Department of the Interior
Departmental Manual
Effective Date: 3/11/98
Series: Information Resources Management
Part 380: Records Management
Chapter 6: Vital Records Program
Originating Office: Office of Information Resources Management
380 DM 6
1.1 Purpose. The purpose of this chapter is to provide general policy and procedures to ensure that the Department of the Interior (DOI or Department) has an effective Vital Records Program in place to identify, protect and provide ready access to vital records necessary to ensure continuity of essential Departmental activities in the event of a national, regional or local disaster or emergency.
1.2 Authorities and Related Documents.
A. Authorities.
(1) 44 U.S.C. 2104(a), 2904(a), 3101.
(2) 36 CFR 1236, Management of Vital Records.
(3) Executive Order 12656, November 18, 1988, Assignment of Emergency Preparedness Responsibilities.
(4) Departmental Manual, Part 900, Chapter 1, Civil Defense Emergency, August 22, 1980.
B. Related Document.
(1) National Archives and Records Administration (NARA), Instructional Guide Series, "Vital Records and Records Disaster Mitigation and Recovery," 1996.
1.3 Objectives. The objectives of the DOI Vital Records Program are:
A. To ensure that emergency operating records vital to the continuity of essential DOI activities during a national/regional emergency or disaster will be available at DOI relocation sites in the event that those sites are activated during the crisis.
B. To safeguard legal and financial records essential to the preservation of the legal rights and interests of individual citizens and the Government.
C. To ensure that vital records are evaluated on the basis of their necessity in carrying out emergency operations or in protecting the rights and interests of citizens and the Government and not on their value as permanent records.
D. To ensure that such records will be easily retrievable and maintained in proper condition.
E. To ensure that the necessary finding aids are available at the relocation sites.
F. To ensure that a current inventory of records located at the sites is readily accessible.
1.4 Definitions.
A. Records are books, papers, maps, photographs, machine readable materials, or other documentary materials, regardless of physical form or characteristics that are made or received in connection with the transaction of public business, and are preserved or appropriate for preservation as evidence of the organization, functions, policies, decisions, procedures, operations, or other activities of the Government or because of the informational value of data in them.
B. Vital Records are essential agency records needed to meet operational responsibilities under national or regional emergency or disaster conditions. Vital records are divided into two categories.
(1) Emergency operating records are vital records essential to the continued functioning or reconstitution of an organization during and after an emergency. Included are emergency plans and directive(s), orders of succession, delegations of authority, staffing assignments, selected program records needed to continue the most critical agency operations, as well as related policy or procedural records that assist agency staff in conducting operations under emergency conditions and for resuming normal operations after an emergency.
(2) Legal and financial rights records are vital records essential to protect the legal and financial rights of the Government and of the individuals directly affected by its activities. Examples of these records are records containing proof of ownership, financial interest (social security, payroll, retirement, insurance, accounts receivable), legal proceeding decisions, contractual obligations, and similar records. These records were formerly defined as "rights-and-interests" records.
C. Disaster means an unexpected occurrence inflicting widespread destruction and distress and having long-term adverse effects on agency operations.
D. Emergency means a situation or an occurrence of a serious nature, developing suddenly and unexpectedly, and demanding immediate action. This is generally of short duration, for example, an interruption of normal agency operations for a week or less. It may involve electrical failure or minor flooding caused by broken pipes.
E. Proprietary information is information contained in a vital record that is owned by a private individual or a corporation/business organization, such as under a trademark or patent, and so designated by the owner.
1.5 Policy. All bureaus and offices will establish a Vital Records Program for the identification and safeguarding of emergency operating and legal and financial rights records necessary for their own essential emergency and recovery functions. For the purpose of this directive, the Office of the Secretary (OS) [consisting of the Immediate Offices of the Secretary and Deputy Secretary, and Assistant Secretaries offices] will be treated as a single entity and their vital records managed by the OS Records Officer. All other offices are responsible for implementing their own Vital Records Program.
1.6 Responsibilities.
A. Assistant Secretary - Policy, Management and Budget (PMB). The Assistant Secretary - PMB has overall responsibility and authority for the management of the Department's records, including vital records.
B. Chief Information Officer (CIO), Director of the Office of Information Resources Management. The CIO has been delegated responsibility for the policy direction, oversight and administrative management of the Department's Records Management Program, including the Vital Records Program. The CIO is responsible for overall Departmental program management of vital records and will:
(1) Develop and administer Departmental vital records policy and guidance;
(2) Provide program coordination and liaison with the Office of Managing Risk and Public Safety (MRPS) as it relates to the Department's policies and plans for continuity of operations and other emergency preparedness;
(3) Provide technical assistance to bureaus/offices for the development of their respective Vital Records Program; and
(4) Periodically monitor and evaluate the implementation of Vital Records Program activities Departmentwide.
C. Heads of Bureaus and Offices. Heads of bureaus and offices will designate a Vital Records Manager to implement a Vital Records Program that will ensure compliance with Departmental policies.
D. Vital Records Manager. Each bureau/office Vital Records Manager will:
(1) Develop and update a strategic plan for coordinating and implementing vital records planning between individual bureau/office locations.
(2) Ensure that a Vital Records Program is developed for each organizational unit, location, facility, or other appropriate component of the bureau/office.
(3) Ensure the identification, safeguarding, maintenance and regular updating of vital records stored off-site.
(4) Ensure adequate coordination occurs between the vital records liaisons, security officers, local continuity of operations planners, local information technology contingency operations managers, and all other necessary program managers.
(6) Provide assistance in obtaining space and security provisions for safeguarding vital records.
(7) Assist in the transfer of vital records to a Federal Records Center (FRC) or other suitable off-site locations.
(8) Ensure adequate safeguarding of classified records and any records containing proprietary information.
(9) Monitor and evaluate the implementation of the bureau/office's Vital Records Program. Suggested methods are piggybacking on other review programs, such as Information Resources Management (IRM) reviews, management control reviews, special reviews, and/or the analysis of the test results of the records recovery plan. A suggested review/self-assessment tool is Appendix E: Self-Evaluation Guide in NARA's Vital Records and Records Disaster Mitigation and Recovery Guide.
E. Security Officer. The bureau/office Security Officer is responsible for the safeguarding of vital records containing classified information, in cooperation with the Vital Records Manager.
F. Continuity of Operations (COO) Planner. The bureau/office COO Planner is responsible for the safeguarding of emergency operating records, in cooperation with the Vital Records Manager.
1.7 Procedures. The Vital Records Manager in cooperation with program offices, the COO Planner, and the Security Officer will:
A. Inventory records to identify those vital to both emergency operating and legal and financial rights under emergency conditions.
B. Create a written inventory of vital records. The development of a written inventory of all bureau/office vital records should include the following items. All vital records maintained in electronic form should be coordinated with the bureau IRM office to determine if IRM-related contingency plans can meet the vital records off-site storage/recovery requirements.
(1) The name of the bureau/office responsible for the records series or electronic system containing vital information.
(2) The title of each records series or information system containing vital information (i.e., brief title/description found in the bureau/office records schedule).
(3) Identification of each series or system that contains emergency-operating vital records or vital records relating to rights (i.e., descriptive information about the records series or electronic system, purpose of the record, viz., the sources of the records, the type of vital record they are, etc.).
(4) The medium on which the records are recorded.
(5) The physical location for offsite storage of copies of the records series or system.
(6) The frequency with which the records are to be cycled (updated).
C. Develop a Vital Records Program that will identify:
(1) The emergency operating records needed at DOI relocation sites in order to perform their assigned responsibilities during and/or after an emergency/disaster. The bureau/office must identify the specific relocation site where the emergency operating records will be needed.
(2) The legal and financial records that the bureau/office believes should be safeguarded at a specified relocation site.
(3) Specific requirements for storing and periodically cycling (updating) copies of those records. This is especially important for electronic records. System documentation adequate to operate the system and access the records must be made available.
D. Ensure that vital records will be easily retrievable. Necessary finding aids (indexes of the vital records stored) must be available at each relocation/storage site to facilitate retrieval.
E. Periodically update and test the Vital Records Program. Via a data call, the Office of IRM will periodically (as needed) request certification of each bureau/office's update of their Vital Records Program and certification that the program has been tested. Each bureau/office should conduct a periodic review of its Vital Records Program with the assistance of selected program officials to determine its adequacy and accuracy. This review should include the list of vendors (with telephone numbers, address, and other relevant data) that may have to be called upon in case of an actual records emergency or disaster.
The Vital Records Program should also be periodically tested, much as fire drills and building evacuation procedures are tested. The test should include the records disaster recovery team and evaluate its activities as well as the usefulness and thoroughness of the records recovery plan. In determining the scope of the test, managers should consider all factors, such as, the risks associated with the loss of the vital records and the costs involved in a "live" test. For assistance in evaluating the effectiveness of the overall vital records program, refer to Appendix A: Vital Records Program Self-Evaluation Guide.
F. Protection methods and storage sites for vital records. Bureaus/offices must choose protection methods and storage sites for their vital records.
(1) Protection Methods: If using existing duplicates or duplicating the original records is chosen as a protection method, it is usually most economical to duplicate the original medium onto the same medium (i.e., paper to paper, microfilm to microfilm, magnetic tape to magnetic tape). Appropriate equipment should be selected to ensure the continued preservation of copies of the vital records until they are cycled (updated). Proper environmental conditions for storage of copies of vital records must be ensured, particularly for those records on fragile media (microfilm, magnetic tape or disks). Other special protective measures for vital records may include using fire-rated filing equipment for storage, or using lockable and/or steel safe filing equipment for proprietary or classified vital records. Refer to 442 DM 10, Storage of Classified Documents, for specific guidance.
(2) Storage Sites: Bureaus/offices should arrange for off-site storage of vital records in a facility not subject to the same emergency or disaster but still reasonably accessible to agency staff. The storage site for copies of emergency operating records may be different from the storage site for copies of records needed to protect legal rights. Whenever feasible, vital records should be stored in a properly equipped and environmentally controlled facility. Agencies may store emergency operating records at a FRC operated by NARA. Agencies should contact NARA first to determine if it has sufficient space to store the records, if frequent cycling of records is required, and what costs the agency may have to incur. An FRC will usually agree to a reimbursable agreement with agencies for records that require frequent cycling. Records needed to protect legal and financial rights may also be stored at any FRC. If vital records are recorded on a medium other than paper, agencies should check with the FRC before initiating the transfer to ensure that appropriate environmentally controlled space is available.
(3) Storage Considerations. Several factors need to be considered when deciding where to store copies of vital records. Copies of emergency operating vital records need to be accessible in a very short period of time for use in the event of an emergency or disaster. Copies of legal and financial records may not be needed as quickly. In deciding where to store vital records copies, bureaus/offices should treat records that have the properties of both categories, that is, emergency operating and legal and financial records, as emergency operating records.
(4) Periodic cycling (updating) of copies of vital records is essential. Bureaus/offices must determine the frequency of cycling (daily, weekly, monthly, annually, etc.) based on how current its vital records must be to meet its information needs and responsibilities.
G. Records Recovery. Each bureau/office should include records recovery procedures in its continuity of operations plan. The Vital Records Manager should work with other agency officials such as the COO Planner, IRM staff, facilities managers, and security staff in developing the records recovery plan. The records recovery plan should provide details about the following processes:
(1) notifying the appropriate persons immediately in case of emergency to relate details about the nature of the emergency and the level of threat to the records;
(2) assessing the damage to records as soon as possible after the emergency and taking steps to stabilize the condition of the records so further damage will not occur;
(3) assembling a records recovery team of bureau/office staff members to expedite stabilization of the records (generally only for major records disasters);
(4) consulting with contractors who provide records disaster recovery services if the damage assessment shows a need for their expertise;
(5) recovering the records and the information that they contain, or providing replacement of any lost recorded information when recovery is not feasible; and
(6) resuming normal business using the recovered records and information.
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Appendix A
VITAL RECORDS PROGRAM
SELF-EVALUATION GUIDE
This checklist reflects the National Archives and Records Administration's regulations and recommended practices for the development and implementation of Federal records disaster mitigation and records recovery programs. Bureaus and offices may find it useful in evaluating their records management procedures for vital records.
Contingency Planning
1. Have appropriate agency personnel, including the records officer, program officials, the emergency coordinator, facilities managers, IRM officials, and safety/security personnel, assessed the potential risks to the agency's operations and records?
2. Has the agency determined which of its functions are most critical and would need to be continued if an emergency or disaster struck the agency?
3. Has the agency identified those functions or activities that most impact the rights of the agency and the individuals directly affected by its actions?
Vital Records Program
4. Has the agency prepared and disseminated written information to appropriate agency staff, describing the vital records program, including the responsibilities of various agency officials?
5. Has the agency assigned an official responsibility for managing the vital records program and coordinating it with other appropriate officials?
6. Have liaison officers delegated responsibility for implementing the program in the agency's field offices?
7. Has the agency identified its vital records, i.e., its emergency-operating records and records needed to protect legal and financial rights.
8. Does the agency make copies of the vital records for offsite storage?
9. Does the agency store duplicates at a remote location not subject to the same fire or other risks (such as high-risk geographic areas prone to flooding or earthquakes) present in storage areas where original records are kept?
10. Are agency personnel trained in their vital records responsibilities?
11. Does the agency conduct a periodic review of its vital records plan and update it to ensure that it is current, complete, and usable in case of emergency?
12. If special records (such as electronic information systems or microform records) are designated as vital records, has provision been made for access to the equipment needed to use the records in the event of an emergency?
Records Protection
13. Has the agency established protective measures for all its records?
14. Has the agency given special attention to the protection of its vital records, regardless of the media on which these are maintained?
Records Recovery Program
15. Has the agency prepared a written issuance establishing a records recovery program and disseminated it to appropriate agency staff?
16. Has the agency designated an official responsible for the records recovery program?
17. Has the agency designated a records recovery team?
18. Has the records recovery team been trained?
19. Has the agency developed a list of records recovery consultants and reviewed it periodically for accuracy?
20. Does the agency maintain supplies and equipment required to recover records damaged in an emergency or disaster?
21. Does the agency conduct a periodic review of the records recovery plan and update it as necessary?
3/11/98 #3199
Replaces 12/4/78 #2126