NARA records draft plan on its way to OMB

The National Archives and Records Administration is floating a pared-down plan for how agencies should manage their information systems records.

The draft plan, which is headed for Office of Management and Budget review, covers most documents that relate to agencies' internal information technology policies and daily operations. It would not cover files that relate information systems to agency programs or missions, such as IT strategic plans.

Mark Giguere, an information management specialist with NARA, said his agency simplified its original proposal after agencies asked for fewer categories of records to maintain and fewer distinct retention periods. "There's much more simplification and aggregation,'' he said.

The plan is part of revisions NARA is making to General Records Schedule 20, its policy for maintaining electronic records that was voided by a federal judge 18 months ago. The agency already has issued a new policy for the government to catalog e-mail, word processing documents and other digital files that relate to its programs.

The first proposal, made a year ago by NARA's Electronic Records Work Group, outlined 52 types of records, each with its own retention period, that agencies would have to maintain. The latest version, circulated among federal agencies in April and obtained by FCW this month, has 35 categories.

Under the latest plan, agencies would, in most cases, be required to keep their files for three years before destroying them, although some records would only have to be kept for a year, and others, such as reports from databases, could be deleted as soon as they were accepted by the people who requested them.

The first proposal had retention periods ranging from a few system backup cycles to six years.

However, Giguere said NARA could not address all the agencies' demands. "They also wanted to move solely to time-based retentions and move away from event-driven retentions,'' he said. "We weren't able to accommodate that as much.''

That, he added, is because whether a document needs to be maintained sometimes depends on an agency's actions. One example of this in the proposal is an instruction to keep application development files active as long as the applications to which they pertain are operating or until the records created using that application have been destroyed.

Giguere said NARA will consider a final set of comments from federal agencies, which it received this month, before sending the proposal to OMB. After OMB approves it, NARA will seek public comment.

The Federal Information and Records Managers Council (FIRM), a group recently formed by agency records officers to weigh in on government information policies, told NARA it "appreciate[d] that the conditions for destroying these records have been simplified.''

But FIRM said a few instructions were not clear, and some others, such as what to do with backup tapes, were missing.

The group asked whether one directive, for maintaining the application source code needed to retrieve and maintain electronic records and other digital files, would turn software applications themselves into federal records.

Rich Kellett, director of the Emerging Policies Division at the General Services Administration, said he had not seen the latest plan, but that such regulations in general should give IT managers as much discretion as possible. Maintaining system records can affect how systems operate, and IT managers are "the people on the front line balancing cost and performance,'' he said.