NARA circulates governmentwide draft records plan

Federal agencies would have until early next year to devise a plan for maintaining, preserving or disposing of their electronic records—- or at least have a timetable for doing so—- according to a draft electronic records policy being circulated governmentwide.

The plan, which has been given to government records officers and information technology managers by the National Archives and Records Administration, would allow NARA to determine whether specific categories of records should be preserved in electronic form and would allow the public to weigh in on these decisions.

The policy responds to a federal court ruling that overturned General Records Schedule 20, which is a regulation that let agencies delete all their e-mail and word processing files if they first printed out paper copies. Judge Paul Friedman said NARA must issue a new policy by Oct. 1.

The proposal, a copy of which was obtained by FCW but has not been publicly released, mainly addresses how agencies ought to manage documents stored in "live" electronic mail, word processing and other office automation applications, leaving open whether these digital files, or paper copies, should be considered their official records.

"We are not in the position, at least at this point, to say that agencies have to decide; [we are] not in the position of telling agencies what format they have to keep their records in," said Michael Miller, director of Modern Records Programs at NARA and head of the interagency Electronic Records Work Group that developed the plan. He said a new committee would be convened to devise guidelines for agencies that want to maintain their official files in digital form.

The policy includes a proposed new regulation covering "information technology records," consisting mainly of documents relating to the management and operation of agency information systems. Under the plan, most such records—- including billing information, system documentation, data documentation, source code and help-desk files—- could be eliminated up to three years after the systems, files or procedures to which they pertain are upgraded, replaced or otherwise become obsolete.

Although maintenance of at least some of these records is covered by existing policies, Burt Newlin, who oversees the Defense Department's electronic recordkeeping program, said the plan represents the first attempt to manage IT records comprehensively. "We cannot afford not to manage this information," he said. "It's become a critical resource."

According to the plan, whether agencies would be allowed to destroy records in their online systems would depend not only on the content of those records but also the extent to which the agencies can maintain copies in electronic recordkeeping systems. To help NARA make this determination, agencies would have to inventory their technical capabilities, including which operating systems and office automation packages they use, how they name files and how they store information in shared directories.

NARA has asked agencies to submit unofficial comments on the draft by July 2. A revised plan is expected to be released to the public for a 30-day comment period during the week of July 20. Miller said the plan would probably take effect after the Oct. 1 date set by Judge Friedman.