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# Bulletin 2011-04

**July 18, 2011**

**TO:** Heads of Federal Agencies

**SUBJECT:** Guidance on Managing Mixed-Media Files

**EXPIRATION DATE:** Expires when revoked or superseded

**1. What is the purpose of this Bulletin?**  Agencies frequently manage files with records created or received in more than one type of medium. This Bulletin provides agencies with guidance about the records management implications when records in various types of media are intermixed in one file. This Bulletin also reminds agencies of lifecycle management requirements for electronic records as described in 36 CFR 1236.20 and for audiovisual, cartographic, and related records per 36 CFR 1237. This Bulletin is not intended to address scheduling of these records.

NARA bulletins provide fundamental guidance to Federal agencies, who must then determine the most appropriate ways to incorporate recordkeeping requirements into their business processes and identify the specific means by which their agencies will fulfill their responsibilities under the Federal Records Act.

**2. What are mixed-media files?**  A "file", for the purposes of this Bulletin, is a group of records regardless of location that relate to a topic, such as a case file. Mixed-media files are files composed of records on different forms of media. Media are the physical forms on which records are stored; paper, photographs, compact discs, DVDs, analog tapes, flash drives, local hard drives, servers, and other items. Records in a file may be stored on more than one medium reflecting the way agencies create, maintain, and use records today. The electronic parts of a file could also be in many different formats, but this Bulletin only covers the mix of physical media.

**3. How are Federal agencies currently creating and managing mixed-media files?**  Employees responsible for maintaining a current file generally know where to find the disparate records associated with the file. However, when the file is no longer needed for active Federal business, employees may lose track of the file components and, over time, parts of the file may be lost and/or electronic media may become unreadable.  NARA interviewed Federal agencies that create mixed-media files as part of their business processes. All agencies interviewed recognize the challenges and risks posed by mixed-media files and have different ways of handling these files. The following summarizes these interviews.  Several agencies create files that include electronic and paper records received from external sources. As a result, agencies have little control over how these records are created, and may receive records on digital or analog media. Most interviewed agencies have a policy to print electronic records and include them in the paper files. In practice, some records are not printed or certain records cannot be printed at all. In such situations, the physical media that hold the electronic records are often included in the paper files. Agencies also use shared drives to keep together electronic records for each file maintaining some links with the paper versions.  In another example, an agency prints any records received electronically and includes these with the original paper file. If records are received on physical media, the physical media is added to the paper file after the records are printed. If the file was created electronically, any paper records received are scanned and included in the electronic file. The agency maintains the scanned paper records and links them to the electronic version so the paper records can be located.  In a final example, most of the agency's case files are scheduled for permanent retention, and 25% include mixed media. This agency receives information from external sources on various types of media as part of the case file. The electronic media is separated from the paper within the file when the case is closed. Upon file closure, the paper records are sent to the records storage facility and the electronic media are retained at the agency until legal transfer to NARA. The agency states the media are well-labeled and they can reconstruct the file.   

**4. What are some agency records management risks associated with mixed-media files?**  Mixed-media files have inherent records management risks that can cause agencies to be unable to meet their business needs, protect rights and assure accountability, and ensure NARA can preserve and make available records of archival value for future generations.  The following challenges and risks are organized based on when they are likely to occur in the records lifecycle:

**Creation or Receipt:**

- No policies addressing file creation and identification, which can lead to records being created in various media
- No policies requiring metadata to link records on different media within a file, which may lead to an incomplete record of agency activities or inability to locate the complete file, especially if the media is separated

**Maintenance and Storage:**

- Improperly identified records may be stored in environments inappropriate for their long-term preservation and may become unreadable due to media degradation or obsolescence
- Increased processing time that may increase costs at records storage facilities if mixed-media files are not identified during the business
- process
- Inability to reconstruct the original order of the file when records are separated by media
- Lack of current inventories showing the location of all generations of audiovisual records and all cartographic and related records

**Disposition:**

- Records may be destroyed too early and/or permanent records may not be transferred to NARA
- Records destroyed too late could lead to increased search and production costs for information access requests
- Electronic media in mixed media files may not be identified properly so that they can be separated for preservation or destruction

**5. What are Federal agencies required to do under NARA regulations?**  The following NARA regulations apply:

- Agencies must ensure that procedures, directives and other issuances; systems planning and development documentation; and other relevant records include recordkeeping requirements for records in all media, including those records created or received on electronic mail systems. Recordkeeping requirements must: [...] (2) Specify the use of materials and recording techniques that ensure the preservation of records as long as they are needed by the Government; (3) Specify the manner in which these materials must be maintained wherever held"  36 CFR 1222.24
- "To ensure the adequate and proper documentation of agency programs, each program must develop recordkeeping requirements that identify: [...] (d) The relationship between paper and electronic files in the same series"  36 CFR 1222.26 (d)
- "To ensure that record series and systems adequately document agency policies, transactions, and activities, each program must develop recordkeeping requirements for records series and systems that include: [...] (f) Policies and procedures for maintaining series consisting of different media"  36 CFR 1222.28 (f)
- "Agencies must use electronic or paper recordkeeping systems or a combination of those systems, depending on their business needs, for managing their records"  36 CFR 1236.20 (a)

If agencies store records in a records storage facility, they must do so in accordance with NARA regulations (see 36 CFR Parts 1232-1234  and 1237.16).

**6. What can agencies do to address some of the records management challenges associated with mixed-media files?**  Agency program staff should work with their records officers to address the records management challenges associated with mixed-media files. The successful management of mixed media is dependent on appropriate identification, organization, and retention by agency business units. Processes to manage records are most easily implemented at creation.  The following strategies have been organized around the records lifecycle concept:

**Creation or Receipt:**

- Develop consistent business processes that reduce the number of varying media when creating files
- Specify naming conventions that appropriately identify all media in a file
- Identify the record copy when multiple copies are created and maintained
- Develop metadata and cross-references that link all media in a file to maintain the integrity of that file, especially when considering pre-accessioning the electronic portion of the file

**Maintenance and Storage:**

- Assign clear records disposition dates to record copies and manage any additional copies
- Make sure that media are well-labeled and well-documented to reconstruct the files when necessary
- Use inventory forms or database notations to track locations of all media in a file
- Handle temporary and permanent mixed-media files in the same manner
- Develop a process to check files for mixed media before they are sent to a records storage facility to ensure contents are properly documented and stored in the appropriate environment
- Implement data migration strategies to counteract the hardware and software dependencies of electronic records when necessary (see  "Preliminary Planning for Electronic Recordkeeping: Checklist for IT Staff" )
- Inspect media periodically to ensure data integrity

**Disposition:**

- Pre-accession permanent electronic records (see Question 7)
- Review records and all associated metadata to ensure that disposition is being carried out in accordance with approved records schedules
- Maintain metadata until all portions of the file are properly disposed of or transferred to NARA

**7. What are further considerations for permanent records?**  The strategies identified above should be applied to all records, without regard to their approved disposition. Further, records appraised by NARA to have permanent retention have additional requirements to ensure both the long-term preservation of the records in agency custody and facilitate the legal transfer of the records to NARA custody, especially for electronic records. Agencies must create and maintain cross references or metadata in order to link records within a mixed-media file and maintain integrity of the file.  Most significantly, NARA offers pre-accessioning of electronic records. Pre-accessioning is when NARA fully processes (for preservation purposes) permanently valuable electronic records in order to assume physical custody before the records are scheduled to legally become part of the National Archives. During processing, NARA will copy the records onto archival quality media, verify the adequacy of the technical documentation, prepare the documentation according to NARA standards, and write draft descriptions of the records. The transferring agency retains legal custody of the pre-accessioned electronic records until the records are scheduled to come under the legal custody of NARA. This allows NARA to preserve the records early in their lifecycle while the agency retains its authority and responsibility for providing access. NARA also provides the agency with off-site, no-cost security copies of the pre-accessioned records. For more information about pre-accessioning, refer to NARA Bulletin 2009-03: Pre-accessioning permanent electronic records and Pre-accessioning: A Strategy for Preserving Electronic Records.  The CFR includes additional requirements at 36 CFR 1236.28 for the selection and maintenance of electronic records storage media for permanent records.

**8. What other NARA resources are available?**  NARA has the following resources and related guidance that may be useful:

- Toolkit for Managing Electronic Records: A resource for agencies to share and access records management guidance and best practices
- FRC Toolkit : A resource for Federal employees with records management responsibilities that provides step-by-step instructions for transferring, retrieving, and returning records to a Federal Records Center as well as information on records disposition and accession of records into the National Archives at the end of their retention schedule.
- Information and FAQs on Electronic Media Storage : FRC FAQ on the electronic records vaults.

**9. Where do I go for more information?**  For specific questions about transferring records to NARA Federal Records Centers, contact your Federal Records Center account manager. The list of account managers can be found on the NARA web site at http://www.archives.gov/frc/acct-reps.html.  Agency staff should contact their agency records officers to discuss mixed media. A list of agency records officers can be found on the NARA web site at http://www.archives.gov/records-mgmt/agency/officers-lists.html. Your agency's records officer may contact the NARA appraisal archivist with whom your agency normally works. The list of the appraisal contacts is posted on the NARA web site at http://www.archives.gov/records-mgmt/appraisal/.

DAVID S. FERRIERO*Archivist of the United States*

 This page was last reviewed on September 9, 2022.Contact us with questions or comments.      

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