BTFA-003-Records-and-Information-Management-Policy_24314.pdf

BTFA-003 OFFICIAL POLICY PAGE 1

United States Department of the Interior

BUREAU OF TRUST FUNDS ADMINISTRATION

Washington, DC 20240

Records and Information Management Policy

POLICY NO: BTFA-003

EFFECTIVE DATE: Date of Signature

TO: All BTFA Employees

APPROVING OFFICIAL: Director, BTFA

TITLE: Records and Information Management Policy

SUMMARY

The purpose of this policy is to establish policies and responsibilities within the guidelines of an Information Governance Plan (IGP) to ensure that records and information management is in compliance with regulatory and statutory requirements for the Bureau of Trust Funds Administration (BTFA).

In accordance with Federal statutes, regulations, and guidance, Federal employees must make and preserve records containing adequate and proper documentation of the organization, functions, policies, decisions, procedures, and essential transactions of an agency. Records and information must be managed and accessible to protect the legal and financial rights of the Government and any persons directly affected by a bureaus’ activities.

POLICY

The Office of Trust Records’ (OTR) objectives are to develop and provide policies that are consistent with the requirements set forth in the Federal Records Act 44 U.S.C., Chapter 31 to ensure that:

1. Records and information are managed throughout the three phases of the records lifecycle, from initial creation, maintenance, and use to final disposition in accordance with the National Archives and Records Administration (NARA) approved records schedules.

2. Electronic Information Systems are identified and managed to ensure the elimination of paper-based systems.

3. Unauthorized access, removal, loss, or destruction of records and information is prevented.

4. An Essential Records Plan (ERP) is created and maintained.

This policy supersedes the Indian Affairs Records Management Manual. Procedures and required forms will be defined in OTR’s Records and Information Management Principles and Procedures Handbook.

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RESPONSIBILITIES

All employees, contractors, volunteers, temporary employees, and seasonal employees must comply with all recordkeeping policies, standards, and guidance to ensure that the organization's functions, policies, decisions, procedures, and essential transactions are documented, regardless of media or format.

1. Director, BTFA:

BTFA’s Director is responsible for oversight of the organization’s records and information management strategic plans, reports, and overall objectives and compliance standards. The incumbent:

a. Ensures that an IGP is established and maintained.

b. Delegates the responsibility of the records and information management to the Associate

Chief Information Officer (ACIO).

c. Ensures that performance standards reflect records and information management duties for Senior Managers, as appropriate.

2. Associate Chief Information Officer The ACIO is responsible for the oversight and administration of a records and information management program to support the IGP. The incumbent delegates the responsibility of the records and information management program to the Director of OTR.

3. Director, OTR OTR’s Director is responsible for supporting the organization's IGP and executing records and information management objectives and compliance standards by issuing policies, procedures, and guidance. The incumbent:

a. Oversees a records and information management program that complies with NARA, Department of the Interior (DOI), and BTFA policies and objectives.

b. Manages strategic plans, budgetary costs, and related expenditures for the records and information management program.

c. Communicates with DOI, as appropriate, to maintain an effective records and information management program.

d. Identifies, documents, disseminates, and periodically reviews recordkeeping requirements.

e. Coordinates records and information management activities with NARA and other Federal agencies.

f. Resolves inter-bureau records and information management issues.

g. Provides oversight and support to the Responsible Records Officer.

h. Supports the records and information management training program.

i. Ensures compliance with 303 DM 6, Indian Fiduciary Trust Records.

4. Responsible Records Officer The Responsible Records Officer is responsible for administering and managing an effective records and information management program. The incumbent:

a. Advises senior management in all aspects of the records and information management program.

b. Collaborates with the Continuity of Operations Administrator to meet operational records and information management responsibilities in the event of an emergency or disaster.

c. Ensures that Records and Information Management Specialists (RIMS) are kept current with established recordkeeping requirements.

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d. Ensures that records schedules are developed, updated, approved, and published.

e. Ensures full compliance with legal and preservation holds.

f. Responds to data calls and information requests.

g. Provides oversight and support to the RIMS.

h. Participates in the design and acquisition of new systems.

i. Oversees the records and information management training program.

j. Coordinates records and information management activities with other Federal agencies, such as NARA, the Department of Justice, the Office of Management and Budget, and the Office of the Solicitor.

k. Provides guidance to Indian Tribes under P.L. 93-638, contracted and compacted programs for IFTR.

5. Records and Information Management Specialist The Records and Information Management Specialist serves as a liaison with other bureaus and offices to implement and maintain an effective records and information management program. The incumbent:

a. Provides records and information management guidance and technical assistance to other bureaus/offices.

b. Coordinates and disseminates directives, policies, and procedures relative to the records and information management program.

c. Assists with the review and revision of records schedules.

d. Assists with change management to support new or revised programs, processes, systems, and procedures.

e. Develops, plans, and provides training for all levels of staff on records and information management topics.

f. Provides pre- and post-technical assistance as it relates to records and information management assessments.

g. Assists programs with disposition activities.

h. Assists programs with data calls and other requests.

i. Conducts records and information management briefings to senior officials.

6. American Indian Records Repository The American Indian Records Repository is responsible for the preservation, protection, storage, and management of Indian Affairs records in its custody and performs research required to support litigation and records requests.

7. Senior Official The Senior Official is responsible for the oversight of a programs records and information management plan. The incumbent:

a. Ensures that all records and information are in full compliance.

b. Establishes and maintains communication with the RIMS to ensure records and information management programs are implemented and operational.

c. Ensures that performance standards reflect records and information management duties, as appropriate, for staff.

d. Ensures that all offices establish and maintain program-level essential records plans and copies are provided to the Continuity of Operations Administrator.

e. Plans and budgets for records and information management costs and related expenditures.

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8. Program Supervisor/Manager The Program Supervisor/Manager is responsible for ensuring that all staff under their supervision comply with all aspects of records and information management. The incumbent:

a. Implements, manages, and supports a records and information management program.

b. Ensures that records and information document the activities, transactions, and decisions of the program.

c. Ensures that a program Files Maintenance and Essential Records Plan (Files Plan) is created, reviewed, approved, and implemented annually.

d. Communicates and disseminates directives, policies, and procedures to program staff.

e. Establishes and maintains program communication with the RIMS and serves as the first point-of-contact for records management operations.

f. Completes all required records and information management training.

g. Designates a program Records Contact (RC) and ensures that all required records and information management training are completed to carry out their RC responsibilities.

h. Ensures all staff complete required records and information management training.

i. Reviews records schedules and reports any unscheduled records or electronic information systems to OTR.

j. Initiates disposition activities using NARA-approved records schedules.

k. Responds to and completes Corrective Action Plans, data calls, and other information requests.

l. Creates and maintains an essential records plan and provides a copy to their Senior

Official.

m. Ensures that departing employees identify and transfer ownership of all records and information to management or other designee prior to separation.

9. Program Records Contact The RC is responsible for assisting the program supervisor/manager with the records and information management program. The incumbent:

a. Completes RC records and information management training.

b. Updates and maintains the Files Plan, as delegated by the Program Supervisor/Manager.

c. Assists with disposition activities.

d. Assists with the communication and dissemination of directives, policies, and procedures to program staff, as delegated by the Program Supervisor/Manager.

10. Program Staff Program Staff are responsible for safeguarding and the preservation of records and information. The incumbents:

e. Create, maintain, and disposition records and information in accordance with NARA-approved records schedules.

f. Assist with identifying and listing records and information on the Files Plan.

g. Complete all required records and information management training.

h. Transfer all records and information within their custody to their program supervisor/manager or designee upon separation.

AUTHORITY

A. Statutes

1. 44 U.S.C. Chapter 21, National Archives and Records Administration

2. 44 U.S.C. Chapter 29, Records Management by the Archivist of the United States and by the Administrator of General Services

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3. 44 U.S.C. Chapter 31, Records Management by Federal Agencies

4. 44 U.S.C. Chapter 33, Disposal of Records

5. 44 U.S.C. Chapter 35, Paperwork Reduction Act

6. 40 U.S.C. §§ 11101-11704, Information Technology Management Reform Act of 1996

7. 29 U.S.C. § 794d, Section 508, Federal Electronic and Information Technology

8. 25 U.S.C. § 4001, The American Indian Trust Fund Management Reform Act of 1994, Pub.L.103-412

9. 25 U.S.C. § 450, et seq., Indian Self-Determination and Education Assistance Act, Public Law 93-638, as amended

10. 5 U.S.C. § 552, Freedom of Information Act

11. 5 U.S.C. § 552a, The Privacy Act of 1974

B. Regulations

1. 36 CFR Chapter XII, Subpart B, Records Management

2. 32 CFR Part 2002, Controlled Unclassified Information

3. Federal Register, Volume 70, No. 166, pp. 51081-51083, “Final Decision Regarding

Self-Determination and Self-Governance Funding Agreement Language on Fiduciary Trust Records Management,” (August 29, 2005)

C. Guidance

1. 110 DM 26, Office of the Special Trustee for American Indians (November 24, 2009)

2. 303 DM 2, Principles for Managing Indian Trust Assets (October 31, 2000)

3. 380 DM 1 Records Management Program and Responsibilities (October 7, 1993)

4. 380 DM 2 Adequacy of Documentation (July 11, 1994)

5. 380 DM 6 Vital Records Programs (March 11, 1998)

6. 382 DM 11 Managing Records in Electronic Form (December 09, 1985)

7. 384 DM 1 Disposition (May 12, 1989)

8. 384 DM 2 Records Disposition Schedules (December 31, 1986)

9. 384 DM 4 Transfer of Records (December 31, 1986)

10. 387 DM 1 Forms Management (January 28, 2015)

11. Government Paperwork Elimination Act (GPEA), Title XVII (Pub.L. 105-277)

12. Circular A-130, Management of Federal Information Resources

13. OMB Circular A-130, Appendix II, Implementation of the Government Paperwork

Elimination Act

14. OMB Memorandum M-19-15, Improving Implementation of the Information Quality

Act

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

EXPIRATION

This policy is valid until it is redacted or otherwise cancelled by BTFA’s Director.

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CONTACT

Mary Beth Roberts, Records Officer Office of Trust Records Bureau of Trust Funds Administration 4400 Masthead St. NE Albuquerque, NM 87109

(505) 816-1640

APPROVAL

Director, BTFA Date