FHWA Order, FHWA Files Management and Records Disposition Manual, M 1324.1A, Chapter 4

FHWA Order M 1324.1A: FHWA Files Management and Records Disposition Manual
November 4, 1999 • Chapter 4

CHAPTER 4 ELECTRONIC RECORDS

GENERAL. This chapter establishes electronic recordkeeping guidelines for the creation, maintenance, security, and disposition of information stored on computers and other electronic equipment. Electronic technology has greatly expanded and enhanced the methods of creating, editing, maintaining, transmitting, and retrieving Federal records. Records now may be in the traditional paper form or use a variety of other media in electronic recordkeeping systems from creation through disposition. Electronic documents are records just as much as paper documents, and their creation, maintenance and use, and disposition must be managed accordingly. Based on need, electronic documents may be maintained in computer memories for instant access, on magnetic tape or disk for reference, or in some other form.
DEFINITION. Electronic records are any records in which a computer or other electronic device is required for the user to create, maintain, access, transmit, or dispose of the record in an electronic format. Electronic records are also referred to as machine-readable records, for they require machine processing for conversion to readable form. Examples of electronic records are those residing on magnetic tapes, diskettes, drums, video files, and optical disks. Electronic records meet the NARA definition for Federal records and must meet applicable standards and guidelines.
RESPONSIBILITIES
1. The Office of Information and Management Services (HAIM) has overall responsibility for the FHWA electronic records management program. HAIM shall:
  (1) develop policies, procedures, and guidelines to improve the effectiveness of the FHWA electronic records management program.
  (2) provide assistance and advice to Headquarters and field offices on electronic records management matters.
  (3) develop and secure NARA approval of records disposition schedules for electronic records and ensure their effective implementation.
  (4) serve as liaison with NARA on scheduling, transferring, and disposing of electronic records.
  (5) establish a training program that ensures adequate training for users of electronic records systems in the operation, care, and handling of the information, equipment, software, and media used in the system.
2. Core Business Unit Program Managers, Service Business Unit Directors, Resource Center Directors, Division Administrators, State Directors of Motor Carriers, and Federal Lands Highway Division Engineers shall:
  (1) manage, control, and coordinate all electronic records management activities within their offices through the local Records Liaison Officer (RLO).
  (2) ensure that electronic records are preserved and disposed of in accordance with agency guidelines and approved records disposition schedules.
  (3) develop security controls to prevent the unauthorized alteration or erasure of information in electronic records.
3. All employees shall:
  (1) use electronic equipment in a safe and responsible way.
  (2) maintain electronic records according to prescribed agency policies and procedures.
  (3) safeguard electronic records until authorized for disposition. Electronic records are to be treated the same as paper records, that is, paper maintenance and disposal must be approved by the National Archives.
  (4) notify the local RLO when unscheduled electronic records are identified.
CREATING ELECTRONIC RECORDS. The widespread introduction of microcomputers into offices has encouraged the re-evaluation of the traditional office approach to records management. Word processing is the most common office computer application. These powerful, easy-to-use systems allow administrative, technical, and professional personnel to create and store documents (records) more frequently and more rapidly and to share and revise them more easily than in traditional, paper-based office operations.
1. Identifying Electronic Records. The first step in determining recordkeeping requirements for electronic records is to identify the records' creators and users. Some information may exist in several different formats within one office. Since such records are needed for separate program purposes, the recordkeeping requirements, including life span, may differ with the program. Such information requirements should be the determining factor in deciding where, how, in what format, and for how long the electronic records are maintained.
2. Records vs. Working Papers. Just as with paper documents, drafts or working copies of electronic documents are normally kept only until the final version of a document is completed. For long or complex documents, several earlier drafts and the current draft may be retained to ensure document integrity until the final draft is approved. Then, normally, previous revisions will be erased and only the final text and the requisite back-up copies kept. The exception to this is when retention of drafts is needed to document significant policy development and changes.
3. Identification Methods. Once working papers are eliminated from consideration, the remaining documents should be examined in terms of the NARA definition for a record. This examination may be by: (a) analyzing each document individually to determine record status or, (b) establishing records groups to which each record document may be assigned.
MAINTAINING ELECTRONIC RECORDS ON LOCAL AREA NETWORKS (LAN).
The purpose of a LAN is for multiple users to be able to have access to files stored on the LAN file server and to be able to share peripheral equipment, such as a laser printer.
1. Access
  (1) Generally, all users should have access to all working files in that organization's directory.
  (2) Secretaries should have access to all files in their Division or Office for quick reference and changes by management.
  (3) Organize files in folders and subfolders so that employees having a need to access the files can easily find them when needed.
  (4) For security reasons, and to ensure that unauthorized persons do not have access to work files, do not share any computer ID and password.
2. Folders. Within a LAN file server, files are organized into folders that generally are created and managed by the word processing software package under which the files were created. A folder serves, in effect, the same function that folders in a filing cabinet serve for paper files; they organize and store individual documents.
  (1) Multiple folders, commonly termed subfolders, should be used to group logically related files. Separate subfolders should be created for each major program area or area of responsibility.
  (2) Folders and subfolders should be assigned names that clearly communicate their contents to employees other than the originator so that employees can locate files when the originator is out of the office. Avoid mixing unrelated files within a specific subfolder.
  (3) When organizing folders, ensure that only one type of record is being stored in a particular folder. Keep official records in folders on the file server. Non-record materials may be stored on the file server (depending on the size of the file and remaining file space), the user's C: drive, or on a floppy disk.
DISPOSITION OF ELECTRONIC RECORDS. Arranging for the authorized disposition of electronic records is similar to the scheduling of information stored on any other medium, such as paper or microfilm. Electronic records are usually stored on erasable, reusable, and relatively expensive media, which are easy to revise and update and are relatively fragile. For these reasons, the disposition of electronic records should be determined as early as possible in the life cycle. Inventorying and scheduling are the most effective ways of ensuring that electronic records are saved as long as they are needed.
1. Inventorying. A records inventory begins with a survey of the records created or maintained by an organization or one of its components. An inventory includes information such as the series or system title, inclusive dates of the data, the software and hardware used, the office(s) with responsibility for the records, how and why the records are created, what information they contain, any restrictions on access, and how the records are used. The first step in the disposition process is the identification and description of records and recordkeeping requirements. This process requires a review of all organizational documentation to determine the information requirements of each operating unit. Once these decisions have been made, a description of records and recordkeeping requirements can be developed to be used in the preparation of inventories. Both the inventorying and scheduling of electronic records work best in the context of an "electronic information system," which is the organized collection, transmission, and dissemination of information in accordance with defined procedures.
2. Permanent Electronic Records. Given the enormous variety of information stored in computer files, it is impossible to compile a comprehensive list of potentially permanent electronic records. The following examples are intended to suggest this variety:
  (1) Electronic records that replace records scheduled as permanent in another form, e.g., paper.
  (2) Administrative data that have unusually broad coverage or significance, such as the budgets of an entire department or agency.
  (3) Natural resources data related to land, water, minerals, or wildlife.
  (4) Emergency operations data that document military or civilian operation during times of war, civil emergency, or natural disaster.
  (5) Political, survey, or judicial data related to such topics as elections, special investigations, or court proceedings.
3. Preservation. Special handling is needed to ensure the long-term preservation of electronic records that are permanent or unscheduled and, therefore, potentially permanent. The basic requirements for the creation, maintenance, use, and storage of Federal permanent and unscheduled magnetic media are spelled out in 36 CFR 1234.
  (1) Mainframe-based Records. The useful life of a magnetic tape, the recommended storage medium for permanent electronic records, is currently estimated at 10 years. Therefore, Federal agencies are encouraged to transfer permanent electronic information directly to the National Archives when additions to the master file cease or as periodic snapshots of the data system.
  Current up-to-date documentation is essential for transferring electronic records to the National Archives, and the documentation must accompany electronic records that are transferred to the National Archives. As a minimum, the documentation for data files and data bases should include the record layout and a codebook. For data base management systems, essential documentation is a data dictionary or the equivalent information, including a description of the relations between data elements in relational data bases. NARA has attempted to deal with the problem of diverse and incompatible systems by standardizing the computer media it will accept to half-inch magnetic tape.
  (2) PC-based Records. NARA is in the process of establishing guidelines for the acceptance of permanent electronically stored data on optical disks, but does not accept electronic data stored on any other medium, such as floppy disks.
SECURITY OF ELECTRONIC RECORDS. Security for electronic records created, used, and stored on personal computers (PC) systems and LANs has become an important issue. Mainframe computer systems have traditionally had considerable protection, but PC systems have not, for they have been treated as single-user devices. As a result, security weaknesses may threaten the confidentiality, integrity, or availability of electronic information. This is especially true with the advent of LANs in each FHWA office, the agencywide Wide Area Network (WAN) and Electronic Data Sharing (EDS) with State DOTs and other customers and partners. Successful electronic records security requires a balance among the following objectives:
1. Confidentiality of personal, proprietary, or otherwise sensitive electronic records handled by the system.
2. Integrity and accuracy of electronic records and the processes associated with them.
3. Accessibility of electronic record systems and the electronic records or services they support.
COURT DECISIONS CONCERNING ELECTRONIC RECORDS. In March 1999, NARA issued Bulletin 99-04, "Scheduling Electronic Copies of Program Records and Administrative Records Not Covered by the General Records Schedules (GRS)." This bulletin instructed agencies on how to schedule the electronic copies of the agency's currently scheduled program records and certain administrative records that were previously scheduled under GRS 20, items 13 (word processing documents) and 14 (e-mail documents). The bulletin also defined electronic copies as, "the electronic records that were created using word processing or electronic mail software that remain on the "live" computer system after the recordkeeping copy is produced." The impact of the NARA bulletin is that agencies must now decide: (1) whether electronic versions have lasting value, and (2) whether the electronic version of agency records should become the official copies. NARA Bulletin 99-04 was issued in response to the U.S. District Court for the District of Columbia decision on Public Citizen et al. v. John Carlin et al., which ruled that portions of GRS 20 reached beyond the authority of NARA and declared GRS 20 null and void. This decision prohibited agencies from destroying electronic records and e-mail without guidance from NARA, even when paper copies were kept. In August 1999, the U.S. Circuit Court of Appeals for the District of Columbia overturned the U.S. District Court's decision, declaring that the NARA does have the authority to instruct agencies on how to dispose of electronic records and e-mail. As of the date this manual is posted on the Internet, NARA is reviewing the appeals court's decision and will provide comments at a later date. The outcome of this court action has elevated the attention to the importance of the maintenance and disposition of electronic records and e-mail and it has also outlined the agency responsibilities for implementation.

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