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This time it's PERSONAL Frequent Questions about Personal Papers

What are personal papers?

Personal papers are defined in federal regulations as:

"...documentary materials, or any reasonably segregable portion thereof, of a private or nonpublic character that do not relate to or have any effect upon the conduct of agency business." 36 CFR 1222.36(a)

There are three generally accepted classes of personal papers:

  1. Materials accumulated before joining government service that are not used subsequently in the transaction of Government business;
  2. Materials relating solely to an individual's private affairs, such as outside business pursuits, professional affiliations, or private political associations that do not relate to agency business;
  3. Diaries, journals, or other personal notes that are not prepared or used for, or circulated or communicated in the course, of transacting Government business.
What is EPA's policy on retaining personal papers?

EPA's schedule 999 - Personal Papers states that personal papers may be destroyed or removed at the owner's discretion. EPA's records schedules document Agency policy on retaining all documentary materials.

How do I decide what's what?

There are three common tests for whether something is a personal paper. Although these tests are not definitive, they do offer general guidance for making day-to-day decisions. If a document:

  1. Is a necessary part of the "adequate and proper" documentation of an Agency program, its functions, or its policy and decision making process, it should be considered a record.
  2. Relates solely to an individual's own affairs, it is probably a personal paper. If it relates to an individual's job, is done on Government time, or with Government equipment, it should be considered a record until proven otherwise.
  3. Is prepared for your own use and is not circulated to other staff or used as the basis for agency action, it is probably a personal paper.

Labeling materials "personal," "private," or "confidential" does not make them personal papers. Documents marked with those or similar designations are federal records and not personal papers if they are used in the transaction of agency business.

What are examples of personal papers?

The line between personal papers and records is not always clear. Here are some examples of records and personal papers. If you have any questions about specific documents or files, you should ask trained records management staff to review them.

These are "personal papers":

  • Materials for your activities as a member of a union or a professional association.
  • A journal of daily events maintained for your personal use that is separate from the schedule of daily activities you use for your job.
  • Notes taken for your personal use at a training course.
  • Notes taken for your personal use at a meeting that (1) are not circulated to other staff, and (2) are not used as a basis for action.

These are not "personal papers":

  • Calendars, appointment books, schedules of activities, etc., that record your activities as a federal employee.
  • Drafts, background materials, notes, and other documents prepared in the course of your assigned duties, even though these are not made part of the "official file."
  • Speeches given or articles written in your capacity as an Agency employee or Government official.
  • Notes used to give a briefing to Agency staff.
Can I keep copies of my work?

Many employees want to keep copies of materials which they have drafted, reviewed, or otherwise acted upon. You are permitted to accumulate extra copies of these documents for your own convenience provided that retention would not:

  • Diminish the official record of the Agency,
  • Violate confidentiality required by national security, privacy, or other interests provided by law, or
  • Exceed normal administrative business economies.

Technically speaking, such extra copies are considered nonrecord material and not personal papers. However, officials can arrange to take the extra convenience copies with them when they leave the Agency or move to another job within the Agency.

If you wish to keep copies of your work, it is much easier to make the copies on a regular basis rather than to wait until you are departing.

What's the best way to manage my personal papers?

If you keep personal papers in your office, there are three simple rules you need to follow to manage them properly.

  • Clearly designate the files as personal papers.
  • Maintain them separately from official Agency records.
  • If you receive a document that contains information about both private matters and Agency business, the document is a record, and the part that concerns the Agency business must be made part of the official record. There are two means of doing this. You can immediately copy the document with the personal information deleted and treat the sanitized copy as the Agency record, or extract the Agency business portion and add the extract to the Agency files.
How can I get additional guidance?

If you have policy questions about your personal papers, you should contact the Records Help Desk. You can find additional guidance in the following publications:

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