials.

           t.   Permanent Records.  Records appraised by NARA as having sufficient historical or
        other value to warrant continued preservation by the Federal Government beyond
        the time they are needed for administrative, legal, or fiscal purposes.

           u.   Record.  All books, papers, maps, photographs, machine-readable materials, or
        other documentary materials, regardless of physical form or characteristics, made
        or received by an agency of the United States Government under Federal law or in
        connection with the transaction of public business.  Records are preserved or are
        appropriate for preservation by an agency or its legitimate successor as evidence of
        the organization, functions, policies, decisions, procedures, operations, or other
        activities of the Government or because of the value of their information.

           v.   Recordkeeping.  The act or process of managing records from their creation, or
        receipt, through their processing, distribution, organization, storage, and retrieval to
        their ultimate disposition.

           w.   Recordkeeping Requirements.  As used by NARA, statements in statutes,
        regulations, directives, or other issuances specifying the records to be created or
        received and maintained.

           x.   Records Management Program.  The planning, controlling, directing, organizing,
        training, promoting, and other managerial activities involved with respect to
        records creation, records maintenance and use, and records disposition in order to
        achieve adequate and proper documentation of the policies and transactions of the
        Federal Government and effective and economical management of agency
        operations.

           y.   Records Schedule.  A document providing authority for the final disposition of
        recurring or nonrecurring records.  Also called records disposition schedule,
        records control schedule, and records retention schedule.
                          CHAPTER II 
                                
                      CREATION AND RECEIPT

The way in which human-readable records are created does not pose an issue for future use
because no special device or knowledge is required to read them.  The opposite is true of
machine-readable electronic records.  Creation of electronic records is dependent on the software
application, hardware, operating system, media, and file formats that make up the computer
system in use.  Therein lies the special nature of electronic records in records management. 
Records managers should be concerned with, and help employees understand that, the methods
used to create records and the documentation of the system that created the records are important
and will dictate the requirements for retrieving, reading, and using records in the future.

   1. CREATION OF ELECTRONIC RECORDS.

           a.   Types of Electronic Records.  Electronic records may be created as text, data, or
        images.  They may be produced in a variety of media and file formats.  Proper
        records management planning and control of these variables should ensure ongoing
        preservation and usability of records in electronic form.

           b.   Two Main Groups.  Electronic records can be described as either magnetic or 
        optical media.  Magnetic media are written and read using a magnet.  Optical media
        use lasers.  Examples are provided in the two columns below:

           Magnetic Media                       Optical Media

                                           3.5-inch diskettes                   CD-ROM
                                      5.25-inch disks                      Optical tape cartridge
                                           magnetic tape                        12- and 14-inch disc platters
                                      tape cartridges                      3.5-inch optical diskettes
           magnetic cartridge    

           c.   Current Media.  Although the media listed above are currently in use, new media
        and formats are constantly being created and adopted and existing ones dropped. 
        Users, computer operations administrators, and records management personnel
        should constantly reevaluate electronic media to determine its continued suitability
        for business or archival purposes.  Each medium has a different life span, and
        records may need to be transferred to a new medium or format to ensure the
        information remains accessible.

           d.   Selection.  Proper selection of software, media, and file formats for the creation of
        electronic records will ensure that records can be adequately read, retrieved, and
        duplicated until they are no longer needed.  Instructions and information for
        retrieval and/or preservation must be documented to ensure long-term readability. 
        Such information might include the physical and technical characteristics of the
        records, hardware and software platforms required to read the records, form of the
        data, and any other technical information needed to read or process the records.

           e.   Text-Data Files.  Text-data files are computer-readable files storing simple text
        characters that can be displayed or printed, usually in American Standard Code for
        Information Interchange (ASCII).  Other computing standards for text characters
        exist, but are less common, such as the Extended Binary Coded Decimal
        Interchange Code (EBCDIC) used on some mainframe computer systems.

                       (1)    ASCII.  Electronic documents created or stored with ASCII text can only
               be enhanced with additional embedded ASCII text characters (tags) to add
               to the document some basic display features, print formatting, or search
               capability.  These tagged text file formats include Hypertext Markup
               Language (HTML) and Standard Generalized Markup Language (SGML). 
               Electronic documents stored as text files are less dependent on a particular
               computer application software to view or print the document than
               electronic documents stored as binary data files.

                       (2)    Binary Data Files.  Binary data files are computer-readable files that store
               data formatted as 1s and 0s in a manner that requires a specific application
               software to display, print, or use the data in the file.  Data can be stored in
               binary data files by word processors, spreadsheets, databases, graphics
               programs, or document imaging systems in either proprietary or
               non-proprietary data formats.  Types of binary data file formats include
               Rich Text Format (RTF), Computer Graphics Metafile (CGM), Portable
               Document Format (PDF), and Tagged Image File Format (TIFF).

           f.   Computer System Documentation.  To ensure the long-term viability of electronic
        records created by computer software, computer system documentation will need to
        be available to anyone who might need to read or recreate the record.  In addition,
        imaging systems that use optical disk media for records storage and contain
        permanent records for accessioning into NARA should conform to NARA
        standards.  NARA regulations, directives, bulletins, and handbooks stating current
        policies can be obtained from NARA prior to developing or purchasing an imaging
        system that will contain permanent records.

   2. RECEIPT OF ELECTRONIC RECORDS.  

           a.   Custody.  In the Federal contracting environment, the custody of electronic records
        is frequently reassigned from one organization to another in the course of closing or
        changing contracts.  Electronic records received but not created by an organization
        should follow the same guidelines as those created by the organization.  However, 
        receiving organizations not involved in creation of the system or the records have
        no control over the methods used to create the records.  If electronic records
        received  have inadequate documentation, or if they require a hardware or software
        platform that is unavailable or obsolete, the records are rendered useless.  The value
        of the records should be compared against the cost of obtaining or recreating
        software and hardware to enable the records to be read and used.

           b.   E-mail Records.  Internal e-mail policies, procedures, and systems for managing e-
        mail as records should be designed to accommodate e-mail messages received from
        outside.  Such messages should not be treated any differently than internally
        generated messages.  If an e-mail message received from outside meets the
        definition of a Federal record, it should be handled as a Federal record within the
        organization's internal system.

   3. AUTHENTICATION/APPROVAL.  All records requiring authentication must be dated
   and either signed, initialed, stamped, or otherwise attested to their authenticity. 
   Authentication is a confirmation that the record is accurate, complete, and appropriate to
   the actions taken.  For paper records, authentication is usually easy to verify because most
   forms of hard copy record authentication are visible on the front of the record.  Methods of
   authenticating electronic records, however, are more varied.  These methods include, but
   are not limited to the following:

           a.   Hard Copy.  Authentication of a hard-copy document that accompanies the
        electronic media.  This hard-copy document can be a transmittal or information
        sheet containing information about the electronic record that can be used for
        identifying, retrieving, or indexing.

           b.   Label.  Authentication of a label attached to the media.

   c.   Signature Link.  Linking of a digital signature to the electronic file/document.
   
           d.   Authentication.  Design of a unique location-specific procedure for authentication
        of electronic records.

   4. SUBMISSION OF ELECTRONIC RECORDS.  In organizations employing centralized
   files, electronic records should be submitted as follows:  

           a.   Indexing Requirements. Electronic records should have sufficient accompanying
        information to allow correct indexing of the records.  The records should have an
        external label affixed, or include documentation that contains the following:

                  names or narrative description of the information submitted;
                              date the information was generated;
                              names of person or organization that generated the information; and
                              identifying numbers or codes, such as serial or volume number.

           b.   Additional Documentation.  Electronic records submitted should include all
        available documentation including any special instructions for retrieval or
        preservation, physical and technical characteristics of the records, hardware and
        software platforms required to read the records, a description of the form of the
        data, and any other technical information needed to read or process the records.

           c.   Duplicates.  Electronic records should be submitted in duplicate so that records
        maintenance personnel can place one copy in storage and have one copy available
        for retrieval.  Generally, records maintenance personnel will not have hardware and
        software to read or duplicate electronic records.  It should be a requirement that
        users submitting electronic records are responsible for providing any equipment
        necessary to read and process the records.

           d.   Missing Documentation.  Generally, electronic records submitted in compliance
        with the above criteria will be accepted by records maintenance personnel.  On the
        other hand, records maintenance personnel should not accept records with
        insufficient information until that information is provided. 

           e.   Preservation Responsibility.  Records maintenance personnel who accept an
        electronic record also accept responsibility for continued preservation of the record. 
        Appropriate policies, procedures, and standards should be developed to ensure the
        media are properly stored, including but not limited to proper environmental
        storage conditions for temperature and humidity; cleaning, rewinding, retensioning,
        and recopying magnetic tapes; migration; and periodic checking of the electronic
        records to identify and rectify any degradation.
                          CHAPTER III
                                
                      USE AND MAINTENANCE

It is important that the integrity of all Federal records be maintained throughout their life cycle. 
Capturing information electronically imposes new requirements for the records including their
handling, use, and maintenance in the office, which must occur concurrently with the protection
of their integrity.  The basic records management principles applied to paper records can be
applied to electronic records.

1. RECORDS STORAGE AND MAINTENANCE.

           a.   Necessary Criteria.  Appropriate media and systems for storing Federal records
        throughout their life cycle should 

                       (1)    permit easy retrieval in a timely fashion;

                       (2)    facilitate distinction between record and nonrecord material;

                       (3)    retain records in a usable format until final disposition/destruction occurs;

                       (4)    meet requirements for accessioning permanent records into the National
               Archives;

        (5)    include a data migration plan for each series; and 

        (6)    facilitate records authentication and verification.

           b.   Factors to Consider.  Before selecting a storage medium or converting from one
        medium to another, the following factors should be considered: 

                       (1)    The authorized life of the records, as determined during the scheduling
               process.

                       (2)    The effort necessary to maintain the records.

                       (3)    The cost of storing and retrieving the records over the life of the media or
               record.

                       (4)    The record's density.

                       (5)    The access time to retrieve stored records.

                       (6)    The portability of the medium; i.e., selection of a medium that will run on
               equipment offered by multiple manufacturers and that will allow transfer
               of the information from one medium to another (e.g., from optical disk to
               magnetic tape).

                       (7)    Whether the medium meets current applicable Federal Information
               Processing Standards.

                       (8)    The length of time that storage is required.  Floppy disks are not
               recommended for the exclusive long-term storage of permanent or
               unscheduled electronic records.

                       (9)    Established procedures for external labeling to ensure that all authorized
               users can identify and retrieve information stored on diskettes, removable
               disks, or tapes

                       (10)   Conversion of storage media to provide compatibility with current
               hardware and software to ensure that information is not lost because of
               changing technology or deterioration.  Before conversion to a different
               medium, a determination should be made that the authorized disposition
               of the electronic records can be implemented after conversion.

                       (11)   Backing up electronic records on a regular basis to safeguard against the
               loss of information due to equipment malfunctions or human error.  (This
               is sometimes called "making a copy.")  Duplicate copies of permanent or
               unscheduled records should be maintained in storage areas physically
               separated from the storage location of the records that were copied.

   2. RECORDS RETRIEVAL.  All electronic records should be retrievable throughout their
   life cycle.  All authorized users of the system should be able to retrieve desired documents
   through some means, such as an indexing or text search system.  Key fields should be
   uniquely identified and properly indexed to ensure records can be retrieved accurately.  

   3. RECORDS PROTECTION.  To ensure they are accessible and readable until their
   disposition, all electronic records should be protected to ensure their integrity and to check
   for deterioration.

   4. RECORDS SECURITY.  Implementation and maintenance of an effective records security
   program should incorporate the following:

           a.   assurance that only authorized personnel have access to electronic records,

           b.    backup and recovery of records to protect against information loss,

           c.   assurance that appropriate personnel are trained to protect sensitive or classified
        electronic records,

           d.   minimum risk of unauthorized alteration or erasure of electronic records, and 

           e.   assurance that electronic records security is included in computer systems security
        plans prepared pursuant to the Computer Security Act of 1987 (40 U.S.C. 759
        note).

   5. JUDICIAL USE.  Electronic records may be admitted in evidence to Federal courts for use
   in court proceedings if trustworthiness is established by thoroughly documenting the
   recordkeeping system's operation and the system management controls imposed upon the
   system.  Implementation of the following procedures will enhance the legal admissibility
   of electronic records:

           a.   documenting that similar kinds of records generated and stored electronically are
        created by the same processes each time and have a standardized retrieval approach;

           b.   substantiating that security procedures prevent unauthorized addition, modification,
        or deletion of a record and that those procedures protect the system against such
        problems as power interruptions;

           c.   identifying the electronic media on which records are stored throughout their life
        cycle, the maximum time span that records remain on each storage medium, and the
        NARA-approved disposition of all records; and

           d.   coordinating all the above with legal counsel and senior staff.
                           CHAPTER IV
                                
                          DISPOSITION

One of the most effective techniques for managing all records (including electronic records) is
scheduling them for disposition.  Use of DOE F 1324.14, "Files Maintenance and Records
Disposition Instructions," is recommended.  This form describes records series as either
temporary or permanent.  Temporary means the records are disposable after a certain fixed
period.  Permanent records are records appraised by NARA as having sufficient historical or
other value to warrant continued preservation by the Federal Government beyond the time they
are needed for administrative, legal, or fiscal purposes.  The term "disposition" refers to what
happens to the records when they are no longer needed for current business and includes, but is
not limited to, transfer of eligible records to Federal records centers, transfer of permanent
records to the National Archives, and disposal of temporary records.  To prescribe disposition
for electronic records, their electronic information system should be analyzed and described.  

   1. INVENTORYING ELECTRONIC RECORDS.  An aggregate collection of information
   about information systems constitutes an information systems inventory.  This is the first
   step in the disposition process.  Information pertinent to determining the disposition of an
   information system follows:

           a.   name of the system;
           b.   system control number;
           c.   program supported by the system;
           d.   purpose of the system;
           e.   data input and sources;
           f.   major output(s);
           g.   information content;
           h.   hardware/software environment;
           I.   system managers;
           j.   location of documentation needed to read and understand the files (code books and
        file layouts);
           k.   restrictions on access and use;
           l.   authorized disposition of the information as determined by the General Records
        Schedules or a NARA-approved Standard Form 115, "Request For Records
        Disposition Authority";
           m.   disposition authority citation;
           n.   location and volume of any storage media containing identical information;
           o.   identification of person conducting the inventory;
           p.   date of inventory;
   q.   data/application owner; and 
   r.   data/application organization.

   2. APPLYING GENERAL RECORDS SCHEDULES.  After compiling an inventory of
   electronic information systems, the next step is to determine whether the information in
   any system is covered by disposition instructions in the General Records Schedules (GRS)
   issued by NARA, the NARA-approved DOE Administrative Records Schedules (ADM),
   the NARA-approved DOE Program Records Schedules (PRO), or site-specific records
   schedules.

   3. SCHEDULING RECORDS.

           a.   Unscheduled Records.  Some records with enough value to warrant permanent 
        preservation in the National Archives are not covered in existing schedules.  Other
        records with only a temporary value are also not covered in existing schedules. 
        These records are referred to as "unscheduled" records.  To obtain authorization for
        the disposition of unscheduled electronic records, an SF 115 is submitted to NARA
        for approval.  When scheduling records for disposition, the following factors
        should be considered:

                       (1)    data sets and files included in the system;

                       (2)    hard-copy inputs and outputs;

                       (3)    processing, subset, and special format files created and used in the system;

                       (4)    documentation describing and defining the system and the data in it;

                       (5)    determination of the values inherent in the records.

           b.   Standard Form 115.  An SF 115 should be prepared after it has been determined
        how long the data needs to be maintained, and after any additional legal
        requirements affecting disposition have been identified.

           c.   Potentially Permanent.  As is true for most hard copy records, most electronic
        records do not warrant permanent preservation in the National Archives.  The
        following are examples of some potentially permanent electronic records:

                       (1)    electronic records that replace records scheduled as permanent in another
               medium;

                       (2)    automated indexes to permanent records;

                       (3)    unique and important scientific and technical data resulting from
               observations of natural events or phenomena or from controlled laboratory
               or field experiments;

                       (4)    management data that have Government-wide coverage or significance;

                       (5)    socioeconomic data on such topics as trade, education, health, or behavior;

                       (6)    natural resource data related to land, water, minerals, or wildlife;

                       (7)    data that document military or civilian operations during times of war,
               civil emergency, or natural disaster;

                       (8)    political or judicial data related to such topics as elections, special
               investigations, or court proceedings;

                       (9)    cartographic data used to map the earth's surface, other planetary bodies,
               or the atmosphere; and

                       (10)   national security and international relations data that document such
               activities as strategic or foreign policy assessments, foreign public
               opinion, or international negotiations.

   4. SCHEDULES.  Once a proposed disposition for the unscheduled records of an electronic
   information system has been approved by NARA, the disposition authority and approved
   disposition become part of either of the two types of Departmental records schedules
    ADM and PRO , or site-specific records schedules.

   5. DISPOSITION OF UNIQUE ELECTRONIC RECORDS.  See Chapter V for disposition
   regarding unique information management issues.
                           CHAPTER V
                                
                         SPECIAL ISSUES
                                

Records managers should coordinate the effort among records creators, records recipients, and
computer systems management organizations to ensure that records are maintained and protected
in accordance with approved record schedules.  Records managers should ensure that site-level
policies and procedures are developed to protect and ensure accessibility of electronic
documents.

Certain actions involving electronic records may have a direct, significant impact on the integrity
and authenticity of those records.  It is important to know that regardless of its record status, any
electronic document, draft, copy, backup, image, and voice mail message is potentially
"discoverable" and may be admissible in court. 

1. LEGAL ADMISSIBILITY.

           a.   Creation/Receipt.  When effective recordkeeping practices are implemented,
        computer-based records pose no greater legal problems than do paper or
        micrographic records, unless statutes or regulations specifically require records to
        be in paper format.  If the only record is electronic, procedures should be
        established and followed so that (1) the date of the record can be determined, (2)
        the date of any alterations will be automatically recorded by the system, and (3) it
        will be evident that the document was authorized to be issued ("signed"). 

           b.   Use and Maintenance.  System documentation and procedures should sufficiently
        document the system's credibility as an accurate representation of work performed. 
        (See also Paragraph 9. of this chapter, "Electronic Record System
        Documentation.")  Electronic records must be used and relied on in the normal
        course of business.   Training and procedures should support the normal use of
        electronic records and be kept current, as should system documentation and
        disposition.  Additionally, regular, independent assessments of electronic records
        and the system maintaining them need to be performed.  Procedures should include
        how and what records are entered, retrieved, used, maintained, dispositioned, and
        audited, reflecting what occurs in the normal course of business.

           c.   Disposition.  Retention and disposition of electronic records must adhere to NARA-
        approved records schedules.  

      Note:  Records eligible for disposition that have been identified as necessary for a legal
   process may not be disposed of until the legal process has been resolved.

2. MULTIPLE COPIES, REVISIONS, DRAFTS, AND BACKUPS.

           a.   Use and Maintenance.  It is important to use and maintain the most recent version
        of an electronic record or nonrecord because multiple, prior iterations of an
        electronic document can exist on local hard drives, network drives, floppy disks,
        and other electronic storage media, causing confusion. 

           b.   Disposition.  When scheduling electronic records for disposition, the records
        manager should ensure the following are considered and reflected in local policy
        and practice: 

                       (1)    Determining the retention period for drafts that do not become finalized
               (e.g., until no longer needed; report issued; disposition of final version), as
               well as drafts of issued versions.  

        (2)    Ensuring that all copies are scheduled.  

                       (3)    Establishing a routine schedule for deleting working and system backups
               and deleting prior iterations of documents.

                       (4)    Establishing a routine schedule for degaussing, or overwriting, erased disk
               files by using appropriate disk utilities.  This is increasingly important for
               all computer systems to prevent business risk. 

                       (5)    Ensuring that each linked information source is properly dispositioned to 
               consider the approved retention period of the documents to which they are
               linked.  (See this chapter, Paragraph 11, "Complex Electronic Records," 
               for additional information.) 

                Compound documents may contain links to various information sources rather than
        the actual information itself.  Documents can be compiled from various
        "boiler-plate" information sources.  These sources may be stored in different word
        processing documents, database files, spreadsheets, and sound files, each of which
        might reside on a different computer system.  For example, purchase requisitions
        may be compiled from signature files, vendor name and address files, requisitioner
        name and address files, and parts and inventory files, which may be stored in
        diverse locations accessible via a network.  

                Note:  In high-security environments, users should be aware that deleting a file
        does not necessarily remove the data or information from the medium; it may only
        remove the file name and extension from the directory of files.  The space occupied
        by classified files should be degaussed and overwritten or the medium physically
        destroyed to prevent unauthorized re-creation of the file.

      See Attachment V-1, for additional discussion of disposition issues for particular kinds of
   electronic files.

3. IMAGING SYSTEMS.

           a.   Creation/Receipt.  If the paper (or other media) originals are retained after imaging, 
        the "best evidence rules" will generally indicate that the original copy remains the
        record copy for legal purposes.  The storage medium selected i.e., Write Once
        Read Many (WORM), re-writable optical disk, tape, magnetic disk should be
        appropriate for the records retention and Quality Assurance (QA) requirements, and
        should include policies, procedures, and training that support and enforce record
        preservation and integrity.  Preparation of originals for scanning is essential to
        ensure readable, complete, and accurate imaging..   Before equipment and software
        applications are selected, the physical characteristics of the originals being imaged
        must be considered, including color, textual, and pictorial content of the originals,
        in order to make a true and accurate imaged copy of the original.  Site legal counsel
        should be consulted regarding the admissibility of the scanned images.

           b.   Use and Maintenance.  Provisions should be established, documented, and managed
        for migrating images forward as applications, imaging equipment, and storage
        media advance.

                Note:  See Paragraph 7 of this chapter, "Data Portability/Migration."

           c.   Disposition.  Storing files with varying disposition dates on one disk or tape
        requires management of disposition.  In the case of WORM drives, disposition
        management will require recopying records that are not due for disposition onto
        new storage media so that the other files can be disposed of, whether for transfer or
        destruction.  Removing the index pointers to the imaged files will not destroy an
        image.  The image itself must be removed from the storage media, or the storage
        media must be physically destroyed. 

4. QUALITY ASSURANCE RECORDS.

           a.   Creation/Receipt.  It is important to understand the creation and duplicate copy
        requirements established for the site.

           b.   Use and Maintenance.  Likewise, it is important to understand and implement any
        special, local site storage requirements designated for QA records.  It is not
        recommended that single storage be used for electronic, QA records.
      
           c.   Disposition.  Ensure that disposition of all copies of QA records takes place.

5. VOICE MAIL.
   
           a.   Creation/Receipt.  Generally, a voice mail system is not considered to be a
        recordkeeping system.  Should a voice mail message be determined to be a record, 
        the user should document the message in a more stable and appropriate
        recordkeeping system.  For example, the content of the voice mail message can be
        recorded on paper, or in an electronic file, either as a "note to file" or in a
        confirming note or memorandum to the sender of the voice mail message; this
        record can then be entered into the recordkeeping system. 
        
           b.   Use and Maintenance.  Users should be aware of the voice mail application's
        capabilities regarding deletion of unread, skipped, and stored voice mail messages,
        and whether a deleted message can be recovered.  If this information is not widely
        disseminated in a policy or procedure development of such a policy should be
        considered.  Included in such a policy should be the site's policy regarding privacy
        of voice mail messages and the circumstances in which an individual's voice mail
        may be retrieved by someone other than the individual. 

           c.   Disposition.  If a voice mail message is determined to be a record, the recorded 
        message may be deleted once the content has been properly documented in a
        regular recordkeeping system.

6. AUDIO/VIDEO CONFERENCING/RECORDINGS.

           a.   Creation/Receipt.  Audio and/or video recordings may be considered a record if the
        content of the recording meets the definition of a record as found in 44 U.S.C.
        3301.  If it is anticipated that the content of a recording will be a record, the
        necessary actions must be taken to properly identify the recording, the date it was
        made, etc.  

           b.   Use and Maintenance.  Recordings should be maintained under proper conditions 
        (e.g., in a temperature/humidity-controlled storage environment) to ensure 
        preservation and accessibility of recordings during the approved retention period. 

           c.   Disposition.  The recording of a video conference or teleconference may be
        disposed of if 

                              a video conference or teleconference is recorded for note-taking purposes
               only, and 

                              the visual and auditory content is fully transcribed to a document
               (electronic or otherwise), and 

                              the document is solely relied upon as a record of the meeting, and 

                              this reliance is reflected in the site's records schedule

7. DATA PORTABILITY/MIGRATION.

           a.   Creation/Receipt.  As software and equipment continues to improve, change,
        become obsolete, or be replaced with other software and/or equipment, it is
        necessary to ensure that electronic records created using the superseded software
        and/or equipment are readable, and accessible, throughout the records' approved
        retention period.  This requires records managers, users, system administrators, and
        other interested individuals to make provisions to upgrade, convert, or otherwise
        move the electronic documents into the new equipment/software environment at the
        time that the new software/equipment is put into service.  Likewise, quality control
        provisions should be part of the process to ensure the upgraded, converted, or
        moved electronic records are readable, accessible, and unaltered once they reside in
        the new software and/or equipment. 

           b.   Use and Maintenance.  Records managers and users should develop processes,
        including periodic records compliance audits, for ensuring compliance with the
        standards for storing electronic documents as those standards develop and change.
        Such standards may address use of the following:  

                              a particular directory/folder structure, 

                              a network drive rather than a local drive, 

                              a particular universal format like Portable Document Format (PDF).

           c.   Disposition.  Even though electronic documents may not be accessible or readable
        by an individual user or group of users after upgrade of equipment or software,
        others may be able to access and read those documents.  Records managers and
        users should ensure the former versions of the electronic documents are destroyed
        once the documents reside in the new software/equipment to avoid the potential for
        unauthorized disclosure of the content of the documents. 

   8. E-MAIL RECORDS.  E-mail messages are considered Federal records according to the
   same criteria established for other Federal records.  Accordingly, the same records
   management principles and guidelines that apply to paper and other non-electronic records
   apply to e-mail.  E-mail records are subject to the same information protection and security
   issues as other Federal records in other media.  In addition, the dynamic communication
   environment of e-mail, with potential copying and wide distribution of information, makes
   it very important that standard records management procedures and recommendations be
   followed by all creators and users of e-mail.  Each organization's records management
   guidelines and procedures should specifically address the important issue of e-mail records.
   E-mail users (senders and receivers) should distinguish between record and nonrecord
   materials, properly preserve the records, and promptly dispose of nonrecords as soon as
   they have fulfilled their purpose.

        a.  Creation and Receipt.

                (1) A Record.  The user generally decides whether an e-mail message and/or
          attachments is a record.  The user must base the decision on the 44 U.S.C. 3301
          definition and local guidance and explanatory material provided by records
          management personnel.  As with other records, the decision process focuses on
          the information, not the media.  Each organization must implement specific
          programs to ensure that users are properly trained to determine the record or
          nonrecord status of any e-mail messages.  The appropriate two-part question to
          answer is, "Should this message be included in the appropriate records series as
          necessary documentation for a transaction, and is maintenance of its specific
          records series the responsibility of the user's organization"?

                (2) Distinguish.  All e-mail users should be provided with sufficient information,
          guidance, and training to distinguish Federal records from nonrecords and to
          apply appropriate retention and disposition practices.  Many nonrecords are
          retained solely for convenient reference, not to document transactions in a
          records series.

                (3) Training.  Training programs for e-mail users should address the following:

                        (a) how to identify or create e-mail records that are appropriate or necessary
              for retention purposes; 

                        (b) how to distinguish between record and nonrecord messages and/or
              attachments;

                        (c) the similarities for recordkeeping purposes between e-mail records and
              records transmitted by mail or fax systems;

                        (d) the need for describing and instructing users regarding the e-mail
              hardware/software used on-site;

                        (e) how technology should be used to best meet recordkeeping requirements
              (e.g., how to set up electronic "folders" to match record series/file titles);

                        (f) how to establish site-specific procedures for producing a complete record
              of the message, plus transmission data and receipt, if in use at the site;

          (g) site-specific requirements for record creation, and;

                        (h) site-specific requirements and/or outside compliance orders for training
              methods and documentation.

            b.  Use and Maintenance.

                (1) Storage Options.  The recordkeeping system should allows e-mail records to be
          retrieved in a useable format.  The three general storage options are 

                        the e-mail system itself;
                            a separate electronic recordkeeping system; and 
              paper or non-electronic media.

                (2) Person Responsible.  The person who has created, received, or acted upon a
          message/attachment that is a record is responsible for ensuring that it enters the
          recordkeeping system.  A non-record may be deleted without entering it into the
          system.

                (3) Transaction Documents.  Messages belong in a record series when they
          document transactions in a records series that the user's organization is
          responsible for maintaining.  The responsible person should first note that an e-
          mail message constitutes a transaction document; second, he/she should ensure
          that the message is placed in the official record series for that type of record. 
          The record will then be available to other authorized users.  The records series
          file could be  paper or electronic.  Whichever it is, the record series should be
          described, maintained, and disposed of according to the established file
          instructions on DOE Form 1324.14, "Records Maintenance and Disposition
          Instructions."  Each organization should implement specific procedures for
          performing this activity.

                (4) Personal E-mail Folders.  Generally, personal e-mail "folders" for storing
          messages should not be part of an official record system.  E-mail is password-
          protected and is available increasingly on a user's workstation only.  Others do
          not have easy access to the information 

            c.  System Backups.  System backups are intended to restore computer system operations
        and are not adequate for records storage and archival purposes.  They should not be
        used for a records series retention. 

            d.  System Backup Tapes.  System backup tapes or media should be destroyed according
        to established rotation schedules.  Temporary records should never be kept longer than
        the retention period in the records disposition schedules for the records series
        contained in the backup files because if the record exists, it is discoverable.  Deleting
        or thoroughly erasing this information at specific intervals will reduce possible
        business risk, cost due to misuse of information, and compromise of protected
        information.  This records retention consideration also applies to personal backups on
        floppy disks.

            e.  Message Meta Data.  E-mail message records should include transmission and receipt
        data, as needed for adequate and proper documentation of transactions.  Transmission
        data is part of an e-mail record and should be included wherever necessary for
        complete documentation of significant transactions.  Incidentally, this related data is
        appropriate record information, whether non-electronic or electronic.  As meta
        information, it includes sender's name, dates and times transmitted, names of
        recipients, and subject.  If a return receipt is requested, the verification of that receipt
        including time received is also part of the record.  If an e-mail record is sent to a
        "group," the names of the individuals in that group at that point in time should be
        available.  For large corporate groups, such as "all employees," the organization that
        maintains the group may be assigned responsibility for keeping a record of who was in
        that group at any point in time.

            f.  Security.  E-mail systems need to incorporate security measures to protect against
        unauthorized alterations or deletions.  

            g.  Access to E-mail.  E-mail is not completely confidential or private.  Supervisors may
        have the right to read an employee's e-mail in certain circumstances (e.g., during
        absences).  A network or systems administrator may need to access employees' e-mail
        for technical reasons.  

            h.  Classification.  Approved records disposition schedules are required for classified
        documents.  Classified documents are also records.  Classification requirements must
        be strictly adhered to regarding the creation, maintenance, or disposition of classified
        records (including classified electronic records).  For security requirements and
        procedures affecting classified records, see DOE O 471.2, INFORMATION
        SECURITY PROGRAM; DOE M 471.2-1, MANUAL FOR CLASSIFIED MATTER
        PROTECTION AND CONTROL; and their accompanying contractor requirements
        documents.   Information classification and protection procedures and guidelines are
        mandatory for use of an e-mail system involving classified records.  

                               Notes:  (1)        Simple deletion of a message does not actually erase or destroy the
                         message, and specific requirements apply. 

                                       (2)        Additional organizational and systems procedures may apply to some
                         nonclassified systems.  

    i.  Disposition.

                (1) E-mail records should be retained and disposition made according to approved
          records schedules.

                (2) Depending on the content, some e-mail messages may be unscheduled records. 
          As the term "unscheduled" implies, unscheduled records are not authorized to be
          destroyed.

                (3) Avoid retaining records beyond the approved retention period provided for in an
          approved records schedule. 

                (4) Nonrecords may be deleted from computer systems without filing a copy for
          record purposes.  Many e-mail messages are nonrecords.  Other examples of
          nonrecords include copies of memoranda or letters that were received for
          information rather than action; messages or attachments for whose retention the
          individual is not responsible; or messages that have only temporary value (such
          as the message that an insignificant meeting has been moved from the morning
          to the afternoon).

    9.  ELECTRONIC RECORD SYSTEM DOCUMENTATION.  Documentation is required
    for any computer system that electronically transmits records to a recordkeeping system or
    stores and manipulates electronic records.  For any legal or regulatory purpose, system
    documentation will substantiate and demonstrate consistent and systematic use of the
    system, in accordance with established requirements.  To protect an organization in the
    event of litigation, it is imperative to show that all reasonable requirements were
    successfully met in the implementation and operation of electronic records systems.  To
    that end, the level of detail in the documentation should be commensurate with the
    importance of the application and records series being considered.  The following
    information should be addressed when documenting systems or related activities or
    processes that involve the generation of electronic records.

            a.  System Purpose and Scope.  Describe the system's purpose, function, and operation. 
        Identify the records that are to be maintained as electronic records and those that are
        not to be included in the scope of the system.

            b.  Operating and Technical Specifications.  Describe the operational and technical
        specifications used for developing or procuring the system, and provide complete
        copies of the operating manuals purchased with the system or developed for the
        application. 

            c.  Testing and Validation.  Document the testing, test results, and validation program or
        method used to evaluate the system's compliance with design or procurement
        specifications.  Include the method by which any program changes are implemented
        and verified for proper system operation.

            d.  Data Dictionary.  For database applications, document the following in the data
        dictionary for all data and summary fields:  data element name, description, field type,
        field size, and method for validation.

            e.  System Links to Other Systems.  Identify all links and network configurations used to
        receive, use, or exchange data with other computer systems.  Include the names of
        other systems and describe the information exchanged and how that information is
        exchanged.

            f.  Disaster Planning.  For disaster prevention and recovery plans, describe how records
        access downtime is minimized and what alternative methods, if any, are available
        when experiencing minor failures up to and including catastrophic failures.  These
        plans should describe potential hazards, preventive measures taken, and procedures to
        follow in the event of a disaster.  System access controls preventing unauthorized
        modification of the information should be included in the disaster prevention section. 
        These plans should be reviewed and tested periodically for adequacy; any deficiencies
        identified should be promptly corrected.

            g.  Future System Migration or Upgrade.  Document how future migration or upgrade
        plans for the system will be handled.  Address how hardware, software, or operating
        system upgrades or obsolescence will be handled while simultaneously continuing to
        properly retain and maintain the records until their authorized disposition. 
        Satisfactory evidence that data migration will be successful can be demonstrated by
        testing.  During testing, data should be transferred to other systems or file formats to
        demonstrate that the transfer works.  This will ensure that the data configuration can
        be maintained for as long as it is required to be retained.

            h.  Operational Procedures.  Procedures should be approved and in effect for all system
        operations including data entry, correction, modification, or deletion; database
        administration; and modifications to, and testing of, the software.

            i.  Quality Control and Quality Assurance.  To ensure data accuracy and integrity, plan
        for and describe the quality control and quality assurance measures or procedures to
        be implemented.  To verify compliance with all programmatic and procedural
        requirements, plan for the type and frequency of internal and independent assessments
        to be performed.
    
            j.  Training.  Document user training to show that users are qualified to enter, retrieve,
        modify, or delete data in the system and to perform any system database
        administration functions.  Also, document general user training to enable users to
        extract necessary information and to interpret the information in support of decision-
        making processes.

    10. INFORMATION SYSTEMS AS RECORDS.  Information systems or databases are
    complex, dynamic data processing environments.  In these environments, information
    undergoes a variety of logical and numerical processes to provide multiple system users
    with up-to-date, relevant, on-line, structured and unstructured information. 
    Organizational systems may include payroll, budget and accounting, records indexing,
    inventory, scheduling, computer-aided design and drafting (CADD), and
    three-dimensional modeling.  These information systems consist of one or more
    numerical, textual, or graphical files containing data elements subject to a variety of rules
    and relationships with other fields, files, and even systems.  These systems can reside on a
    variety of computer platforms ranging from stand-alone personal computers to group or
    Departmental servers, including mainframes.

            a.  Formerly the Nonrecord Copy.  In the past, due to the complexities and logistics
        involved, many organizations considered information systems by themselves to be the
        nonrecord copy, and the copy itself was retained and used for information purposes
        only.  The signed, hard-copy forms authorizing data to be updated or changed and the
        specific, periodic printouts paper, computer output to microfilm (COM), or laser
        disk (COLD) were considered to be the records.  Some organizations considered the
        records to be the hard-copy printouts or screen prints of requested ad hoc reports
        summarizing the data contained in the system.  The database itself, however, was not
        considered to be "record" information.

            b.  Electronic Information Systems Designated as "Records."  The following guidelines
        should be considered in planning for the implementation and maintenance of an
        information system as "the record copy" or as "record" information, as opposed to its
        use as "an extra copy for information only" (i.e., for convenient reference only)
        consider the following guidelines: 

                (1) Assemble a project implementation team drawing on, at a minimum, computer,
          technical, legal, business/operation, regulatory, and records experts.  Additional
          resources or support may include computer security personnel and
          representatives of upper management, such as, the chief executive officer (CEO)
          or chief information officer (CIO).
  
                (2) Provide complete system documentation  to substantiate consistent and
          systematic use of the system for any legal or regulatory purposes.  The level of
          detail in the documentation should reflect the importance of the application
          being studied.  (See this chapter, Paragraph 9, "Electronic Record System
          Documentation.")  Depending on the specific functions and importance of the
          application being planned, address the following considerations in the
          documentation:  
  
                        (a) Evaluate and document the record media balance to be used; that is,
              determine  how much of the data in the information system will be used as
              the record copy, in lieu of traditional paper records.  Records management
              organizations or implementation teams should evaluate the value of data
              contained in the system and determine which information is better retained
              electronically rather than as hard copy.  Data that can be disposed of "when
              no longer needed" or "when superseded" could reasonably be expected to
              be kept electronically. Data that requires a long retention period or
              documented authorizations and signatures may need to be documented in a
              hard copy.  Periodic status reports can be prepared and generated to capture
              specific data elements and then printed to paper, microfilm, laser disk, or
              even magnetic tape.  This practice may help prevent some of the electronic
              storage and long-term retention and management issues involved with
              retaining the database as a record.

                        (b) Determine the types and importance of decisions likely to be made using
              the on-line information system, and determine what documentation is or
              will be necessary to support those decisions in the future.  Recognize also
              that the user's ability to generate ad hoc reports may result in information
              being seen in a variety of different contexts, more so than if they were
              made available through standard, system-generated reports.  If that is the
              case, the system manager should determine how to maintain that
              electronically retained information.  To do this, he/she should determine 

                                  whether each addition, modification, deletion, or system query should
                 be tracked in a transaction log or audit trail along with periodic
                 snap-shots;
                                  
                                  how far back a transaction log/audit trail should be maintained; and 

                                  what information should be maintained in the log (e.g., user
                 identification, before data, after data, and date and time of change).  

                            The project implementation team should decide how often, and for how
              long, complete system backups should be maintained, while ensuring that
              they are not retained longer than authorized for the system records.  The
              team should decide when, if necessary, users or system administrators are
              required to save ad hoc queries and query results as hard copy records
              rather than relying on system transaction logs or backups.

                        (c) Evaluate requirements for accessing and manipulating data to meet future
              retrieval needs.  Periodic ASCII reports may meet the business and
              regulatory retention needs.

    11. COMPLEX ELECTRONIC RECORDS.  Complex electronic records are composed of
    multiple computer files to be viewed on a computer screen.  Printing these records on
    paper may result in a loss of some of the records' content.  These complex electronic
    records are a subset of electronic records and include the following:  multimedia
    documents such as electronic files that combine both text and video, dynamically linked
    documents such as text files with active links to electronic spreadsheets,HTML documents
    sometimes known as "Home-pages or Web pages," and three-dimensional CADD models. 
    These records present relatively new issues for records and information managers and
    require special care to manage electronically.  The following guidelines are intended to
    aid organizations in managing these types of records:

            a.  Multimedia Combined Documents.  Multimedia documents that combine two or more
        record types in a single record are best used for record series with short retention
        periods, or simply as "information only" documents.  The viability of maintaining
        these records for long retention periods is uncertain particularly as software and
        hardware evolves.  Record copies could be managed more easily if stored as separate
        records, rather than as combined multimedia records. 

            b.  Linked Records.  Linked records are records that automatically extract information
        from another electronic file; for example, a word processing report that automatically
        extracts and displays selected financial data from a budget spreadsheet.  Through the
        use of linked files, one file can be automatically updated when the linked file is
        changed.  This situation would invalidate records that require retention periods longer
        than "until superseded."  Therefore, care must be taken that the information to be
        extracted is either copied and pasted into the record file, or the file from which data is
        extracted is protected from being changed or revised.  In the first case, copying and
        pasting data eliminates the need for maintaining the second file as part of the record. 
        In the latter case, any time a component of a set of linked files is changed, the entire
        set must be saved as a new revision, if required by an approved records disposition
        schedule.  This maintains a revision audit trail for the record.

            c.  Hypertext Documents.  Hypertext documents are files that contain embedded links
        that allow a reader to select new information by pressing the mouse button while the
        cursor is on the link.  This results in a jump to another view of the same document or a
        jump to an entirely new document on the same server or some other designated server
        anywhere in the world.  At this time it is recommended that Web pages on an Internet
        Server be viewed as "information only" documents and not records.  Record copies of
        Web information should be stored in a separate recordkeeping system for as long as is
        required by approved records disposition schedules.

            d.  Design Models.  Three-dimensional CADD models can be used to represent the design
        of facilities, structures, systems, equipment, or components.  They can produce the
        traditional two-dimensional drawings necessary for construction and maintenance of
        an item. Engineering design changes can result in the model being updated
        electronically without the need for printing two-dimensional drawings ,but these
        changes will be there when a hard copy is requested.  Record managers should work
        with the appropriate engineering and construction organizations to decide how the
        record information should best be managed.  Options include electronic or hard copy
        management.  Electronic management would require taking and storing electronic
        snapshots of the model and tracking the individual changes electronically between
        snapshots so that the model can be reconfigured for any point in time.  Hard-copy
        management could require printing out paper or computer-output-to-microfilm (COM)
        of the two-dimensional drawings along with each subsequent revision.  A mix may
        include direct computer-output-to-laserdisc (COLD) or scanning the paper or aperture
        cards into a more traditional imaging system.

            e.  Similarities.  The general issues and concerns for managing complex electronic
        records are the same as for simple electronic records or even paper and microfilm. 
        Records managers should work with appropriate organizations to establish and
        document the policies and procedures for transferring the records to a new custodian. 
        Consideration should always be given to access frequency, information format,
        technology migration, and long-term retention issues, such as software and hardware
        upgrades.  These issues should be balanced by the relative importance of the
        application and the record series.
                          ATTACHMENT 1
                                
 DISPOSITION ISSUES FOR PARTICULAR KINDS OF ELECTRONIC RECORDS

      1.    Overwritten Files.  When a file already exists with a specific filename and extension,
      revisions to that file may replace the old file.  The old file is still stored on the medium, but it
      is inaccessible to the user.  (Technically advanced users with the proper commercially
      available utilities may still gain access to the file.)

      2.    Erased Files.  Files that have been erased directly by the user generally have no problem with
      record integrity.  However, the operating system may only delete the file's name from the
      directory and leave the data on the medium while waiting for the space on the hard disk or
      floppy disk to be reused for another file.

      3.    Copied Files.  As files are created, saved, and copied to another medium (e.g., from the hard
      disk to a floppy disk), two copies of the file exist with the same file name and extension.  If
      the copy process is repeated using a different floppy disk, multiple prior iterations of the file
      exist.  If it becomes necessary to restore a file from a backup floppy disk, it is important to
      use the most recently revised floppy disk file; use of an earlier but unrevised floppy disk will
      result in loss of data and time when the error is discovered.

      4.    Backup Files.  Some software applications create backup files with the same name but a
      different extension to identify it as a backup file.  These backup files may be recaptured
      without the need for special utilities.  Unless the medium is degaussed or the backup file is
      erased and its file space either reused or degaussed, the old file may still be resident on the
      medium.

<<EOD>>