Records and Information Management Policy and Program

280 FW 1
FWM Number
Originating Office
Information Resources and Technology Management





1.1 What is the purpose of this chapter?

1.2 What is the scope of this chapter?

1.3 What is a Federal record?

1.4 What other terms do you need to know to understand this chapter?

1.5 What are the key authorities for this chapter?


1.6 What is the Service’s overall records and information management policy?


1.7 Who is responsible for records and information management in the Service?


1.1What is the purpose of this chapter? This chapter:

A. Describes the U.S. Fish and Wildlife Service’s (Service) Records and Information Management (RIM) program within the office of Information Resources and Technology Management (IRTM);

B. Establishes the position of the Service Chief Records Officer;

C. Provides policy to help ensure all employees create, maintain, and safeguard records that adequately and properly document Service activities in accordance with Federal laws and regulations, as well as Office of Management and Budget (OMB), National Archives and Records Administration (NARA), and Department of the Interior (Department) policies and guidance; and

D. Identifies roles and responsibilities for managing Service records throughout their lifecycle, including creation, maintenance, use, and disposition.

1.2 What is the scope of this chapter? This chapter applies to:

A. All Service employees, and

B. Contractors (as part of carrying out their contractual obligations), volunteers, interns, students, and other entities when they create, receive, access, or use Federal records, regardless of format (i.e., electronic, analog, etc.), on behalf of the Service. In this chapter we use the term “employee” to include employees and these other entities who work on behalf of the Service mission.

1.3 What is a Federal record?

A. 44 U.S.C. 3301 defines records as, “…all recorded information, regardless of form or characteristics, made or received by a Federal agency under Federal law or in connection with the transaction of public business and preserved or appropriate for preservation by that agency or its legitimate successor as evidence of the organization, functions, policies, decisions, procedures, operations, or other activities of the United States Government or because of the informational value of data in them.”

B. Recorded information includes all traditional forms of records, regardless of physical form or characteristics, including information created, manipulated, communicated, or stored in digital or electronic form (44 U.S.C. 3301). “Regardless of physical form or characteristics” means that the medium may be paper, film, disk, or other physical type or form, and that the method of recording may be manual, mechanical, photographic, electronic, or any other combination of these or other technologies (36 CFR 1222.10).

C. Federal records do not include:

(1) Library and museum material made or acquired and preserved solely for reference or exhibits, and

(2) Duplicate copies of records preserved only for convenience.

D. NARA puts records into two categories based on their value. These two categories help Federal employees determine preservation and disposition requirements:

(1) Permanent records, which are records that have archival value (see section 1.4B for a definition); and

(2) Temporary records, which are records that do not have archival value. Employees can dispose of these records after the Service no longer needs them or after a certain event or period has passed, in accordance with this policy and the applicable records schedule.

1.4 What other terms do you need to know to understand this chapter?

A. Adequate and proper documentation. A record of the conduct of Service business that:

(1) Is complete and accurate to the extent required to document the organization, functions, policies, decisions, procedures, and essential transactions of the Service; and

(2) Can provide the information necessary to protect the legal and financial rights of the Service and of a person directly affected by the Service’s actions.

B. Archival value. As determined by NARA, the enduring historical or other value that warrants NARA’s continued preservation of records beyond the period that is required for conducting Government business and functions. NARA’s Appraisal Policy defines the framework and guidelines that they use to determine archival value.

C. Disposition. Actions taken for records that we no longer need to conduct regular Service business. Disposition of a record may include deleting, destroying, or transferring the records to NARA or a NARA-approved repository.

D. Electronic information system. Technology that contains and provides access to computerized Federal records and other information. This includes major applications and also databases and spreadsheets created to capture data and information that the Service uses for program business functions and decision-making activities.

E. Electronic record. Any information that is recorded in a form that only a computer can process and that satisfies the definition of a Federal record. The term includes both record content and associated metadata. Examples of electronic records include, but are not limited to, emails, databases, documents developed in Microsoft® Word or other word processing software, spreadsheets, website content, and records from electronic information systems.

F. Essential records. Information an agency needs to meet operational responsibilities under national security emergencies or other emergency conditions (i.e., emergency operating records) or to protect the legal and financial rights of the Government and those affected by Government activities (i.e., legal and financial rights records).

G. Nonrecords. Informational materials that do not meet the definition of a record or that have been excluded from coverage, including multiple copies of publications and processed documents and library or museum materials intended solely for reference or exhibit. Examples of nonrecords include:

(1) Informational copies of correspondence, directives, forms, and other documents on which employees have not taken action;

(2) Routing slips and transmittal sheets that do not add any information to the materials that they are transmitting; and

(3) Physical exhibits, artifacts, and other material objects that do not provide information about the origin, functions, and activities of the Service.

H. Personal papers. Materials belonging to an employee that are not used to conduct Service business. Personal papers are not considered Federal records.

I. Records management. The planning, controlling, directing, organizing, training, promoting, and other activities involved with creating, maintaining, using, and disposing of records.

J. Records schedule. A NARA-approved and published manual or directive that aligns similar lines of business records with streamlined and simplified management across an organization’s enterprise. 

1.5 What are the key authorities for this chapter?

A. Disposal of Records (44 U.S.C. 33).

B. National Archives and Records Administration (44 U.S.C. 21).

C. OMB Circular A-130, Managing Federal Information as a Strategic Resource.

D. OMB Memorandum M-19-21, Transition to Electronic Records.

E. Records and Reports (18 U.S.C. 101).

F. Records Management (36 CFR 12, Subchapter B).

G. Records Management by the Archivist of the United States and by the Administrator of General Services (44 U.S.C. 29).

H. Records Management by Federal Agencies (44 U.S.C. 31).

I. 380 Departmental Manual (DM) 1, Records Management Program and Responsibilities.

J. 380 DM 2, Adequacy of Documentation.

K. 380 DM 3, Files Management.

L. 380 DM 6, Vital Records Program.


1.6 What is the Service’s overall records and information management policy?

A. Employees must keep records to maintain adequate and proper documentation of our functions, policies, decisions, transactions, and other activities. We must create records that are sufficient to:

(1) Identify the people, places, things, activities, transactions, and matters that relate to the Service’s mission and business-related activities;

(2) Help Service officials and their successors to perform their duties;

(3) Help Congress and other authorized oversight agencies or entities (e.g., the Department’s Office of the Inspector General) to oversee the Service’s work;

(4) Document the formulation and execution of Service policies, decisions, and actions, including all significant decisions and commitments Service officials make;

(5) Protect the financial, legal, and other rights of the Service and of people directly affected by the Service’s actions in cases of litigation or to meet other legal obligations;

(6) Document board, committee, or staff meetings in accordance with the recordkeeping requirements in 105 FW 4, Service Committees and 107 FW 5, Meetings, Recordkeeping, and Reporting (for Federal advisory boards); and

(7) Support the activities of the Service’s Privacy Act, Freedom of Information Act (FOIA), and Paperwork Reduction Act (Information Collection) programs.

B. After employees create records, they must maintain them throughout their lifecycle until their final disposition in accordance with applicable legal and statutory requirements by:

(1) Safeguarding records to protect their integrity and to prevent unauthorized access, removal, destruction, and loss;

(2) Retaining records in accordance with the applicable NARA-authorized records retention schedules;

(3) Organizing and maintaining records so that they are accessible to employees when and where needed in a usable format; and

(4) Maintaining records in electronic form, whenever possible, in an approved location or electronic records management system.

C. Employees must retain records for the length of time the applicable records schedule designates.

D. Employees must receive approval from the Service’s Chief Records Officer or designated RIM Specialists in IRTM before beginning records disposition actions. You can visit the Records and Information Management SharePoint to find contact information for the Chief Records Officer and RIM Specialists.

(1) Employees must follow the disposition procedures the Chief Records Officer (or designated RIM Specialist) establishes because records must be transferred or disposed of in accordance with NARA regulations (36 CFR Part 1226 and 36 CFR 1232-1235) and Service practices.

(2) After employees receive disposition approval for records, they should work with the RIM Specialist to dispose of the records by deleting, destroying, or transferring them to NARA.

E. Regions and programs must identify, protect, and manage essential (formerly known as vital) records as part of ensuring continuity of operations, as described in 090 FW 1, Continuity of Operations


1.7 Who is responsible for records and information management in the Service? See Table 1-1.

Table 1-1: Responsibilities for Records and Information Management

These employees…

Are responsible for…

A. The Director

Approving or declining to approve Servicewide RIM policies and procedures.

B. Directorate members

(1) Ensuring that all records within their purview are managed in accordance with Federal and Departmental law, regulation, and policy;

(2) Ensuring employees in their Regions or programs are aware of their records management responsibilities and are following  applicable RIM requirements; and

(3) Providing adequate resources for proper records management in their Regions or programs.

C. Associate Chief Information Officer (ACIO) (also known as the Assistant Director – IRTM)

(1) Designating an employee to serve as the Service’s Chief Records Officer;

(2) Providing overall leadership and direction for the Service’s RIM program;

(3) Ensuring the Service’s RIM program has the budgetary and other resources necessary to function effectively;

(4) Establishing and implementing policies, procedures, and standards related to RIM, including how to manage essential records; and

(5) Ensuring records management functionality and requirements are incorporated into the Service’s electronic information systems.

D. Chief, IRTM Policy and Planning Division

(1) Overseeing the Chief Records Officer (CRO) and the RIM program; and

(2) Assisting the ACIO and the CRO with developing and implementing policies, standards, and requirements related to RIM.

E. Service Chief Records Officer (CRO)

(1) Serving as the Service’s Responsible Records Officer (RRO) and carrying out associated responsibilities per Departmental policy;

(2) Implementing the Service’s RIM program and ensuring that it meets applicable Federal and Departmental requirements;

(3) Advising and providing technical assistance to Service leadership on existing and proposed RIM laws, regulations, and policies;

(4) Establishing procedures to assist employees with creating, maintaining, and disposing of Federal records;

(5) Maintaining and implementing records schedules for all records the Service creates or receives;

(6) Developing and disseminating RIM policies, standards, and requirements in accordance with Federal laws and regulations and Departmental policy;

(7) Ensuring employees are aware of their records management responsibilities and providing necessary training;

(8) Assisting the Department with updating and reviewing the Departmental Records Schedule;

(9) Assisting employees to comply with legal obligations and providing followup notifications for all legal and preservation hold orders affecting Service records;

(10) Serving as the Service’s liaison to the Department and NARA on matters related to RIM and participating in the development of new or revised Departmental RIM programs, initiatives, and processes;

(11) Ensuring, or delegating to a RIM Specialist to ensure, that the Service implements and uses Department-approved electronic records management system(s) appropriately;

(12) Participating in the Service’s Information Management and Technology (IMT) governance processes, as described in 270 FW 1, IRTM Senior Leadership and Governance, to ensure that records management requirements are incorporated into the Service’s IMT projects, investments, systems, and processes;

(13) Maintaining an inventory of Service electronic information systems and their associated records schedules;

(14) Conducting periodic evaluations of the Service’s RIM program and recordkeeping practices;

(15) Leading investigations and providing reports on actual or potential unauthorized removal or loss of records; and

(16) Helping programs and Regions identify, protect, and manage essential records as part of their continuity of operations planning activities.

F. Records and Information Management (RIM) Specialists within IRTM

(1) Serving as liaisons between the CRO, managers/supervisors, and Service employees within their areas of responsibility;

(2) Providing technical assistance and records management guidance to Service employees within their areas of responsibility;

(3) Coordinating with the CRO to:

     (a) Disseminate records management directives and guidance,

     (b) Provide training to staff within their areas of responsibility, and

     (c) Implement records management policies and procedures;

(4) Assisting offices within their areas of responsibility with:

     (a) Identifying and implementing recordkeeping requirements,

     (b) Maintaining a records inventory, and

     (c) Developing and implementing a comprehensive file plan;

(5) Working with employees and the CRO to dispose of records in accordance with the applicable approved records schedules;

(6) Coordinating with managers/supervisors within their areas of responsibility to implement any identified corrective actions to address records management deficiencies, as directed by the CRO;

(7) Assisting managers/supervisors to transfer records to an approved repository or NARA under the authorization of the CRO; and

(8) Notifying the CRO of any actual or potential loss of records they identify or that is reported to them and assisting in the investigation of the incident.

G. Managers/supervisors

(1) Ensuring employees under their supervision:

     (a) Follow applicable Departmental and Service records management policies and procedures,

     (b) Complete the required annual records management training, and

     (c) Understand their records management responsibilities;

(2) Supporting records management and recordkeeping activities within their respective areas, including the identification of essential records needed for continuity of operations;

(3) Directing employees to complete records management-related exit clearance activities when leaving the Service to ensure the Service maintains custody of records;

(4) Working with RIM Specialists and the CRO to transfer applicable records to an approved repository or NARA; and

(5) Assigning specific records management responsibilities to employees under their supervision and ensuring those employees have the responsibilities in their performance plans.

H. Employees

(1) Creating and maintaining records that reflect decisions and actions they take and that document the activities for which they are responsible;

(2) Maintaining records separately from nonrecords and personal papers;

(3) Managing and safeguarding records in accordance with applicable requirements, including while teleworking or working remotely, until they are authorized for disposition according to the appropriate approved records schedule and by the CRO;

(4) Coordinating with a RIM Specialist to carry out disposition of records in accordance with the applicable approved records schedule;

(5) Notifying their manager/supervisor, RIM Specialist, and the CRO of any actual or potential loss of records;

(6) Completing annual records management training;

(7) Complying with applicable legal obligations, including, but not limited to, preservation and legal holds;

(8) Working with their supervisor and RIM Specialist to identify and transfer Service records when ending their employment with the Service or moving to a new position within the Service;

(9) Identifying essential records for use for continuity of operations planning and ensuring those records are managed in accordance with the established plan for their programs/Regions; and

(10) Following established records management and recordkeeping policies, procedures, and best practices.