Chapter 3. Active Records
Active records are those used to conduct current Agency business, and that are generally maintained in office space and equipment. Events in this phase of the lifecycle include creating or receiving records and capturing them in a recordkeeping system.
Creating and Receiving Records
Federal agencies are required to create and receive records that document:
- how the agency is organized,
- what functions it performs,
- how it carries out those functions,
- how it relates to other agencies and the public, or
- information of value to the agency.
EPA offices must determine what records they need to create or receive to meet these requirements. Records contacts and Agency staff should work together to ensure that complete and accurate records are created. Offices should develop guidelines and procedures to incorporate the records creation and receipt process into business functions.
After creating or receiving a record, EPA staff must capture it by filing, storing, or otherwise systematically maintaining it in a recordkeeping system. Capturing records ensures that the information is accessible to all authorized staff. It also assists offices in dispositioning records in accordance with the applicable records schedules.
An office's records program must capture records to:
- maintain adequate and proper documentation and evidence of Agency activities for the time required to meet all program, audit and historical needs;
- maximize the usefulness of the records while active and allow for interoperability and sharing of records across programs and information systems;
- allow for timely access and retrieval;
- safeguard records from loss, misuse, unauthorized access to or modification of information; and
- facilitate the identification and preservation of permanent records.
Staff should ensure that they capture metadata along with related records, including:
- the creator or originating organization,
- the title and subject of the record,
- the date of the activity,
- the names of involved parties, and
- the type of record it is (e.g., report, memorandum).
EPA offices must capture records in a recordkeeping system that facilitates maintenance and use of the records in an efficient and cost-effective manner. A recordkeeping system has several components:
people - RLOs and records contacts, who oversee aspects of records management, and custodians, who create, receive, and use records when conducting EPA business;
processes - procedures to manage records throughout their lifecycle;
tools - equipment and software used to capture, organize, store, track, and retrieve records; and
the records themselves.
A recordkeeping system must allow records to be:
organized for ready access and retrieval,
linked to the records schedules,
maintained for the time period required by the records schedules, and
cross-referenced to related records stored on special media or in different locations.
Once records are organized within a recordkeeping system, the office must regularly review the system to determine when records are ready to be closed, retired, and destroyed or transferred.
Special Considerations in Capturing Records
EPA staff must preserve records created with software applications in a recordkeeping system for the length of time designated in the approved records schedule for the functions they support. For example, if a letter is produced using Microsoft Word to respond to a controlled correspondence, retention is governed by the records schedule for controlled correspondence.
E-mail records with an approved retention of six months or less may be retained in the e-mail system, and do not have to be captured in a recordkeeping system.
Any verbal communication in which an Agency decision or commitment is made, and that is not otherwise documented, needs to be captured and placed in a recordkeeping system. Voicemail systems are not recordkeeping systems. These systems delete messages automatically after a set number of days.
Centralized vs. Decentralized
EPA uses a combination of centralized and decentralized recordkeeping systems.
A centralized recordkeeping system:
- collects records for several custodians or units in one location; and
- is controlled by a records contact or, in the case of large systems, a records center staff.
A decentralized recordkeeping system:
- collects records in several locations throughout the office, generally at individual work stations; and
- is controlled by the custodian who creates and/or receives the records.
An office may choose to maintain specific types of records in a central location, while maintaining other types of records at individual work stations. Records maintained at individual work stations should be identified in the recordkeeping system, so that everyone in the office can locate the records.
See Centralized vs. Decentralized Filing for more information.
Electronic Recordkeeping Systems
Electronic records must be maintained in an electronic recordkeeping system, such as EPA's enterprise content management system (ECMS). The Agency's requirements for electronic recordkeeping systems are listed in Basic Requirements of an Electronic Recordkeeping System at EPA.
If an office does not have an electronic recordkeeping system that meets these requirements, it must print records and capture them in a paper recordkeeping system. In some cases, printing may cause loss of context (e.g., databases, complicated spreadsheets or geospatial data). In those cases, the records may be maintained electronically, but must be readable, accessible and usable for the entire life of the records, and dispositioned according to the applicable records schedule.
Computer drives, backup tapes, and software applications such as Lotus Notes are not recordkeeping systems. However, in the absence of an electronic recordkeeping system, offices may establish network directories using the Agency-wide file structure to facilitate access and retrieval of the electronic copy, while maintaining the record copy in a paper recordkeeping system.
EPA must maintain adequate and up-to-date technical documentation for each electronic recordkeeping system. The documentation must include narrative description of the system, and the physical and technical characteristics of the records, including a description of the data format, a record layout describing each field, and any other technical information needed to read or process the records.
If electronic records are produced in response to litigation or audits, offices must demonstrate consistent usage of the electronic recordkeeping system in accordance with federal and EPA requirements.
A file plan lists the records in an office, and describes how they are organized and maintained. It should include identifying information about the records, such as the:
- person and office responsible for maintaining the records, (i.e., custodian)
- Agency file code,
- folder title,
- medium (e.g., paper, electronic, video),
- access restrictions,
- location of the records,
- date range of the records, and
- disposition dates.
EPA policy requires offices to organize records according to the Agency-wide file structure. If an office maintains electronic copies of records (e.g., on a share drive), it should organize the directories in the same way to facilitate retrieval.
See the File Plan Guide for more information.
Offices can choose to store their active records on-site, or, with permission, in an off-site storage facility. All on-site records centers and off-site storage facilities the Agency uses must protect federal records from threats such as fire, pests, theft, natural disasters and water damage.
Permanent records must be stored on archival-quality media and in containers and facilities appropriate to long-term preservation. Offices should arrange records in storage media with like schedules and disposition dates.
Filing equipment and supplies should be the most economical possible to meet recordkeeping requirements. In selecting equipment, offices must consider:
- the media to be filed (e.g., CDs, slides, photographs, paper, oversized paper);
- the volume and rate of growth;
- activity (i.e., how often the records are retrieved and refiled);
- the cost of the equipment, including costs to convert to new systems;
- the cost of moving, including dismantling and reassembly;
- site characteristics, such as floor reinforcement and amount of aisle space; and
- the need to maintain confidential records in equipment that can be locked and/or stored in a secure location.
Offices should use equipment that accommodates letter-sized records unless there is a requirement for other sizes. Offices should also consider purchasing used or reconditioned equipment when available.
Electronic records are usually stored on magnetic media (e.g., tapes, magnetic cartridges) or optical media (e.g., CD-ROMs, flash drives). Offices must monitor electronic records to ensure that the records are accessible and readable until final disposition. Offices may need to reformat or migrate the records.
Electronic records require special care, including:
- keeping them at the appropriate temperature and humidity;
- recopying the information periodically, and
- testing the readability of an annual sample.
System backups used to restore computer system operations are not adequate for storage of electronic records. Offices must destroy system backup tapes or media according to established rotation schedules and applicable records schedules.
Offices must meet NARA regulations (36 CFR 1234) when selecting electronic records storage media.
Special Media Records
Special media records such as film, video recording and microform have unique storage requirements. Storage of the records must meet the requirements in NARA regulations (36 CFR 1237 and 36 CFR 1238).
Imaging is a process by which a paper document is converted from a human-readable format to microform or a computer-readable digital image file. Imaged pictures of documents can be stored on a variety of media.
See Frequently Asked Questions About Imaged Records for more information.
Offices should implement a tracking system for retrieving and checking out records from its recordkeeping system. The system should include, at a minimum, chargeout cards that are placed in the record's location in the filing cabinet or shelf to indicate:
- Agency file code and any internal identifiers;
- title on the folder(s);
- date on the folder(s), if applicable;
- name and room number of the person charging out the record(s); and
- date charged out.
When returning the record, office staff should:
- remove the chargeout card, and
- replace the record in the location noted on the file plan.
Offices may implement electronic tracking systems (e.g., barcodes) to track records at the document, folder or box level. These systems should track the same type of information described above.
Each office must maintain its records securely, protecting the integrity and confidentiality of the records as appropriate. The criteria for determining the level of security control should include the sensitivity, value and replaceability of the information.
Offices should secure records by:
- Placing records into the office recordkeeping system.
- Ensuring the office's file plan is updated on a regular basis.
- Tracking the location of records at all times, using a manual or automated system.
- Performing timely follow-up on records that have been checked out of the recordkeeping system.
- Returning records to the recordkeeping system at the conclusion of the check-out time or upon termination of employment.
- Developing procedures to protect sensitive records, allowing access only to authorized individuals.
- Shredding or otherwise completely destroying records containing sensitive information at final disposition.
Agency staff using records at alternate work sites must follow the security requirements in EPA's Flexiplace Policy (PDF) (27 pp, 92K) 3180, Section V.G. Records Management. Specific requirements mandate that:
- Any record removed for Flexiplace assignments or generated from Flexiplace assignments is the property of EPA.
- Staff get written approval from their supervisors to take records to a Flexiplace work site.
- Staff on Flexiplace ensure that the records in their custody are available to the Agency during their absence.
- Records and nonrecords used at alternate work sites are destroyed in accordance with the applicable records schedule.
- Records containing sensitive information are returned to EPA for shredding.
RLOs or records contacts must work with the departing employee to ensure that the following activities are complete:
- All EPA records, regardless of format, are identified, collected, transferred to an appropriate location, and assigned to a new custodian.
- All records are accessible and properly secured.
- File plans are updated.
Departing employees must obtain permission from their supervisors to remove extra copies of any documentary materials, which may still be subject to FOIA or discovery actions.
Each office must implement a plan that identifies and protects its vital records in accordance with EPA's Records Management Policy (PDF) (9 pp, 109K). Each office within EPA is required to establish and maintain a records management program which includes a plan to protect vital records and assess damage to and the recovery of any records affected by an emergency or disaster.
See the following for more information:
- Developing and Maintaining a Vital Records Program
- Protecting Your Records
- Vital Records Procedures (3 pp, 78K)