Records Management Self-Evaluation Guide

2001 Web Edition

Note: This version is based on Records Management Self-Evaluation Guide, National Archives and Records Administration Management Guide Series, College Park, MD (1995), 22 pp. This web edition varies slightly from the printed version. The text has been changed to update organizational information, reflect changes in regulations, and remove references to outdated or out-of-print publications.

Table of Contents

Introduction
Section I. Program Management
Section II. Records Creation/Recordkeeping Requirements
Section III. Records Maintenance (General)
Section IV. Maintenance of Special Records
Section V. Records Disposition
Section VI. Vital Records
Appendix A. For Further Information and Assistance
Appendix B. Records Management Publications
Appendix C. Regional Records Services Facilities

Introduction

The National Archives and Records Administration (NARA) developed this self-evaluation guide for Federal agencies to use as an overview of the basic components of a records management program. This guide is provided to help agencies in implementing the requirement to conduct self-evaluations (36 CFR 1220.42). Using this guide will assist agencies in making a preliminary assessment of the status of their records management programs and in identifying major problems and setting priorities for program improvements. Other NARA publications provide additional details regarding records creation, maintenance, and disposition policies and procedures. (Relevant publications are cited at the end of each Section of this guide and a complete list with information for ordering copies is in Appendix B.)

Although this guide provides a framework for general evaluation of a records management program, agencies that wish to conduct a more in-depth review may add more specific questions based on other NARA records management publications. Agencies may also modify or add questions to accommodate specialized records and recordkeeping practices. No guide developed for government-wide use can replace audit or evaluation activities tailored to the unique organization and operations of each agency.

This guide is divided into six broad Sections, most of which are subdivided by subject. Agencies may use the entire guide to conduct a comprehensive program review or select Sections to focus on specific areas such as records disposition or files maintenance. The guide consists of a series of questions to be answered either "yes" or "no." A "yes" answer indicates compliance with NARA records management regulations and recommended practices.

The term "records officer" is used generically to include headquarters, site, field office, or facility records managers. All other terms are defined in NARA records management regulations (36 CFR 1220.14, 1230.4, 1234.2, and 1236.14).

Section I. Program Management

An effective Federal records management program requires a clear definition of program objectives, responsibilities, and authorities; sufficient resources to administer the program; continuing training for staff; and regular internal evaluations to monitor compliance and program effectiveness. The benefits derived from such a program include economy and improved efficiency through ready access to complete and accurate information, avoidance of unnecessary costs for records storage, protection of rights, and assurance of continuity of operations.

A. Program authorization and organization

Yes	No
		1.	Has the agency formally designated a records officer with responsibility for carrying out a records management program?
		2.	Does an agency directive(s) define the role and responsibilities of the records officer and the scope of the records management program and provide authority to the records officer to conduct an effective agency-wide program?
		3.	Has the agency formally incorporated its records management program into the information resources management program?
		4.	Does the headquarters records officer provide program direction to a network of records liaison officers at field sites and in major programs throughout the agency?
		5.	Are records management responsibilities included in the position descriptions for records liaison officers?
		6.	Does the agency records officer routinely communicate with all records liaison officers?
		7.	Are all employees informed of the identity and role of the records officer and the liaison officer serving their office?
		8.	Does the agency records officer participate in planning for new electronic information systems and in major modifications to existing systems to ensure incorporation of recordkeeping requirements and records disposition procedures?
			a. Is the records officer involved in the development of micrographic applications?
			b. Is the records officer involved in the development of electronic recordkeeping systems, including procurement of computer equipment?
			c. Is the records officer involved in the development of document imaging systems?

B. Guidance and Training

Yes	No
		1.	Has the agency records officer received training in Federal records management regulations, policies, and procedures?
		2.	Do records liaison officers, secretaries, file clerks, and others with regular records duties receive training in records maintenance and filing procedures and records disposition?
		3.	Does the records officer send to all records liaison officers records management guidance from NARA and other oversight agencies?
		4.	Is records management guidance received from oversight agencies such as NARA, tailored, when appropriate, to reflect the agency's specific procedures prior to dissemination to appropriate agency staff?
		5.	Does the agency brief senior officials and program administrators on the importance of records management and records handling responsibilities?
		6.	Have NARA, GSA, and OMB electronic records regulations (Titles 41 and 36, Chapter XII, of the CFR and OMB Circular A-130) and guidance been distributed to all employees who are responsible for managing electronic information and recordkeeping systems?

C. Internal evaluations

Yes	No
		1.	Does the records officer, with the assistance of liaison officers, periodically evaluate records management practices?
		2.	Do these evaluations include electronic records?
		3.	Are written evaluation reports prepared?
		4.	Are evaluated offices required to respond to the evaluation reports promptly?
		5.	Does the records office staff or records liaison official follow up to determine if offices implement necessary corrective action or recommendations for improvements?

Section II. Records Creation/Recordkeeping Requirements

Ensuring adequacy of documentation in any information system depends on the clear articulation of recordkeeping requirements. Recordkeeping requirements specify the creation and maintenance of specific records to document agency operations and activities; facilitate action by agency officials and their successors; permit continuity and consistency in administration; make possible a proper scrutiny by Congress and other duly authorized agencies; protect the rights of the Government and those affected by its actions; and document important meetings and the formulation and implementation of basic policy and decisions.

A. Creation of records/adequacy of documentation

Yes	No
		1.	Has the agency provided guidance for all employees on the definition of Federal records and nonrecord materials, including those created using office automation, and the ways in which they must be managed?
		2.	Does each office or program have written guidance on what records, including electronic records, are to be created and maintained and the format of the official copy?
		3.	Has the agency issued guidance and instructions for documenting policies and decisions, especially those arrived at orally?
		4.	Has the agency issued guidance on the record status of working papers/files and drafts?
		5.	Has the agency issued guidance on personal papers?
		6.	Do agency procedures require creation of finding aids such as captions and indexes to facilitate access to individual files or record items, when appropriate?

B. Contractor records

Yes	No
		1.	Do contracts identify which contractor-created records are Federal records?
		2.	Particularly when electronic records are involved, do agency contracts specify the delivery of background data that may have further value to the agency in addition to the final product?
		3.	Do agency contracts involving development of electronic systems specify the delivery of systems documentation to the agency along with the final product?
		4.	Are deferred ordering and delivery of data clauses included in contracts when it is impractical to identify in advance all electronic data that should be delivered to the Government?
		5.	Does the agency provide to contractors the regulations and procedures governing Federal records?

For further information, see "Documenting Your Public Service" and "Agency Recordkeeping Requirements."

Section III. Records Maintenance (General)

Proper management of records ensures that complete records are maintained; records can be located when needed; records, nonrecord materials, and personal papers are maintained separately; and the identification and retention of permanent records are facilitated. Proper records maintenance also contributes to economy of operations by facilitating records disposition. This Section covers general records maintenance policies and practices, regardless of media, and several aspects of records maintenance that apply to paper-based records. The next Section specifies additional requirements for special records, i.e., records other than traditional paper text.

A. General

Yes	No
		1.	Has the agency established standards and procedures for classifying, indexing, filing, and retrieving records and made them available to all employees?
		2.	Is access to all records, regardless of media, limited to authorized personnel?
		3.	Are cutoffs clearly defined and implemented for each records series?
		4.	Are permanent series of records identified and maintained separately from temporary records?
		5.	Has the agency established and implemented regulations or procedures for the storage of security classified, Privacy Act, and other restricted records?

B. Paper-based Records

Yes	No
		1.	Has each office designated official file locations (file stations)?
		2.	Is a file plan for each series of records maintained at each file station?
		3.	Does each office have procedures for filing, charging out, and refiling its records?
		4.	Are file drawers and folders labeled correctly?

Section IV. Maintenance of Special Records

Special records are those in formats other than traditional paper text files, i.e., electronic, audiovisual, cartographic, and architectural records. The physical properties of the materials used to create microfilm and special records require additional standards for their maintenance.

A. Electronic Records

Yes	No
		1.	General. The following questions apply to all electronic information systems that contain Federal records, regardless of media or application:
			a. Are records in agency electronic information systems readily identifiable?
			b. Do electronic recordkeeping systems that maintain the official copy of text documents on electronic media provide indexing or text search capabilities?
			c. Do electronic recordkeeping systems require user identification codes or passwords to control access and ensure integrity of the documents?
			d. Does the agency regularly back up electronic records to safeguard against loss of information due to equipment malfunction or human error?
			e. Does the agency avoid the use of diskettes for the exclusive long-term storage of permanent or unscheduled records?
			f. Do electronic recordkeeping systems provide a standard interchange format, when necessary, to permit the exchange of electronic documents between agency components using different software/operating systems and the conversion or migration of documents from one system to another?
			g. Does the agency maintain complete and up-to-date technical documentation for each electronic information system that contains Federal records?
			h. Does the agency safeguard and maintain all software and hardware required to read electronic records throughout their life?
			i. Are procedural controls in place for all electronic recordkeeping systems (magnetic and imaging) to protect the integrity of the Federal records and their legal admissibility under the rules of evidence?
		2.	Magnetic media. In addition to applying the questions under subSection A-1, Electronic Records - General, of this Section, the following questions should be applied to ensure the proper maintenance of records on magnetic media:
			a. Has the agency implemented a standard procedure for external labeling of the contents of diskettes, disks, magnetic tape reels or cartridges?
			b. Are tapes used for permanent and unscheduled records tested within 6 months prior to use to verify that they are free of permanent errors?
			c. Are tapes used for permanent and unscheduled records rewound under controlled tension every 3 years?
			d. Is an annual statistical sample of tapes used for permanent and unscheduled records read to identify any loss of data and to discover and correct the causes of data loss?
			e. Are tapes used for permanent and unscheduled records copied before they are 10 years old onto tested and verified new tapes?
			f. Are magnetic media containing permanent or unscheduled records stored under recommended temperature and humidity conditions (between 62 and 68 degrees Fahrenheit and constant relative humidity between 35 and 45 percent), and is the media protected from potential exposure to magnetic fields?
		3.	Office automation applications. In addition to applying the questions of subSection A-1, Electronic Records - General, of this Section, special consideration should be given to electronic records created using personal computers (electronic mail, word processing documents, databases, and spreadsheets).
			a. Have all agency employees using personal computers received training and guidance in determining record status of documents that they create with office automation applications?
			b. Has the agency implemented procedures for maintaining Federal records created using personal computers in an official file (hard copy or electronic recordkeeping system)?
			c. Are all agency staff who use computers trained in procedures to avoid the unintentional loss of records, including techniques for backing up files and for handling diskettes?
		4.	Optical Imaging Systems. In addition to applying the questions of subSection A-1, Electronic Records - General, of this Section, the following questions should be used in evaluating compliance with recordkeeping requirements for optical imaging systems:
			a. Do CD-ROM disks used to store permanent records meet NARA transfer requirements?
			b. Do optical imaging systems conform to NARA policy requiring the disposition of original records when converting to an optical digital data disk storage system?

B. Audiovisual Records

Yes	No
		1.	Are original and use copies of audiovisual records maintained separately?
		2.	Are finding aids such as indexes, captions, lists of captions, data sheets, shot lists, continuities, review sheets, and catalogs (published or unpublished) maintained for all audiovisual records?
		3.	Are cross-references to closely related textual records maintained with audiovisual records?
		4.	Has the agency instituted procedures to ensure that information on permanent or unscheduled magnetic sound or video media is not erased or overwritten?
		5.	Does the agency retain original photographic images created electronically (digital photography)?
		6.	Does the agency maintain originals of permanent or unscheduled photographs scanned into computer programs?
		7.	Does the agency store permanent audiovisual records, particularly color films and photographs, in environmentally controlled space (72 degrees Fahrenheit or less and the relative humidity between 30 and 40 percent)?

C. Cartographic and Architectural Records

Yes	No
		1.	Are maps and drawings stored flat in shallow-drawer map cases rather than folded or rolled?
		2.	Are permanent maps and drawings stored in acid-free folders?
		3.	Are large, heavy atlases and other bound volumes of maps or drawings stored flat, preferably on roller shelves to facilitate moving them without damage?
		4.	Do adequate finding aids such as indexes exist for cartographic and architectural records?
		5.	Are cross-references to closely related textual records maintained with cartographic and architectural records?

D. Micrographic Records

Yes	No
		1.	Are records on microform arranged and indexed to permit ready retrieval of individual documents?
		2.	Do microforms contain a title header or initial target page that identifies the records?
		3.	Are boxes containing microforms individually labeled with the records series title and date span of the records, and are they sequentially numbered?
		4.	Are permanent and temporary records filmed separately?
		5.	Are silver gelatin and nonsilver microforms filed separately?
		6.	Are silver gelatin master microforms of permanent and unscheduled records inspected every 2 years while these records are in storage?

For further information, see "Managing Audiovisual Records"

Section V. Records Disposition

Records disposition is a critical element of records management. The records disposition program enables agencies to dispose of records that are no longer needed so only those active records needed for current business are maintained in costly office space. Under records schedule provisions, agencies may destroy records or transfer them to records centers or storage areas. The records disposition program contributes to economical and efficient agency operations. Clearly written, up-to-date, and properly implemented comprehensive records schedules form the basis for a sound records disposition program.

NARA issues General Records Schedules (GRS) for temporary records common to most agencies. The General Records Schedules include records relating to civilian personnel, fiscal accounting, procurement, communications, printing, and other common functions and certain nontextual records. Because these schedules provide disposition authority, agencies do not have to schedule those records individually, unless a deviation from the GRS disposition standard is needed. Agencies may request authority to apply a disposition standard different from the GRS by submitting an SF 115, Request for Records Disposition Authority, along with a justification for the deviation. However, agencies must schedule all other Federal records they create or receive.

Records schedules for Federal records must be approved by NARA before implementation, and once approved, they are mandatory. Agencies must also request NARA approval for transferring records to any other Federal agency or donating them to an individual or non-Federal institution. Permanent electronic, audiovisual, cartographic, and architectural records should be scheduled for transfer to the National Archives as soon as possible because of their fragility and special preservation needs.

A. Records Disposition Schedule Development

Yes	No
		1.	Are records schedules based on inventories? Are the inventories updated periodically to reflect new records series or electronic information systems, changes in recordkeeping practices, or changes in programs resulting from legislative or regulatory changes?
		2.	Do records schedules contain a clear and complete description of records series that reflects the content and arrangement of the files? Do schedules contain a clear and concise description of electronic recordkeeping systems that reflects the purpose, content, sources of information, and outputs?
		3.	When the same information is in both electronic and paper formats, other than records covered by the General Records Schedules, are both formats separately scheduled?
		4.	Do disposition instructions include provisions for cutoff (file break), instructions for retiring appropriate hard copy records to agency storage facilities or a records storage facility, transfer of all records proposed for permanent retention to the National Archives, and specific retention periods before final disposition of all records? Do the disposition instructions for electronic records require the transfer to the National Archives of permanent electronic records as soon as they become inactive?
		5.	Do program officials review proposed records schedules relating to their office or function?
		6.	Are proposed schedules for records with legal rights implications reviewed by the agency's Office of General Counsel?
		7.	Are proposed schedules cleared by the General Accounting Office if they propose destruction of program records in less than 3 years or if they deviate from GRS coverage of records related to fiscal accounting or claims?
		8.	Has the agency issued a handbook, manual, or directive that contains records disposition policies and procedures as well as the GRS and NARA-approved agency records schedules?
		9.	Are records disposition reviews periodically conducted to identify new records series and information systems that should be scheduled and changes in recordkeeping practices that require records schedule revision?

B. Records Disposition Schedule Implementation

Yes	No
		1.	Does the agency records officer monitor implementation of the records schedule, both in headquarters and field facilities?
		2.	Does the agency provide copies of NARA-approved records schedules to all relevant offices, both in headquarters and in the field?
		3.	Are records destroyed only in accordance with NARA-approved records schedules?
		4.	If not incorporated into the agency records disposition manual, are the General Records Schedules applied to pertinent records of the agency or office?
		5.	Do file custodians take prompt action to cut off files, destroy records whose retention periods have expired, and retire eligible records to a regional records service facility in accordance with schedule provisions?
		6.	Are permanent records transferred to the National Archives as provided in the records schedules?

For further information, see "Disposition of Federal Records"

Section VI. Vital Records

The vital records program is intended to assist agencies in identifying and protecting those records essential to continuing their operations under other than normal business conditions and to protecting the rights of the Government and those individuals directly affected by its actions.

Yes	No
		1.	Has the agency assessed potential risks to the agency's records?
		2.	Has the agency issued a directive, or a comparable issuance, authorizing the vital records program and specifying the responsibilities of various agency officials?
		3.	Has the agency designated a vital records manager to coordinate the program?
		4.	Has the agency identified its vital records, i.e., its emergency operating records and legal rights records?
		5.	Does the agency periodically review its vital records plan and update it as necessary?
		6.	If special media records (such as electronic or microform records) are designated as vital records, have provisions been made for access to the equipment needed to use the records in case of emergency?

Appendix A. For Further Information and Assistance

Contact the agency records officer, general counsel, and information security officer for policy guidance and advice.

Call the NARA Life Cycle Management Division at 301-713-6677 or send an e-mail message to records.mgt@nara.gov with questions or to request the following services:

Briefings for agency officials
Training services in such areas as improving the management of an agency's files
Consultations about specific agency records maintenance problems and practices
Determining record status
Scheduling records for disposition

Additional guidance also is available in NARA's management guide, "Agency Recordkeeping Requirements" (1995). That guide is available on the NARA web site, as are the NARA records management regulations and other publications, including a NARA bulletin on Protecting Federal Records and Other Documentary Materials from Unauthorized Removal.

Appendix B. Records Management Publications

Apendix C. Regional Records Service Facilities

NARA

Records Managers

Records Management Resources

Records Management Self-Evaluation Guide