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Department of the Interior

Departmental Manual

Effective Date: 7/11/94

Series: Information Resources Management

Part 380: Records Management

Chapter 2: Adequacy of Documentation

Originating Office: Office of Information Resources Management

380 DM 2

2.1 Purpose and Scope. 44 U.S.C § 3101 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. The records should be designed to furnish the information necessary to protect the legal and financial rights of the Government and of persons directly affected by the agency's activities. Federal agencies should not create and maintain records that are not needed to serve these purposes.

Proper documentation means identifying what information needs to be created or received to manage the organization and to meet the Department's legal responsibilities. Adequate documentation means determining how much information needs to be documented to successfully meet legal requirements. Identifying what and how much information the Department needs to create and maintain establishes the Department's recordkeeping requirements.

The guidance in this Chapter should be followed to establish Departmental recordkeeping requirements responsive to new statutes or regulations and to review existing recordkeeping requirements.

2.2 Authorities. The policies and procedures contained in this chapter are based on the general requirements of 44 U.S.C. § 3101 and implementing regulations issued by the National Archives and Records Administration (NARA) in 36 CFR Part 1222.

2.3 Policy. Departmental bureaus and offices shall identify, document, disseminate, and periodically review recordkeeping requirements for all required activities at all levels within the organization.

2.4 Departmental Responsibilities. See 380 DM 1.6 through 1.8.

2.5 Origin of Recordkeeping Requirements. Interior's requirements to create and maintain records pursuant to 44 U.S.C. § 3101 evolve from statements in statutes and regulations. Some laws and regulations require an agency to carry out specific responsibilities, while others apply to all or most Federal agencies. Furthermore, some laws (e.g. the Administrative Procedure Act and Superfund laws) address specific recordkeeping requirements, while other laws are more broadly written in terms of addressing the need to create and maintain records. In these cases, the translation of legal responsibilities into specific recordkeeping requirements may involve a great deal of judgement and coordination.

2.6 Identifying Recordkeeping Requirements. Records managers, program officials, attorneys, information access specialists, IRM personnel, and NARA's appraisal archivists should play a role in identifying and establishing agency recordkeeping requirements. To identify internal recordkeeping requirements they should:

A. Identify and review all pertinent statutes, regulations, Presidential or Secretarial Orders, policy documents, and other directive materials that relate to the subject program or function.

B. List all the related required activities or responsibilities identified in these materials.

C. Identify the kind of information the subject program or function needs to systematically create, receive, and maintain in its official capacity as documented evidence of carrying out these responsibilities.

D. Group categories of similar information together. The categories may relate to a particular subject or function, result from the same activity, document a specific transaction, or have some other relationship due to the creation or use of the information.

E. Determine whether each category of information is record or non-record material. (See 380 DM 1.6 and 1.7.) Each category of information that meets the standards of a record is referred to as a record series.

F. Project how long the Department may need to maintain the required information by asking the following questions. How long will the information be needed to successfully carry out Departmental responsibilities? How long must the information be kept to protect the legal rights and interests of the Department and of persons affected by the required activities? Does a statute of limitations apply? Is the information unique within the Federal government? Is the information important from a historical perspective?

G. Identify those record series that may contain proprietary, private, or otherwise sensitive information.

H. Prescribe the use of specific methods of recording the information within each record series (e.g. selection of media, organization and arrangement of the information, etc.) that will ensure the preservation of the information as long as it may be needed by the Federal government.

2.7 Developing Standards for Adequate Documentation. Record series should contain documentation that is sufficient to:

A. Identify the persons, places, things, activities, transactions, or matters relating to Departmental responsibilities.

B. Identify all the needed steps or procedures related to required activities or transactions at a level that will assist Interior officials and their successors in making informed decisions.

C. Make possible a proper scrutiny by the Congress or other duly authorized agencies of the activities of the Department.

D. Protect the financial, legal, and other rights of the Department and of persons directly affected by the Department's actions in the event of litigation or other challenges.

E. Ensure continuity and consistency in administering required activities or transactions within the Department.

F. Document the formulation and execution of basic Departmental policies, decisions, and necessary actions, including all significant decisions and commitments made by Departmental officials. Significant decisions made orally, by telephone, using electronic mail systems, in conferences or meetings and the deliberations leading up to the decisions should, to the extent appropriate and practical, be documented and incorporated into the agency files.

G. Document important Departmental board, committee, or staff meetings.

H. Ensure that only needed information is created and maintained by the Department.

I. Leave an enduring record of the Department's organization and mission.

2.8 Documenting Recordkeeping Requirements. If the Department's legal recordkeeping requirements are not adequately addressed in statute or regulation, they must be documented within internal program directives and appropriately disseminated within the organization. Illustrations 1 and 2, Recordkeeping Requirements Checklist and Worksheet, may be used to establish or review internal recordkeeping requirements.

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ILLUSTRATION 1

EVALUATION CHECKLIST

Identifying and Establishing Recordkeeping Requirements

for

(Identify target program, organizational component, etc.)

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ILLUSTRATION 2

RECORDKEEPING REQUIREMENTS WORKSHEET

for the

(List the Target Entity)

7/11/94 #3013

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