Electronic Records

282 FW 4
FWM Number
282 FW 4, FWM 167, 01/04/95
Originating Office
Information Resources and Technology Management

4.1 Purpose. The purpose of this chapter is to present policy, procedures and information related to the creation, maintenance, and disposal of electronic records.

4.2 Scope. Electronic records include numeric, graphic and text information which may be recorded on any medium capable of being read by a computer and which satisfies the definition of a record. This would include, but is not restricted to magnetic media, such as tapes and disks/diskettes; and optical disks. This chapter also applies to all electronic record systems, whether on microcomputers, minicomputers, or main-frame computers, regardless of storage media, in network or stand-alone configurations.

4.3 Authorities. The following authorities govern the requirements for creation, use, preservation, and disposition of electronic records.

A. 44 U.S.C. 2904, 3101, 3102, and 3105 (General responsibilities for records management, Records management by agency heads, Establishment of program of management, safeguards)

B. 40 U.S.C. 759, Computer Security Act of 1987

C. 36 CFR 1234, Electronic Records Management

4.4 Responsibilities. The following positions have responsibilities related to electronic records management.

A. Service Records Management Officer of the Policy and Directives Management - Staff is the Service's contact for the operational activities identified with electronic records management. The following duties apply to that position:

(1) Provides information, training, and guidance related to the care, retention and disposal of electronic records.

(2) Serves as the liaison point between the National Archives and Records Administration (NARA) and Service related to the scheduling, retention, and disposal of electronic records.

B. Chief, Division of Information Resources Management (IRM) is the Service's technical contact for activities related to electronic records. As such, the following duties apply to that position:

(1) In accordance with OMB Circular A-130, conducts the IRM reviews.

(2) Assists programs in their selection of appropriate electronic storage media.

(3) Provides guidance and support related to the protection and security of electronic records.

(4) As required by OMB Circular A-130, maintains a catalog of automated information systems with electronic data.

C. Employees who create electronic records have a significant role in the development, maintenance, retention, and disposal of those records. They have the following responsibilities related to electronic records:

(1) Coordinate with the Division of Information Resources Management regarding the selection of electronic storage media, inventory, and protection and security of electronic records.

(2) Report new and existing records systems to the Service Records Management Officer in order to ensure their retention and/or timely disposal.

(3) Report new or existing systems of records which contain Privacy Act material to the Service Records Management Officer and to the Bureau Information Resources Security Administrator in order to ensure that such systems are adequately protected and reported.

(4) Provide adequate care and maintenance of electronic records (including electronic mail messages) within their possession.

(5) Ensure that the Government's interests are protected by retaining records for the approved period of time and ensuring the proper destruction of those electronic records that are eligible for disposal.

4.5 Definitions. Definitions related to electronic records and recordkeeping may be found in Exhibit 1 of this chapter.

4.6 Guidelines for management of electronic records are similar to those for paper or hardcopy records.

A. However, the transitory nature of such records requires more careful attention to certain aspects of records management in order to ensure the protection of Government property, interests, and history. Details such as selection of electronic media, standardization of records creation procedures, documentation, care and handling of records, records security, and retention and disposal of records require more consideration. All employees should receive adequate training regarding the care and handling of electronic media and records.

B. Electronic records have the same disposal as their paper or hardcopy counterparts. It is the subject matter of the record rather than the format that determines eligibility for disposal or transfer to Federal records repositories. For information on which records to keep, dispose of, or transfer, employees should consult the Service Records Schedule at 283 FW 2, Appendix 1.

4.7 Selection of Electronic Storage Media. Appropriate media and systems for storing agency records throughout their life should be selected. The information needed to establish recordkeeping requirements and retention periods for records can also serve as valuable input for management decision related to the design or update of an information system. Personnel should consider which electronic medium, equipment configuration, and software are best for current and future records storage, access, and retrieval. The following should be used as guidelines for selection.

A. The media permits easy and timely retrieval.

B. The media facilitates distinction between record and nonrecord material.

C. The media allows for retention of records in a usable format until their authorized disposition date.

D. The media meets NARA requirements for transfer of permanent records (reference Part 6.20 of this chapter).

E. Factors pertaining to records such as the necessary maintenance to retain the records, the cost of storage and retrieval, records density, and access time for records retrieval have been considered.

F. The ability to transfer information from one medium to another (portability of the medium) has been considered.

G. The different needs for retaining system data based upon the different needs of the users have been considered (i.e. will the record be needed on a temporary basis or for legal or audit purposes).

4.8 Records Creation processes should be standardized. A label such as "Smith 5" or "Jane 3" is not very useful. Labels which include the titles of subject matter and dates are more readily identifiable. Users should strive to keep similar subject matter on the same electronic media (disk, tape, film, or reel). Information considered "sensitive" (as defined in 270 FW 7. 2, the Service's chapter on Automated Information System Security) should be labeled and protected accordingly. This "file drawer" approach keeps those records with similar disposal dates together and allows records accession, disposition, and transfer to Federal records repositories to be more easily accomplished.

4.9 Documentation. The contents of records need to be adequately documented, currently maintained and indexed. Electronic indices should be able to assist in locating the records based upon the characteristic of the particular record. These would include such things as date, subject, sender, receiver, and number (case, contract, purchase order, etc.) How the index operates should be part of the system documentation. Documentation requirements vary depending upon whether the records are data files or whether they are text documents.

A. Documentation for electronic records that are data files should include the following.

(1) A narrative description of the system (date and purpose of its creation, program area responsible for its creation and maintenance, other systems with which it is associated, is part of or may overlap; and authorized disposition date).

(2) Physical and technical characteristics of the records such as record layout which indicates the fields within the record, their name, size, relative position, type of data (alphabetic, decimal, numeric). A printout of the record label may often suffice.

(3) Other technical information required to read or process the record (such as hardware and software on which it was created or with which it is compatible, identity of those who have knowledge of required system or personal passwords, printer specifications; whether the system is the official file copy and, if not, the location of the official file copy and its format).

B. Documentation for electronic records that are text documents should include:

(1) Clear external labels which indicate the contents of the file, office of origin, file code (if used), any key words for retrieval, encompassing dates of information, security classification, sensitivity with regards to the Privacy Act of 1974, and authorized disposition (see 283 FW 2).
(2) Clear internal labeling which readily indicates the subject matter of the document, addressee(s) (if any), signatory, author, and date and purpose of the text's creation. Such documentation is usually found at the end of the text - after the signatory and courtesy copy lines.

4.10 Records Retrieval. Records should be easily retrievable by authorized personnel through the use of various techniques such as indexing or a text search systems. Purchase of new software or computer equipment should make an allowance for its compatibility with existing record systems, or existing systems should be converted. Permanent records should be transferred to NARA (see 283 FW 2 for identification of the Service's permanent records). NARA has defined the acceptable formats for the exchange, conversion, or migration of information by those authorized users on different software/operating systems.

4.11 Care and Maintenance of Electronic Records. Because of the transient nature of electronic records, care and maintenance should be paramount. Employees should avoid using floppy disks for the exclusive long-term storage of permanent or unscheduled records. Programs should ensure that information is not lost because of changing technology or deterioration. Conversion of storage media to provide compatibility should be done soon after receipt of new hardware or software. Electronic records should be backed up regularly to safeguard against the loss of information due to equipment malfunction or human error.

A. The following are guidelines for the maintenance of magnetic disks containing record material.

(1) Maintain a clean working environment. Contamination of the flexible disk surface is a serious cause of data losses.

(2) Avoid finger contact with the exposed surface of electronic media.

(3) Clean the flexible disk drive regularly at its insertion slot position.

(4) Have the read/write heads professionally cleaned on an occasional basis.

(5) Always return the flexible disk into its protective envelope after it is used. Don't scatter the disks around on table tops and desks in a random fashion.

(6) Don't fold, flex, or put magnetic disks over a heater, near a magnet or magnetic area, or near a telephone.

(7) Don't put a rubber band or a paper clip onto the flexible disk envelop. It may cause permanent damage.
(8) External labels should be written prior to application on the electronic medium or, if necessary to write on a label that is already attached, it should be done with a soft, fiber-tipped pen. Erasure should never occur on electronic material as it may contaminate the disk and cause loss of information.

(9) Temperatures between 50 degrees to 125 degrees Fahrenheit (10 to 51.6 Celsius) and relative humidity between 8 percent and 80 percent are recommended as general environmental requirements by the American National Standards Institute for storage of electronic medium.

(10) Flexible disks should be stored in a vertical position in a storage container.

(11) Make backup copies immediately of all disks that contain record material - especially vital records. Store them in an alternate location.

B. Maintenance of magnetic tape also involves specialized requirements.

(1) Agencies should test the tape no more than 6 months prior to using them for storage of electronic records. Such testing should verify whether the tape is free of permanent errors and in compliance with National Institute of Standards and Technology or industry standards.

(2) Storage areas where records are kept on magnetic tape should be dust free and maintained at a temperature between 62 to 68 degrees Fahrenheit with a constant relative humidity between 35 percent to 45 percent.

(3) Magnetic tapes containing unscheduled or permanent records should be rewound under controlled tension every 3 1/2 years. A statistical sample should be read annually to identify any loss of data and to correct any deficiency. Permanent or unscheduled data should be copied onto tested and verified new tapes before the records are 10 years old.

(4) External labels for tapes used to store permanent or unscheduled records should provide unique identification for each reel, including the name of the organizational unit responsible for the data, system title, and security classification, if applicable (see 282 FW 3, Files Management).

(5) Smoking and eating should be prohibited in magnetic computer tape storage areas.

4.12 Protection and Security of Electronic Records is important to ensure the integrity of the data and to prevent unauthorized use. Aside from the obvious need for data integrity in any assignment, protection and security of electronic records holds importance from the standpoint of the Government's sensitive or classified information; the potential use of electronic records in the judicial process; and the individuals rights to privacy. Electronic records should be regularly "backed up" and record access should be restricted via password or some other mechanism to prevent unauthorized modification or erasure of such records. Record material versus nonrecord material on electronic media should be designated and then segregated to ensure an orderly approach to retention and disposal of records.

4.13 Sensitive or Classified Records will be protected by implementation of an effective records security program that incorporate the following basic procedures:

A. Only authorized personnel have access to electronic records.

B. The system provides for backup or recovery of records to protect against information loss.

C. Appropriate agency personnel are trained to adequately safeguard sensitive or classified electronic records.

D. The risk of unauthorized alteration or erasure of electronic records is minimized.

E. Computer system security plans prepared pursuant to the Computer Security Act of 1987 include electronic records security.

4.14 Judicial Use. Electronic records may be admitted in evidence to Federal courts for use in court proceedings if it is established that the records are accurate. Accuracy may be established by adherence to the following procedures and through coordination with legal counsel, IRM, and the Service Records Management Officer.

A. Documentation is provided that similar kinds of records generated and stored electronically are created by the same processes each time and there exists a standardized retrieval approach.

B. Documentation exists that security procedures are in place to prevent unauthorized modification or deletion of a record and ensure system protection against such problems as power interruptions.

C. Electronic media on which records are stored throughout their life cycle are identified. The time span that records remain on each storage medium and the approved period of record retention (as indicated in the Service's records schedule, 283 FW 2) is identified.

4.15 Contractor Records. The use of contractors to perform program functions creates a special situation for the management of electronic records. Under 44 U.S.C. 3101, agencies are required to create and maintain records to document contractor-operated programs. To fulfill this requirement, a specification for delivery of all pertinent background documentation should be included as part of the contract. It is essential to require the contractor to deliver sufficient technical documentation to permit the agency to use the data. Examples of such background data are:

A. Contracts to produce statistical analyses which have background data that may have further value to the creating agency or to other agencies.

B. Contracts to produce reports that represent Government policy and have background data that verifies assertions or justifies conclusions.

C. Research contracts that have background data that may have reuse value to the Service or other agencies.

4.16 Privacy Act Considerations. The ease with which electronic records may be manipulated and shared makes them exceptionally vulnerable to abuses of the Privacy Act. Employees should be cautious when creating databases which contain names or other personal identifiers (such as employee numbers, social security numbers). Whenever possible record systems should be designed to be stored by elements that do not reveal a personal name or identifier. If the use of names or personal identifiers is unavoidable, the record system should be reported to the Service Privacy Act Officer who will assist the user in legitimizing the record system as an approved Privacy Act system of records. For more information related to the Service's administration of the Privacy Act and a current listing of the Service's approved Privacy Act systems of records, see 204 FW.

4.17 Inventory of Electronic Records. The inventory and cataloging of electronic records should be done as required by OMB A-130. Such an inventory also facilitates the Service compliance with requirements of the Privacy Act of 1974 and allows for the orderly and timely transfer of electronic records to a Federal records repository. An inventory also allows for the orderly scheduling of electronic records for disposition in accordance with the Service's NARA approved records disposition schedule. A complete and accurate inventory should include the following elements.

A. System Name. This would include the common name and acronym for the system.

B. Purpose of The System. This would include any requirements met by the system such as mandatory reports.

C. Information Content. This would include the main subject matter and time span of information, geographic coverage, update cycle, and other major characteristics.

D. Hardware/Software Environment. This would include the computer system, software used, and any application programs.

E. System Managers. This would include the name, office, telephone number of the manager or other personnel who can provide an overview or pertinent information regarding the electronic record system.

F. Restrictions on Access and Use. Indicate national security, privacy, or other restrictions that apply to the use of such records.

G. Authorized Disposition. Indicate the approved disposition status of the records as permitted by the Service Records Disposition Schedule (see 283 FW 2, Disposition Schedule). The records schedule and item numbers covering the records contained in this system should be cited.

4.18 Retention of Electronic Records. Employees shall ensure that electronic records and their documentation are retained as long as needed by the agency and in accordance with the Service's records schedule. Retention of electronic records is subject to the same retention periods outlined in the Service's Comprehensive Records Disposition Schedule (records schedule). If stability of the medium on which electronic records are stored cannot be guaranteed for the required retention period, those records should be converted to paper or some other more stable electronic media. The following guidelines apply to the retention of electronic records:

A. Electronic record systems, including those operated for the Government by a contractor, shall be scheduled as soon as possible but no later than one year after implementation of the system. Any new records systems should be reported to the Service Records Management Officer who will coordinate with NARA regarding the scheduling of those records systems.

B. A copy of the electronic records and any related documentation and indexes shall be transferred to NARA at the time specified in the Service's records schedule.

C. Procedures should be established for the regular recopying, reformatting, and other necessary maintenance to ensure the retention of electronic records throughout their authorized life cycle.

4.19 Permanent Electronic Records. Although the Service records schedule (reference 283 FW 2, Disposition Schedule) is the Service's guide for determining the status of agency records, the variety of information in computer files may make it difficult to know whether an electronic record is permanent. Electronic records become permanent records when.
A. The electronic records replace records scheduled as permanent in another medium.

B. The electronic records are automated indexes to permanent records.

C. The electronic records contain unique and important scientific and technical data resulting from observation of natural events or phenomena or from controlled laboratory or field experiments.

D. The electronic records contain management data that has Service-wide or Government-wide coverage or significance.

E. The electronic records contain natural resources data related to status and trends of land, water, minerals, or wildlife resources.

F. The electronic records contain information that documents operations during times of war, civil emergency, or natural disaster.

G. The electronic records contain political or judicial data related to such topics as elections, special investigations, or court proceedings.

H. The electronic records contain cartographic data used to map the earth's surface or other planetary bodies, or the atmosphere.

I. The electronic records contains data or information that documents foreign policy assessments, foreign public opinion, or international negotiations.

4.20 Transfer of Permanent Electronic Records to NARA. Magnetic media sometimes has a relatively short life span and current computers may not be able to read or be compatible with media that was produced in previous years. Additionally agencies may lack the climate controlled environment necessary to maintain such records adequately. Therefore, NARA maintains permanent electronic records for subsequent use by the original agency, other agencies, and the general public. NARA does not currently accept for permanent preservation electronic data stored on floppy disk, or optical disks and requires agencies to transfer permanent computer files in the following format.

A. Records should be either on open reel magnetic tape or tape cartridges.

B. The open reel or magnetic tapes or the tape cartridges on which the data are recorded should be new or recertified tapes which have been passed over a tape cleaner before writing and shall be rewound under controlled tension.
C. Tape cartridges should be 18 track 3480-class cartridges recorded at 37,871 BPI.

D. Records should be written on half inch magnetic tape in EBCDIC or ASCII.

E. Records should contain no extraneous control characters (except record length indicators for variable length records, or marks designating a datum, word, field, block or file).

F. Records should be on 7 or 9 track open-reel magnetic tape, recorded at 800, 1600, or 6250 bytes per inch and blocked no higher than 32,760 bytes per block.

G. NARA requires certain documentation for the transfer of electronic records. Inventory information detailed in the previous section should accompany the records. NARA also needs information on how the tape was written, identification and definition of all data sets transferred, record layouts specifying relative positions, lengths and definitions of all data elements, and code books for all unique codes used in the records. Documentation shall also include NARA Form 14097, Technical Description for Transfer of Electronic Records, or its equivalent.

4.21 Destruction of Electronic Records. Life cycle planning for information often stops at implementation or is sometimes equated with the obsolescence of computer equipment. Life cycle planning should include the creation, maintenance, use and disposition of information in the system. One of the most effective ways of managing all records including electronic records is scheduling them for disposition. Electronic records may be destroyed only in accordance with the Service's Comprehensive Records Disposition Schedule. Employees who are responsible for electronic records which are scheduled for destruction should ensure that such records are disposed of in a manner that ensures protection of any sensitive, proprietary information. Electronic media that has been previously used for the storage of sensitive or proprietary information should not be reused if the previously recorded information can be compromised by reuse in any way.

Attachments (Exhibits, Amendments, etc)