Attachment 3 VHA Records Control Schedule 10-1 Jan 2020.pdf

January 2020

Veterans Health Administration Washington DC 20420

RECORDS CONTROL SCHEDULE 10-1

Department of Veterans Affairs

VHA Records Control Schedule 10-1

1. PURPOSE

The Records Control Schedule (RCS) 10-1 provides Veterans Health Administration (VHA) records retention and disposition requirements for

VHA Central Office, Program Offices, and field facilities. The primary purpose of this revision is to incorporate changes to RCS 10-1 issued since the last publication date of January 2019. The schedule is divided into eight chapters. Each chapter covers a group of records, e.g., chapter one covers administrative records. The first four chapters include most of the National Archives and Records Administration (NARA) General

Records Schedules (GRS). Space for additional records schedules is available to allow for future expansion. The VHA Records Management

Office intends to update this schedule every three years in order to publish the most up to date records management requirements. Between updates the VHA Records Management Office will post new or revised schedules on the HIM/RM (Health Information Management/Records

Management) website. Schedules are not required to be in the RCS 10-1 to be a legal schedule. Once a schedule is approved by the Archivist of the United States it must be used to manage the agency’s records.

2. INTRODUCTION

a. Title 44, Section 3301, of the United States (U.S.) Code defines records as “all books, papers, maps, photographs, machine-readable materials or other documentary materials, regardless of the physical form or characteristics, made or received by an agency of the U.S. Government 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 government or because of the information value of data in them. Library and museum material made or acquired and preserved solely for reference or exhibition purposes, extra copies of documents preserved only for convenience or reference, and stocks of publications and of processed documents are not included. These items are referred to as non-record materials.

b. The VHA Records Control Schedule (RCS) 10-1 is the main authority for the retention and disposition requirements of VHA records. It provides a brief description of the records and states the retention period and disposition requirements. It also provides the NARA disposition authorities or the GRS authorities, whichever is appropriate for the records, in addition to program and service sections.

c. The GRS provides disposal authorities for temporary administrative records common to all Federal agencies. It covers records relating to:

personnel, budget and finance, procurement, information technology, and other common functions and activities of Federal agencies. Any deviation from the GRS must be authorized by NARA in accordance with 36 Code of Federal Regulations (CFR) 1228.42(B). Requests for deviations from either the RCS 10-1 or GRS retention and disposition requirements are to be submitted to the VHA Records Management Office via the Facility requesting the change and the primary VHA Program Office with authority over the record type that is being requested for change.

3. RECORDS MANAGEMENT RESPONSIBILITIES

a. The Assistant Deputy Under Secretary for Informatics and Analytics (10P2), Executive Director Information Governance (10P2C) Health

Information Management/Records Management Office will be referred to as the VHA Records Management Office throughout this document.

The VHA Records Management Office is responsible for developing policies and procedures for effective and efficient records management throughout VHA including VHA Program Offices and Veterans Administration (VA) Medical Centers. In addition, the Office acts as the liaison between VHA and NARA on issues pertaining to records management practices and procedures.

b. VHA Field/Facility Records Managers are responsible for all records management activities at their site.

c. All VHA employees are responsible for ensuring that records are created, maintained, protected, and dispositioned in accordance with NARA regulations and VA policies and procedures.

4. DISPOSITION OF RECORDS

The RCS 10-1 contains retention and disposition requirements for VHA records authorized by NARA or assigned a GRS authority. Record disposition refers to the transfer of records to an approved records storage facility, transfer of permanent records to NARA, the destruction of records, or other appropriate actions to dispose of records. Unless retrieved; records transferred to a storage facility shall be dispositioned after expiration of their retention requirements.

5. PERMANENT AND UNSCHEDULED RECORDS

Permanent and unscheduled records in VHA custody must be reported through the VHA Records Management Office to NARA. Permanent

(archival) records are defined as records appraised by NARA to have sufficient historical value or other value to warrant permanent preservation at the NARA. Un-appraised and unscheduled records are records that have not been evaluated to determine their record retention or disposition. Such records are to be retained until they receive disposition authority from NARA. The VHA Program Offices responsible for unscheduled records shall work with the Field/Facility Records Manager, VHA Records Management Office and the VHA Records Officer to identify, describe and submit to NARA a request for disposition authority using the NARA electronic Records Archives (ERA) system.

6. MEDIA NEUTRAL RECORDS

a. A media neutral schedule item on a records disposition schedule (i.e., SF 115, Request for Records Disposition Authority or NARA Electronic

Records Archives (ERA) records scheduling module) applies to the described records regardless of their medium. Program Offices must submit a new schedule request through the VHA Records Management Office to NARA for approval of electronic versions of previously scheduled records if:

(1) The content and function of the records have changed significantly (e.g., the electronic records contain information that is substantially different from the information included in the hard copy series or are used for different purposes).

(2) The previously approved schedule explicitly excluded electronic records.

(3) The electronic records consist of program records maintained on an agency Web site.

(4) The electronic records consist of temporary program records maintained in a format other than scanned image AND the previously approved schedule is not media neutral.

b. Temporary still pictures, sound recordings, motion picture film, and video recordings. Apply the previously approved schedule to digital versions.

c. Scanned images of temporary records, including temporary program records. Apply the previously approved schedule.

d. Other temporary records maintained in an electronic format other than scanned images:

(1) For temporary records that are covered by an item in the GRS (other than those GRS items that exclude electronic master files and databases) or an agency-specific schedule that pertains to administrative housekeeping activities, apply the previously approved schedule. If the electronic records consist of information drawn from multiple hard copy series, apply the previously approved schedule item with the longest retention period. This is common when creating an electronic system that replaces a number of paper and electronic record types. The older systems and paper records are now placed into a new system. In the past these records may have covered various disposition life cycles.

In the case of finance records the range could have been from one to six years. If the records in the new electronic system cannot be dispositioned separately then they must be kept for the longest disposition, in this case six years.

(2) For temporary program records covered by a NARA-approved media neutral schedule item (i.e., the item appears on a schedule submitted to

NARA for approval before December 17, 2007, that is explicitly stated to be media neutral, or it appears on a schedule submitted to NARA for approval on or after December 17, 2007, that is not explicitly limited to a specific recordkeeping medium), are considered media neutral. An example of this is the Health Records Folder File or Consolidated Health Record (CHR). The original NARA approved records disposition schedule was NARA (Job No. N1-15-91-6 item 1). This schedule was written and approved in 1991 and was for the paper health record only. In 2000

(VHA) created an “Electronic Health Record”. Since this record was not paper VHA was required to submit to NARA a request for an electronic record schedule NARA (Job No. N1-15-02-3). This records schedule was created in 2002 which makes both the paper and electronic health record media neutral for future changes.

7. DAMAGE TO AND UNAUTHORIZED DESTRUCTION OF RECORDS

a. VHA records shall not be disposed of without the proper authorization to do so. Federal law prohibits unauthorized destruction or mutilation of Federal records. The penalty for such acts is a $2,000 fine, 3 years in prison, or both pursuant to Title 18 United States Code 2071. Damage to, and unauthorized destruction of records is to be reported to the VHA Records Office immediately upon knowledge of such an act of destruction.

b. VHA officials must take measures to ensure that records are not disposed of improperly. Records are not to be removed from VHA custody or destroyed without regard to the requirements of this schedule or the GRS. When records are improperly disposed, NARA regulations and VA policy require the submission of a report to NARA. The report must include the record description, volume, date of incident, etc. Specific reporting requirements are contained in NARA regulations, Title 36, Code of Federal Regulations, Part 1228, Disposition of Federal Records, and

VA Handbook 6300.1, Chapter 6., Records Management Procedures.

8. RECORDS FREEZES/LITIGATION HOLDS

a. Records freeze: Records whose scheduled disposition has been temporarily suspended because of special circumstances that alter the administrative, legal, or fiscal value of the records.

b. Litigation hold: The Office of General Counsel (OGC) may periodically issue a litigation hold or moratorium on the disposition of certain records because the records may be potentially responsive or helpful in ongoing or pending litigation (lawsuits).

c. A "hold" is simply the implementation of a litigation hold notice issued by an OGC Office. Upon receipt, the records manager must suspend the normal disposition cycle of the records listed in the hold notice to prevent their early/premature disposal. Holds are placed on records in an agency's physical custody.

d. A "freeze" is created when the records manager receives a hold notice for records not in the agency’s physical custody but in the custody of the VA Records Center and Vault (RC&V), a Federal Record Center (FRC), or a commercial records storage facility. The Facility Records Manager would ask NARA to create a freeze to halt premature disposition of the records. Since most litigations deal with relatively current agency activity, the number of freezes is significantly smaller than the number of holds since the agency still has physical custody of most records affected by holds.

e. Upon receipt of a hold notice the records manager should initiate a freeze on any off-site records in conjunction with the hold placed on the on-site records in physical custody. This ensures that any potentially responsive record is preserved regardless of its physical location.

f. The Office of General Counsel maintains a list of litigation holds at the following website: OGC Litigation Share Point:

https://vaww.ogc.vaco.portal.va.gov/litigation/Lists/active/AllItems.aspx.

g. Additional information may be found at the following NARA website: http://www.archives.gov/frc/arcis/freeze-faq.pdf.

https://vaww.ogc.vaco.portal.va.gov/litigation/Lists/active/AllItems.aspx https://vaww.ogc.vaco.portal.va.gov/litigation/Lists/active/AllItems.aspx http://www.archives.gov/frc/arcis/freeze-faq.pdf http://www.archives.gov/frc/arcis/freeze-faq.pdf

9. ESSENTIAL RECORDS

Essential records are defined as essential records needed to maintain the continuity of Federal government activities during and following a national emergency or a technological or natural disaster and to protect the rights and interests of VA beneficiaries and employees. Additional information can be found in VA Handbook 6300.2.

10. PERSONAL PAPERS

Personal papers consist of documents that relate only to an individual’s personal affairs and do not affect the conduct of government business.

Examples of personal papers are diaries, journals or other personal notes that are not created in the process of transacting government business. Personal papers may be disposed of in accordance with the owner’s preference. Note: Personal notes included on an official calendar or files are subject to official records authorities.

11. TERMINATION OF OFFICE/SERVICE AND DEACTIVATION OF FIELD FACILITY

a. Specific records management procedures are to be followed when terminating an office/service or deactivating a field facility. The procedures are contained in VA Handbook 6300.1. It is important to follow these procedures to prevent the loss or unauthorized destruction of

VHA records.

b. Once it has been determined to abolish an office/service or to deactivate a field facility, the office or facility records manager is to be consulted so that certain measures are taken to prevent the premature destruction of records. An evaluation is to be conducted to determine those records that are eligible for immediate destruction, identify records that are to be transferred to the successor office/service or facility, identify records that are eligible for transfer to a records storage facility, and identify records of permanent value to be offered to the NARA.

Records are not to be disposed of without proper authority to do so.

12. DEPARTMENT OF VETERANS AFFAIRS (VA) POLICY

a. VA Directive 6300, Records and Information Management, provides the policy for records and information management.

b. VA Handbook 6300.2, Management of the Vital Records Program, implements the VA Vital Records Program which is an integral component of the VA Emergency Preparedness Plan.

c. VA Handbook 6300.8, Procedures for Shipment of Records to the RC&V in Neosho, Missouri, provides procedures for transferring records to the RC&V.

d. VHA Directive 6300.01, Records Management Compliance Monitoring, provides compliance requirements for the Records Management

Program.

Chapter 1- General Administration & Management Records

1001- Common Offices’ Records

This schedule covers certain records common to most offices in Federal agencies, whether those offices are involved in administrative or mission-related activities. Most of these records are administrative housekeeping records. Agencies create and maintain administrative records when carrying out general, non-mission-related activities that keep an office operating. In contrast, agencies create mission records when carrying out the unique activities for which the agency was established. The only mission-related records this schedule covers are non-recordkeeping copies of electronic records (item 020) that are maintained for decision-making purposes or taking action. Copies maintained solely for convenience of reference are considered non-record materials. This schedule may be applied to records in offices that carry out mission-related activities, but only those records that are described here.

This schedule does not apply to transitory records, which are scheduled in GRS 5.2. The distinction between transitory and the records covered in this schedule is that the records here generally have a longer period of business use than transitory records. This schedule also does not cover materials an agency determines to be non-record or personal. Neither does this schedule cover common administrative records found in most offices that are scheduled elsewhere in the GRS, such as timekeeping and procurement records.

Item Number

Records Description Disposition Instructions

Disposition Authority

1001.1 Administrative Records Maintained in Any Agency Office.

Records accumulated by individual offices that relate to routine day-to-day administration and management of the office rather than the mission-specific activities for which the office exists. Includes:

▪ staff locators, unofficial organizational charts, and office seating charts (see Exclusion 1)

▪ office-level administrative policies and procedures and files related to their development (see Note 1)

▪ calendars or schedules of daily activities of non-high-level officials (high-level officials are defined in

GRS 6.1; this item covers those positions not defined as high-level)

▪ informal requests and tracking of personnel training, travel, supplies, and equipment, excluding procurement and payment records and forms requesting training (e.g. SF-182)

▪ internal office activity and workload reports

▪ studies and analyses of office administrative functions and activities

▪ non-mission related management reviews and surveys

▪ minutes of meetings related to administrative activities

EXCLUSION: This item does not apply to recordkeeping copies of organizational charts, functional statements, and related records that document the mission-related organization, staffing, and procedures of the office.

Temporary. Destroy when business use ceases.

GRS 5.1, item

DAA-GRS-

2016-0016-

Item Number

Records Description Disposition Instructions

Disposition Authority

1001.2 Non-recordkeeping Copies of Electronic Records.

Non-recordkeeping copies of electronic records agencies maintain in email systems, computer hard drives or networks, web servers, or other locations after agencies copy the records to a recordkeeping system or otherwise preserve the recordkeeping version. Includes:

▪ documents such as letters, memoranda, reports, handbooks, directives, manuals, briefings, or presentations created on office applications, including those in Portable Document Format (PDF) or its equivalent

▪ senders’ and recipients’ versions of electronic mail messages that meet the definition of Federal records, and any related attachments

▪ electronic spreadsheets

▪ digital still pictures or posters

▪ digital video or audio files

▪ digital maps or architectural drawings

▪ copies of the above electronic records maintained on websites or web servers, but EXCLUDING web pages themselves

NOTE 1: Non-recordkeeping copies may be Federal records. Often, copies are non-records and can be immediately destroyed, but not always. Copies are non-record if they are kept only for convenience of reference. If copies are used in the course of agency business to make decisions or take action, they are Federal records. The copies described here are Federal records if they are still being used by the agency for such business purposes but are not recordkeeping copies of those records.

NOTE 2: For electronic mail records, the recordkeeping system must capture the names of sender and recipients, date (transmission data for recordkeeping purposes), and any receipt data, along with the message text. Sender/recipient information should be individual account information, not the name of a distribution list.

Temporary. Destroy immediately after copying to a recordkeeping system or otherwise preserving, but longer retention is authorized if required for business use.

GRS 5.1, item

DAA-GRS-

2016-0016-

1001.3 Records of Non-mission Related Internal Agency Committees.

Records created and maintained by committees established by an agency for facilitative or operational purposes unrelated to the agency’s mission, such as organizing events, selecting interior furnishings, overseeing volunteer activities, or employee recreational activities. Records include:

▪ meeting minutes, summaries, agendas, and transcripts

▪ reports and studies

▪ membership records

▪ correspondence, mailing, and distribution records

NOTE: Records of mission-related committees are potentially permanent, and agencies must schedule them by an agency-specific records schedule.

EXCLUSION: These items do not cover records of Federal Advisory Committee Act or interagency committees.

GRS 6.2 covers Federal Advisory Committee Act committee records.

Temporary. Destroy when business use ceases.

DAA-GRS-

2016-0016-

1002- Agency Accountability Records

This schedule covers records agencies create in three areas of accountability:

• internal controls implementing various Office of Management and Budget (OMB) management directives, assessing risks, assuring compliance, and correcting issues

• mandatory reporting on administrative functions to external entities, and interaction with the U.S. Office of Special Counsel concerning allegations and claims that fall under its jurisdiction

Item Number

Records Description Disposition Instructions

Disposition Authority

1002.1 Internal Administrative Accountability and Operational Management Control Records.

Internal evaluations of accounting and administrative controls, mandated or governed by OMB Circulars A-123, A-130, and A-76; Government Accountability Office’s (GAO) Standards for Internal Control in the Federal Government (the “Green Book”); and similar requirements or directives. Includes:

▪ copies of internal and external directives outlining management control policy

▪ management control plans and records of the planning process

▪ records of management reviews

▪ comprehensive plans documenting agency efforts to comply with OMB Circular A-123 and similar requirements

▪ risk analyses and risk profiles

▪ internal controls over reports

▪ feeder reports and compliance statements from agency components contributing to consolidated reports the agency submits to the President/OMB or Congress (see Exclusion 2)

▪ records tracking assignments, tasks, and responsibilities administrative correspondence

EXCLUSION 1: Reports related to agency mission activities (agencies schedule these separately).

EXCLUSION 2: Consolidated final agency reports submitted to the President/OMB or Congress (agencies schedule these separately).

EXCLUSION 3: Reports that mandating agencies receive (agencies must schedule them separately).

1 year after submission or when superseded, as appropriate, but longer retention is authorized if required for business use.

GRS 5.7, item

DAA-GRS-

2017-0008-

1002.2 Internal Control Review, Response, and Mitigation Management Records.

Copies of reports and audits identifying internal administrative program weaknesses, mitigation action plans, corrective actions, tracking records, correspondence, and other records held by the office responsible for coordinating internal control functions.

EXCLUSION: Records held by offices contributing to internal control review, response, and mitigation—but not responsible for overseeing it (GRS 5.1, item 010 covers these).

Temporary. Destroy 5 years after no further corrective action is needed, but longer retention is authorized if required for business use.

GRS 5.7, item

DAA-GRS-

2017-0008-

Item Number

Records Description Disposition Instructions

Disposition Authority

1002.3 Administrative Directives and Notices.

Policy documents on administrative functions such as payroll, procurement, facilities, equipment, and human capital. Includes records documenting development.

NOTE: NARA allows the agency to set this records schedule. It was determined by 10b4, 10a7 and OGC that these records need to have its disposition extended from destroy when superseded to 7 years.

Temporary. Cutoff after CY superseded or cancelled. Destroy 7 years after cutoff.

GRS 5.7, item

DAA-GRS-

2017-0008-

1002.4 Records About Authorizing and Managing Report Requirements and Parameters.

Processing and submission files on reports an agency creates or proposes. Includes copies of authorizing directives; preparation instructions; descriptions of required or standardized formats; clearance forms; and documents on evaluating, continuing, revising, and discontinuing reporting requirements.

Temporary. Destroy 2 years after the report is discontinued, but longer retention is authorized if required for business use.

DAA-GRS-

2017-0008-

1002.5 Mandatory Reports to External Federal Entities Regarding Administrative Matters.

Agency-level reports that external Federal oversight entities such as the White House, Congress, OMB, the Office of Personnel Management (OPM), and General Services Administration (GSA) require under authorities such as (but not limited to) OMB Circular A-123, the Federal Managers Financial Integrity Act (FMFIA), the Chief Financial Officers Act (CFOA), the Paperwork Reduction Act (PRA), Joint Committee on Printing requirements and the FAIR Act. Examples include:

▪ Agency Financial Report (AFR), Performance and Accountability Report (PAR), or equivalent

▪ Annual Performance Plan, Annual Performance Report, or equivalent

▪ Statement of Assurance (per FMFIA), or equivalent

▪ information collection clearances

▪ report on financial management systems’ compliance with requirements (per FMFIA), or equivalent

▪ report on internal controls for corporations covered by the Government Corporation Control Act (per

CFOA)

▪ EEOC reports

▪ Analysis and Action Plans and other reports required by EEOC’s MD 715

▪ No FEAR Act reports

▪ service organization auditor report, or equivalent

▪ annual strategic review

▪ identified material weaknesses and corrective actions report

▪ improper payments report

▪ premium class travel report

▪ report on property provided to nonfederal recipients, schools, and nonprofit educational institutions

▪ feeder reports to the Status of Telework in the Federal Government Report to Congress

▪ feeder reports to GSA fleet reports

▪ E-Government status and compliance report (per PRA)

Temporary. Destroy 6 years after report submission or oversight entity notice of approval, as appropriate, but longer retention is authorized if required for business

DAA-GRS-

Item Number

Records Description Disposition Instructions

Disposition Authority

Includes ancillary records such as:

▪ background and research records

▪ submission packets and compilations

▪ related files

EXCLUSION 1: Oversight entities mandating the reports must separately schedule reports they receive.

EXCLUSION 2: Mandatory external reports on finance matters (GRS 1.1, items 020 and 040 cover these);

mandatory external reports on employee ethics (items in GRS 2.8 cover these); mandatory external reports on information access and protection (GRS 4.2 item 080 covers these).

1002.6 Records of Allegations and Claims That Fall Under U.S. Office of Special Counsel Jurisdiction.

Case files of interactions with the Office of Special Counsel (OSC) responding to allegations of illegality, waste, corruption, or other misconduct per the Civil Service Reform Act, Whistleblower Protection Act, Hatch Act, and Uniformed Services Employment & Reemployment Rights Act (USERRA). Includes correspondence with and reports to and from the OSC; copies of testimony or hearing transcripts; copies of lists of corrective actions, orders or decisions, and appeals; and copies of final adjudications thereof.

EXCLUSION 1: Records the Merit Systems Protection Board and the Office of Special Counsel create and hold (these entities schedule such records separately).

EXCLUSION 2: Records of allegations of illegality, waste, corruption, or other misconduct reported to authorities within the whistleblower's own agency and handled without involving OSC (agencies must schedule such records separately).

3 years after final order or final adjudication of appeal, as appropriate, but longer retention is authorized if required for business use.

GRS 5.7, item

DAA-GRS-

1004- Records Management Records

This schedule covers records created and maintained by Federal agencies that relate to the management of records and information. It includes records related to tracking and controlling agency records and documents, records management, forms management, and managing essential records.

Records Description Disposition Instructions

Disposition Authority

1004.1 Tracking and Control Records.

Records used to provide access to and control of records authorized for destruction by the GRS or a NARA-approved records schedule. Includes:

▪ indexes

▪ lists

▪ registers

▪ inventories

▪ logs

EXCLUSION 1: This schedule excludes records containing abstracts of records content or other information that can be used as an information source apart from the related records.

EXCLUSION 2: This authority does not apply to tracking and control records related to records scheduled as permanent. The value of these records varies, so tracking and control records related to permanent records must be scheduled.

when no longer needed.

GRS 4.1, item

DAA-GRS-

2013-0002-

1004.2 Records Management Program Records.

Records related to the policies, procedures, and management of agency business records from creation to eventual disposition. Includes records created and maintained while planning, managing, evaluating, administering, and performing the function of agency records management. Activities include:

▪ providing oversight of entire records management program

▪ transferring, destroying, and retrieving records

▪ inventorying records and conducting records surveys

▪ scheduling records

▪ providing other records management services to customer units (such as records storage/reference assistance, and technical assistance with files plans and other records management questions)

▪ conducting records "clean out" days

Conducting special records projects include:

▪ agency records management program surveys or evaluations

▪ reports of surveys or evaluations

Temporary. Destroy no sooner than 6 years after the project, activity, or transaction is completed or superseded, but longer retention is authorized if needed for business use.

GRS 4.1, item

DAA-GRS-

2013-0002-

Item Number

Records Description Disposition Instructions

Disposition Authority

▪ reports of corrective action taken in response to agency program surveys or evaluations

▪ disposal authorizations, schedules, and reports

▪ records schedules, legacy records schedules (SF 115, Request for Records Disposition Authority)

▪ SF 135, Records Transmittal and Receipt

▪ OF 11, Reference Request

▪ Transfer Request (TR); Legal Transfer Instrument (LTI); SF 258, Agreement to Transfer Records to the

National Archives of the United States

EXCLUSION: This schedule item covers copies of the records schedule, transfer request, legal transfer instrument, and similar forms maintained by agencies—not the copies maintained by NARA.

1004.3 Vital or Essential Records Program Records.

Records involved in planning, operating, and managing the agency’s vital or essential records program.

Includes:

▪ vital records inventories

▪ vital records cycling plans

▪ results of tests, surveys, or evaluations

▪ reports of corrective action taken in response to agency vital records tests

3 years after project, activity, or transaction is completed or superseded, but longer retention is authorized if needed

GRS 4.1, item

DAA-GRS-

2013-0002-

1004.4 Copies of Vital Records.

Copies of agency records deemed essential to restore agency functions in case of emergency.

Temporary. Destroy when superseded by the next cycle.

DAA-GRS-

1004.5 Forms Management Records.

Records involved with ensuring use of standard Federal and agency forms to support effective record-keeping and ensuring that Federal standard forms are available and used as appropriate to support Federal record-keeping requirements. Includes:

▪ registers or databases used to record and control the numbers and other identifying data assigned to each form

▪ official case files consisting of the record copy of each agency-originated form with related instructions and documentation showing inception, scope, and purpose of the form

▪ background materials and specifications

3 years after form is discontinued, superseded, or cancelled, but longer retention is authorized if needed for business use.

GRS 4.1, item

DAA-GRS-

Item Number

Records Description Disposition Instructions

Disposition Authority

1004.6 Validation Records for Digitized Temporary Records.

Records used to document (validate) that the digitized versions of temporary records are of suitable quality to replace original source records. Includes but is not limited to:

▪ Standards and procedures records used to document that the agency has met validation process requirements, such as:

o quality management plans describing quality assurance objectives o quality control (QC) protocols o format-specific instructions

▪ Records documenting validation actions, such as:

o equipment calibration and test reports o image quality testing results o QC plans, procedures, and reports

EXCLUSION 1: Validation records for digitized permanent records.

EXCLUSION 2: Original source records the agency has digitized and validated; GRS 5.2, Transitory and Intermediary Records, Item 020, or a current, approved agency-specific records schedule that covers the records once digitized covers these.

EXCLUSION 3: Digital surrogates (the newly digitized records); the appropriate current, approved agency-specific records schedule or applicable GRS item covers these.

Legal citation: 36 CFR Part 1236.34 the validation documentation associated with each record that has been digitized when the records digitized using that validation process are destroyed, but longer retention is

DAA-GRS-

2019-0003-

1006- Information Access and Protection Records

This schedule covers records created in the course of agencies (1) responding to requests for access to Government information and (2) protecting information that is classified, controlled unclassified, or contains personal data that is required by law to be protected.

Records Description Disposition Instructions Disposition Authority

1006.1a FOIA, Privacy Act and Classification Documents Administrative Records.

Records on managing information access and protection activities. Records include:

▪ correspondence related to routine implementation of the FOIA and Privacy Act and administration of security classification

▪ associated subject files

▪ feeder and statistical reports

Temporary. Destroy when 3 years old but longer retention is authorized if needed for business use.

GRS 4.2, item

DAA-GRS-

2019-0001-

1006.1b General Information Request Files.

Requests for information, publications, photographs, and other information involving no administrative action, policy decision, or special compilations or research. Also includes acknowledgements, replies, and referrals of inquiries to other offices for response.

NOTE: Current: 36 CFR 1237.28(h) Metadata for Still Pictures Descriptive Elements must include:

▪ (1) An identification number;

▪ (2) Information about image content;

▪ (3) Identity and organizational affiliation of the photographer;

▪ (4) Existence of any copyright or other potential restrictions on image use; and

▪ (5) Technical data including file format and version, bit depth, image size, camera make and model, compression method and level, custom or generic color profiles (ICC/ICM profile)

Temporary. Destroy when 90 days old, but longer retention is authorized if required for business use.

GRS 4.2, item

DAA-GRS-

2013-0007-

1006.2 Access and Disclosure Request Files.

Case files created in response to requests for information under the Freedom of Information Act (FOIA), Mandatory Declassification Review (MDR) process, Privacy Act (PA), Classification Challenge, and similar access programs, and completed by:

▪ granting the request in full

▪ granting the request in part

▪ denying the request for any reason including:

➢ inability to fulfill request because records do not exist

➢ inability to fulfill request because request inadequately describes records

➢ inability to fulfill request because search or reproduction fees are not paid

Temporary. Destroy 6 years after final agency action or 3 years after final adjudication by the courts, whichever is later, but longer retention is authorized if required for business use.

GRS 4.3, item

DAA-GRS-

2016-0002-

Item Number

Records Description Disposition Instructions Disposition Authority

▪ final adjudication on appeal to any of the above original settlements

▪ final agency action in response to court remand on appeal

▪ requests (either first-party or third-party)

▪ replies

▪ copies of requested records

▪ administrative appeals

▪ related supporting documents (such as sanitizing instructions)

NOTE 1: Record copies of requested records remain covered by their original disposal authority, but if disposable sooner than their associated access/disclosure case file, may be retained under this item for disposition with that case file.

NOTE 2: Agencies may wish to retain redacted copies of requested records for business use after the rest of the associated request case file is destroyed.

1006.3 Information Access and Protection Operation Records.

NOTE: Forms involved in investigations are not covered by this item. They are instead retained according to the schedule item for records of the investigation.

a. Information access and protection tracking and control records. Includes:

tracking databases and other records used to manage overall program; requests and authorizations for individuals to have access to classified files.

NOTE: Records documenting individuals’ security clearances are covered under GRS 5.6, items 180 and 181.

Temporary. Destroy 2 years after last form entry, reply, submission, or when associated documents are declassified or destroyed; or when authorization expires, whichever is appropriate.

Longer retention is authorized if required for business use.

GRS 4.2, item

DAA-GRS-

2019-0001-

b. Access control records. Includes: safe and padlock combinations; names or other personal identifiers of individuals who know combinations comparable data used to control access into classified document containers.

Temporary. Destroy when superseded or obsolete, but longer retention is authorized

DAA-GRS-

2013-0007-

c. Records relating to classified or controlled unclassified document containers.

Includes forms places on safes, cabinets, or vaults that record opening, closing, and routine checking of container security.

Temporary. Destroy 90 days after last entry on form, but

DAA-GRS-

2016-0002-

Item Number

Records Description Disposition Instructions Disposition Authority

1006.4 Accounting for and Control of Access to Classified, Controlled Unclassified, and Unclassified Records and Records Regarding FOIA, PA, and MDR.

Records documenting identity, internal routing, and final disposition of classified documents. Also, records documenting control points and accountability for information relating to access requests.

▪ forms, registers, ledgers, logs, and tracking systems documenting requester identity and contact information, request date, and nature or purpose of request

▪ inventories of controlled records

▪ forms accompanying documents to ensure continuing control, showing names of people handling the documents, intra-office routing, and comparable data

▪ agent and researcher files

Temporary. Destroy 5 years after date of last entry, final action by agency, as appropriate, but longer retention is authorized if required for business use.

DAA-GRS-

2019-0001-

1006.5 Privacy Act Accounting of Disclosure Files.

Files maintained under the provisions of 5 U.S.C. §552a(c) for an accurate accounting of the date, nature, and purpose of each disclosure of a record to any person or to another agency. Includes:

▪ forms with the subject individual's name

▪ records of the requester's name and address

▪ explanations of the purpose for the request

▪ date of disclosure

▪ proof of subject individual's consent

Temporary. Dispose of in accordance with the approved disposition instructions for the related subject individual's records, or 5 years after the disclosure for which the accountability was made, whichever is later.

GRS 4.2, item

NC1-64-77-1,

item 27

1006.6 Erroneous Release Records.

Files relating to the inadvertent release of privileged information to unauthorized parties, containing information on the disclosure of which would constitute an unwarranted invasion of personal privacy. Includes:

▪ requests for information

▪ copies of replies

▪ all related supporting documents

▪ may include official copy of records requested or copies

a. Records in which record-keeping copy of the released records is interfiled with records of the erroneous release.

Temporary. Follow the disposition instructions approved for the released record copy or destroy 6 years after the erroneous release, whichever is later.

DAA-GRS-

2015-0002-

b. Files that do not include the record-keeping copy of the released records.

Temporary. Destroy 6 years after the erroneous release, but longer retention is authorized if required for business use.

DAA-GRS-

Item Number

Records Description Disposition Instructions Disposition Authority

1006.7 Agency Reports to the Congress, Department of Justice, or Other Entities Regarding FOIA, MDR, PA, and Similar Access and Disclosure Programs.

NOTE: This item does not apply to summary reports incorporating government-wide statistics. These must be scheduled separately by the summarizing agent.

after date of report, but longer

DAA-GRS-

2013-0007-

1006.8 Legal and Regulatory Compliance Reporting Records.

Reports prepared in compliance with Federal laws and regulations, such as the E-Government Act (Public Law 107-347), Title III (Federal Information Security Management Act), and Title V (Confidential Information Protection and Statistical Efficiency Act), as codified in 44 U.S.C. §101.

a. Annual reports by agency CIO, Inspector General, or Senior Agency Official for Privacy.

Legal Citation: OMB M-07-16

Temporary. Destroy 5 years after submission of report, but

DAA-GRS-

b. All other agency reports and internal reports by individual system owners to the Senior Agency Official for Privacy (SAOP).

after submission of report, but

DAA-GRS-

1006.9 Privacy Act Amendment Request Files.

Files relating to an individual’s request to amend a record pertaining to that individual under 5 U.S.C.

§552a(d)(2), to the individual’s request for review of an agency’s refusal to amend a record under 5 U.S.C. §552a(d)(3), and to any civil action or appeal brought by the individual against the refusing agency under 5 U.S.C. §552a(g). Includes:

▪ requests to amend and to review refusal to amend

▪ copies of agency’s replies

▪ statement of disagreement

▪ agency justification for refusal to amend a record

▪ appeals

▪ related materials

Temporary. Destroy with the records for which amendment was requested or 4 years after close of case (final determination by agency or final adjudication, whichever applies), whichever is later.

DAA-GRS-

2013-0007-

1006.10 Automatic and Systematic Declassification Review Program Records.

Files related to the review of permanent records in anticipation of automatic declassification at 25, 50, or 75 years per Executive Order 13526, and the periodic review of records exempted from automatic declassification. Files include program records documenting declassification decisions.

Temporary. Destroy or delete 30 years after completion of review, but

DAA-GRS-

Item Number

Records Description Disposition Instructions Disposition Authority

1006.11 Fundamental Classification Guidance Review Files.

Reports, significant correspondence, drafts, received comments, and related materials responding to “fundamental classification guidance review” as required by Executive Order 13526 Section 1.9.

NOTE: This item does not cover reports and correspondence received at the Information Security Oversight Office (ISOO).

Temporary. Destroy 5 years after report is submitted to ISOO, but longer retention is authorized if required for business use.

GRS 4.2, item

DAA-GRS-

1006.12 Classified Information Nondisclosure Agreements.

Copies of nondisclosure agreements, such as SF 312, Classified Information Nondisclosure Agreement, signed by civilian and military personnel with access to information that is classified under standards put forth by executive orders governing security classification.

a. Maintained in the individual’s official personnel folder.

Temporary. Apply the disposition for the official personnel folder.

See OPF record schedule

b. Maintained separately from the individual’s official personnel folder.

Legal Citation: ICD 703, Protection of Classified National Intelligence; 32 CFR 2001.80(d)(2)(vii)

Temporary. Destroy when 50 years old.

GRS 4.2, item

DAA-GRS-

1006.13

Personally Identifiable Information Extracts.

System-generated or hardcopy print-outs generated for business purposes that contain Personally Identifiable Information.

Legal Citation: OMB M-07-16 (May 22, 2007), Attachment 1, Section C, bullet “Log and Verify”.

90 days old or no longer needed pursuant to supervisory authorization, whichever is appropriate.

DAA-GRS-

2013-0007-

1006.14 Personally Identifiable Information Extract Logs.

Logs that track the use of PII extracts by authorized users, containing some or all of: date and time of extract, name and component of information system from which data is extracted, user extracting data, data elements involved, business purpose for which the data will be used, length of time extracted information will be used. Also includes (if appropriate): justification and supervisory authorization for retaining extract longer than 90 days, and anticipated disposition date.

business use ceases.

GRS 4.2, item

DAA-GRS-

1006.15 Privacy Act System of Records Notices. (SORNs)

Agency copy of notice about the existence and character of systems of records, documenting publication in the Federal Register when agency establishes or revises the system, per the Privacy Act of 1974 5 U.S.C. 552a(e)(4) and 5 U.S.C. 552a(e)(11), as amended. Also significant material documenting SORN formulation, other than Privacy Impact Assessment records (see GRS 4.2 item 161).

after supersession by a revised SORN or after system ceases operations, but longer retention is authorized if required for business use.

GRS 4.2, item

DAA-GRS-

2016-0003-

Item Number

Records Description Disposition Instructions Disposition Authority

1006.16 Records Analyzing Personally Identifiable Information (PII).

Records documenting whether certain privacy and data security laws, regulations, and agency policies are required; how the agency collects, uses, shares, and maintains PII; and incorporation of privacy protections into records systems as required by the E- Government Act of 2002 (Public Law 107-347, section 208), the Privacy Act of 1974 (5 U.S.C. 552a), and other privacy laws, regulations, and agency policies.

Includes significant background material documenting formulation of final products.

a. Records of Privacy Threshold analyses (PTAs) and Initial Privacy Assessments (IPAs). Records of research on whether an agency should conduct a Privacy Impact Assessment (PIA).

Temporary. Destroy 3 years after associated PIA is published or determination that PIA is unnecessary, but

DAA-GRS-

2016-0003-

b. Record of Privacy Impact Assessments (PIAs).

Temporary. Destroy 3 years after superseding PIA is published, after system ceases operations, or (if PIA concerns a website) after website is no longer available to the public, as appropriate.

DAA-GRS-

2016-0003-

1006.17 Computer Matching Program Notices and Agreements.

Agency copy of notices of intent to share data in systems of records with other Federal, State or local government agencies via computer matching programs, and related records documenting publications of notice in the Federal Register per Privacy Act of 1974 (5 U.S.C. 552. (e)(12), as amended.

Also agreements between agencies, commonly referred to as Computer Matching Agreements, prepared in accordance with Office of Management and Budge final guidance. Including documentation of Data Integrity Board (DIB) review and approval of matching programs and agreements, and significant background material documenting formulation of notices and agreements.

Temporary. Destroy upon supersession by revised notice or agreement, or 2 years after matching program ceases operation, but longer retention is authorized if required for business use.

GRS 4.2, item

DAA-GRS-

2016-0003-

1006.18 Virtual Public Access Library Records.

Records published by agency on line to fulfill the requirement in 5 U.S.C. 552(a)(2)(A) through 5 U.S.C.

552(a)(2)(D) and 5 U.S.C.552(g)(1) through 5 U.S.C. 552(g)(3) that agencies must make those records available for public inspection and copying. Includes:

▪ final concurring and dissenting opinions and orders agencies issue when adjudicating cases

▪ statements of policy and interpretations the agency adopts but does not publish in Federal

Resister

▪ copies of records requested under the Freedom of Information Act (FOIA) which, because of the nature of their subject matter, the agency determines are, or likely to become, the subject of subsequent requests for substantially the same records or which have been requested three or more times

▪ indexes of agency major information systems

Temporary. Destroy when no longer needed.

GRS 4.2, item

DAA-GRS-

2016-0008-

Item Number

Records Description Disposition Instructions Disposition Authority

▪ description of agency major information and record locator systems

▪ handbooks for obtaining various types and categories of agency public information

1006.19 Privacy Complaint Files. (PSETS)

Records of privacy complaints (and responses) agencies receive in these categories:

▪ process and procedural (consent, collection, and appropriate notice)

▪ redress (inquiries seeking resolution of difficulties or concerns about privacy matters not specifically outlined in the Privacy Act)

▪ operational (inquiries regarding Privacy Act matters but not including Privacy Act requests for access and/or correction)

▪ complaints referred to another organization

Temporary. Destroy 3 years after resolution or referral, as appropriate, but longer retention is authorized if required for business use.

GRS 4.2, item

DAA-GRS-

2019-0001-

1007…