HHS Policy for Records Management
January 30, 2008
HHS-2007-0004.001
Table of Contents
1. Nature of Changes
2. Purpose
3. Background
4. Scope
5. Policy
6. Roles and Responsibilities
7. Applicable Laws/Guidance
8. Information and Assistance
9. Effective Date
10. Approved
Glossary
Attachment 1- Employee Departure Process
Attachment 2- Department of Health and Human Services, Documentary Materials Removal/Non-Removal Certification With Non-Disclosure Agreement
Attachment 3- Department of Health and Human Services Documentary Non-Removal Certification
1. Nature of Changes
This is a revision to the September 15, 2005 issuance of the HHS-OCIO-2005-0002.001, Policy for Records Management; and a consolidation and obsolescence of the September 15, 2005 issuance of the HHS-OCIO-2005-0001.001, Electronic Records Management Policy, and, the September 27, 2007 issuance of the HHS-OCIO-2007-0003, Policy for Records Management Employee Departures. The requirements contained in these policies have been revised, consolidated and included into this one policy.
2. Purpose
The purpose of this policy is to establish the principles, responsibilities, and requirements for managing Health and Human Service (HHS) records. This Department-wide policy provides the framework for specific program guidance and detailed operating procedures to be developed and implemented at the organizational unit level.
3. Background
The Federal Records Act of 1950, as amended, requires all Federal agencies to make and preserve records containing adequate and proper documentation of the organization, function, policies, decisions, procedures, and essential transactions. These records are public property and must be managed according to applicable laws and regulations.
The Federal Records Act also requires agencies to establish a records management program. This program is defined as a planned, coordinated set of policies, procedures, and activities needed to manage its recorded information. Essential elements include issuing up-to-date records management policies, properly training those responsible for implementation, and carefully evaluating the results to ensure adequacy, effectiveness, and efficiency.
4. Scope
This Policy applies to all Federal records created or received by HHS Department Operating Divisions (OPDIVs), including the Office of the Secretary (OS), and organizations conducting business for and on behalf of the Department, whether owned and operated by HHS through contractual relationships and/or service level agreements. Within this policy the term OS Operating Division (OPDIV) includes Agencies reporting to the HHS Inspector General, as well as the Office of the Secretary as a combined single entity.
5. Policy
It is HHS policy to preserve all official records in accordance with applicable statutory and regulatory requirements, and to promote access to information by staff, partners, and the public, as appropriate. Each office within HHS is required to establish and maintain a records management program meeting the following minimum requirements:
5.1 Create, receive, and maintain official records providing adequate and proper documentation as evidence of HHS’ activities.
5.2 Manage records, regardless of format, in accordance with applicable statutes, regulations, and HHS policy and guidance.
5.3 Maintain electronic records, including electronic mail records, in an enterprise-wide electronic content management system with record keeping functionality, when available, and migrate legacy systems.
5.4 Print and file records in a paper record keeping system if an enterprise-wide electronic content management system with record keeping functionality is not available.
5.5 Maintain records according to a designated file structure.
5.5.1 Each mission area, OPDIV/STAFFDIV, shall maintain a centralized list and description of its official records, including official electronic files. Mission areas, OPDIV/STAFFDIV, shall strive to standardize file arrangement systems, filing procedures, and filing techniques of official records. These shall be designed to enhance the current use of the files, the preservation of archival records, and the prompt and systematic disposition of temporary records according to the appropriate records schedule.
5.5.2 Secure records to protect the legal and financial rights of the government and persons affected by government activities.
5.6.1 transfer to a Federal Records Center, or
5.6.2 transfer to a records retention facility meeting the requirements of 36 CFR Chapter 12, Subchapter B, Subpart K, or
5.6.3 disposal, if authorized
5.6.4 Following instructions for disposition of records as specified in the approved records schedules including the General Records Schedules (GRS) for routine administrative records
5.6.5 Each mission area is required to regularly review their current records control schedules and, when required, to draft records control schedules for new programs and unscheduled records as specified in 36 CFR 1228.
5.7 Create a Vital Records Program.
Provide appropriate training. HHS Records Officers shall provide records orientation training to new employees and adequate training to other employees to ensure they continue to be aware of their responsibilities to maintain and safeguard Department records.
5.7.1 New Employee - Mission areas, OPDIV/STAFFDIVs and all offices shall provide records orientation training to new employees within their first 30 days of duty.
5.7.2 Annual Training – Annual training will be provided to all employees as a reminder of their responsibilities to maintain and safeguard HHS records.
5.7.3 New Supervisors – New Supervisors are to work with their Records Officer to determine the type of training needed for the position they fill. This will include a review of their Records Program and the need for their team members to obtain training to identify and protect HHS records.
5.8 Establish an appropriate employee departure program. This pertains to employees departing their existing position, the immediate organization, the agency, or the federal government. Attachments 1, 2 and 3 may be used to document the departure process. See attachments 1, 2 and 3.
6. Roles and Responsibilities
6.1 The Secretary of Health and Human Services
The Secretary of Health and Human Services is ultimately responsible for creating and preserving records that adequately and properly document the organization, functions, policies, decisions, procedures, and essential transactions of HHS. The responsibility for establishing a program to ensure compliance with applicable Federal laws and guidelines has been delegated to the Assistant Secretary for Resources and Technology, Deputy Assistant Secretary for Information Technology, Office of the Chief Information Officer (OCIO), Office of Resources Management (ORM).
6.2 Deputy Assistant Secretary for Information Technology (DASIT)/HHS CIO
The Office of Resources Management (ORM) within the Deputy Assistant Secretary for Information Technology (DASIT) is responsible for providing the leadership, planning, overall policy, guidance, and general oversight of records management in HHS, and its incorporation into the broader information resources management framework. ORM will:
6.2.1. Incorporate records management requirements and policies into the Agency's overall information resources management (IRM) policy and planning.
6.2.2. Designate in writing an HHS (Department) Records Officer responsible for:
- Leading and managing the Department-wide records management program.
- Ensuring Department senior officials are aware of their programmatic and individual records management responsibilities.- Advising HHS on records management issues and developing records management policies, procedures, guidance, and training materials.
- Reviewing and coordinating the approval of HHS records schedules.
- Providing technical advice and training to all HHS organizations regarding the establishment and maintenance of effective records management programs.
- Evaluating record keeping practices to determine the effectiveness of the program.
- Promulgating and communicating HHS wide policies and guidance that reflect records management missions and goals and incorporate Federal requirements.
- Developing a vital records program.
- Conducting periodic evaluations of records management programs within HHS as part of the Records Management and oversight program.
6.3 Assistant Secretaries; Directors; Administrators; Chair Departmental Appeals Board; National Coordinator for Health and Information Technology; General Counsel; Inspector General; and, Office Directors
6.3.2 Ensuring the RO has adequate skills, training, resources, time, and appropriate authority to do the job.
6.3.3 Implementing a records management program within their area of responsibility to accomplish the objectives identified in federal regulations and HHS policies and procedures. Minimum program components include responsibilities for:
a. Identifying record keeping requirements for major programmatic and administrative records.
b. Evaluating the value of records within their span of responsibility to serve as a basis for assigning records retention and disposition instructions and implementing the most responsive and cost-effective means for managing them.
c. Developing file plans and indexing approaches, where appropriate, to simplify the use of, access to, and integration of information within the organization.
d. Drafting and updating records schedules for records created and maintained by the organization.
e. Implementing approved records schedules to ensure that records are not destroyed without proper authorization.
f. Reviewing file plans and procedures at least every three years to ensure they are current and updating them as necessary.
h. Implementing a vital records program.
i. Providing records management briefings for all managers and training to staff within their organizations.
j. Developing records management oversight roles and communication networks with all program units including field offices and other facilities, as appropriate, to ensure that the records management program is implemented at all sites under their jurisdiction.
k. Developing and disseminating instructions and operating procedures, as needed to supplement Agency-wide policy to meet the unique records management needs of their organizations and to support a records management program within the organization.
l. Ensuring records and other types of required documentary materials are not unlawfully removed from HHS by current or departing officials, employees, or contractors.
m. Performing an annual inventory to determine changes in any programs that would create a change in the Records Schedule and taking the appropriate action.
n. Implementing a vital records program.
o. Ensuring funds availability for records storage.
6.4 The Inspector General
The General Counsel assists in determining what records are needed to provide adequate and proper documentation of HHS activities and in specifying appropriate disposition for HHS records. Submissions of Records Schedule additions/changes will be coordinated with the Office of the General Counsel.
The Inspector General assists in determining the retention of Department records that may be needed for internal audit purposes.
6.5 The Department Enterprise Architect
The Department Enterprise Architect, as delegated by the Chief Information Officer, shall ensure that any and all systems development plans, schedules, work breakdown structures, business cases, and OMB Exhibits 300 (“Capital Asset Plan and Business Case Summary”) address records management provisions upfront in the planning and development stages of the lifecycle by establishing the requirement that an architectural records management layer be addressed in consultation with the Senior Records Manager as standard development, regardless of medium (paper, electronic, etc.).
6.6 The OPDIV Chief Information Security Officer (CISO)
The OPDIV CISO is responsible for ensuring the technical security of the OPDIV electronic data records according to HHS and OPDIV standards. He/she is responsible for implementing this policy in conjunction with the OPDIV Records Officer, who is responsible for assigning a value to the data. The OPDIV CISO is responsible for providing the detailed monitoring, enforcement tools and procedures as well as the requirements for incident reporting established under the Security Policy.
6.7 Information Resources and System Managers
Information resources and system managers are responsible for:
a. Working with the local Records Officers and NARA to establish and update records schedules for electronic systems.
b. Working with Records Officers to implement proper recordkeeping procedures for existing information systems and ensuring recordkeeping requirements are included in proposed systems.
c. Ensuring that information systems intended to carry out electronic records management comply with NARA's and HHS' requirements for electronic recordkeeping systems.
d. Maintaining electronic information systems in accordance with approved records schedules and NARA requirements.
e. Working with their Records Officers to transfer permanent systems to the National Archives in accordance with approved records schedules and NARA requirements.
f. Ensuring that Internet and intranet postings containing official records are maintained in accordance with HHS recordkeeping requirements.
6.8 All HHS Employees
All HHS employees are responsible for:
- Creating and managing the records necessary to document the Agency's official activities and actions, including those records generated by HHS contractors and grantees, in accordance with HHS recordkeeping requirements.
- Destroying records only in accordance with approved records schedules and never removing records from HHS without authorization.
7. Applicable Laws and Guidance
- Federal Records Act of 1950, as amended (44 U.S.C. Chapter 21, Chapter 29, Chapter 31, Chapter 33).
- National Archive and Records Administration Act of 1984 (Public Law 98-497, 44 U.S.C. Chapter 21).
7.2 Regulations
- 36 CFR Chapter XII, Subchapter B especially Part 1234, “Electronic Records Management”.
- 36 CFR Chapter XII, Subchapter G, “Damage to, Alienation and Unauthorized Destruction of Records”.
- Federal Information Resources Management Regulation (FIRMR) Bulletin B-1, “Electronic Records Management”. (Note that FIRMR Bulletin B-1 is essentially the same as 36 CFR Chapter XII, Subchapter B, Part 1234)”.
- FIRMR Part 201-9, “Creation, Maintenance, and Use of Records”.
8. Information and Assistance
Direct questions, comments, suggestions or requests for further information to the Deputy Assistant Secretary for Information Technology, Office of the Chief Information Officer, Office of Resources Management, HHS Records Officer (202) 205-8548.
9. Effective Date/Implementation
The effective date of this policy is the date the policy is approved.
These policies and procedures will not be implemented in any recognized bargaining unit until the union has been provided notice of the proposed changes and given an opportunity to fully exercise its representational rights.
The HHS policies contained in this issuance shall be exercised in accordance with Public Law 93-638, the Indian Self-Determination and Education Assistance Act, as amended, and the Secretary's policy statement dated August 7, 1997, as amended, titled "Department Policy on Consultation with American Indian/Alaska Native Tribes and Indian Organizations." It is HHS' policy to consult with Indian people to the greatest practicable extent and to the extent permitted by law before taking actions that affect these governments and people; to assess the impact of the Department's plans, projects, programs and activities on tribal and other available resources; and to remove any procedural impediments to working directly with tribal governments or Indian people.
10. Approved
______________/s/___________________________________January 30, 2008___________
Michael W. Carleton DATE
Deputy Assistant Secretary for Information Technology/HHS Chief Information Officer
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Attachment 1 - Employee Departure Process
Steps that will help you meet your record keeping requirements.
1. Sort–
a. Record material.
b. Non-record material.
c. Personal material
As you sort the material:
Purge –
Destroy extra copies.
Destroy reference material that only you would need.
NOTE: Your email box may be of special concern. In the event that your mail box was not organized to match your files plan, the following is suggested.
Create a personal (.pst) folder for your personal information. Move your personal information from your mail box to that folder. You should also delete all information that is not a record. Give access to your mail box to your support staff with instructions to contact the subject matter experts for disposition guidance for the remaining messages.
2. Turn over – All Federal record material to the proper custodian.
3. Seek permission – You are likely to have extra copies of records kept for convenience of reference in your office or workstation. You may take these with you when you leave if you have the approval of your Records Officer, FOIA Officer, or legal counsel.
4. Follow Guidance established by your organizational unit for the transfer of records residing in electronic format (email, local drives, etc).
Record = A record is a unit of information, generated or received by an entity on behalf of the organization, which acts as evidence and provides a history of activities.
Most records are in the form of a document, although records in other forms are possible, such as photographs, videos, voice mail, etc.
The Record copy you leave provides the evidence and history of the work you performed. It must be organized in a meaningful manner and in most cases transferred to the National Archives. In the event the record copy does not exist or is not properly categorized for retrieval then questions can arise regarding your performance. Don’t give anyone the opportunity to question your service to the Health and Human Services mission.
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Attachment 2 - Department of Health and Human Services - Documentary Materials Removal/Non-Removal Certification With Non-Disclosure Agreement
Name: ____________________________ Office: ___________________________
Telephone Number: ___________________ Planned Departure Date: ____________
1. Records that May Not be Removed.
(1) Any material regardless of the media that meets the definition of a Federal Record. (2) Any information not normally released to the general public, unless prior approval has been obtained from the Records Officer and the Freedom of Information Act (FOIA) Officer.
2. Documentary Materials that May Be Removed: Personal Papers.
Examples of personal papers include: papers accumulated by an official before joining Government service that are not used subsequently in the transaction of Government business; materials relating solely to an individual's private affairs, such as outside business pursuits, professional affiliations, or private political associations that do not relate to agency business; diaries, journals, personal correspondence, or other personal notes that are not prepared or used for, or circulated or communicated in the course of transacting Government business (36 C.F.R., Section 1222.36(a), (b), and (c)). Copies of Federal Records if appropriate for release to the general public as determined by the FOIA Officer.
3. Penalties for Unlawful Removal of Records.
Criminal penalties are provided for the unlawful removal or destruction of Federal records (18 U.S.C. 641 and 2071) and for the unlawful disclosure of certain information pertaining to national security (18 U.S.C. 793, 794, 798 and 952).
4. Are you removing any non-record documents, such as extra copies of agency records, from the Department Of Health and Human Services? If yes, go to a. If no, go to b.
a. YES ____ Complete the below certification with the Reviewing Official.
Initials
I certify that the documents that I am removing from the Department of Health and Human Services have been reviewed and approved for removal. They do not include any documents relating to any pending or contemplated civil, criminal, or administrative proceeding or other program information, if released, would impair or prejudice the outcome of the proceeding or Government policy determinations, decisions, or other actions (Examples: classified documents; record copies; documents, even though judged to be a non-record, that will create a gap in the files; and indexes and finding aids necessary to use the official files). These documents are briefly described in the attachment.
Non-Disclosure Agreement:
I agree to keep all nonpublic materials absolutely confidential and will not disclose their contents or existence without prior permission from the appropriate Department of Health and Human Services Official.
_______________________________________________________ ___________
Sign and Print your Name Date
____________________________________________________ _________________
Organization and Title of Reviewing Official Telephone Number
(an HHS Records Officer)
_____________________________________________________ _______________
Signature of Reviewing Official Date
Attachment: as described above
Employee Name: ___________________________Office: ___________________________
Telephone Number: ___________________ Planned Departure Date: ____________
b. NO ___________________ Complete the certification below.
Initials
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Attachment 3 - Department of Health and Human Services - Documentary Non-Removal Certification
By my signature below, I certify that I am not removing any documents from the Department of Health and Human Services.
________________________________________________________ __________
Signature Date
_________________________________________________________
Print your Name
Glossary
Adequate Documentation - Regardless of media, official records shall be:
a. Accessible. The content or substance of the record, including the content or substance of the transaction, the processing of the transaction, the identities of the parties and specific individuals involved, and the intent of the parties, shall be accessible for the life of the record, despite changes to hardware, software, or business procedures.
b. Legally Sufficient. When a transaction must contain a signature in writing in order to be legally enforceable, due care will be taken to ensure that documentation provides a record that is not subject to imperfect memory or competing claims as to what parties to the transactions intended.
c. Reliable. Records in any media must be sufficiently reliable and persuasive to satisfy courts and others who must determine the facts underlying agency actions; and
d. Legally Compliant. The methods used to obtain, send, disclose and store information must comply with applicable laws, such as those governing privacy, confidentiality, recordkeeping, and accessibility to persons with disabilities.
e. Readable. All records must be readable or useable for their established retention period outlined in approved records control schedules.
f. Trustworthiness. All official records systems and document conversion processes must incorporate measures and security to prevent the unauthorized or undocumented alteration or tampering with documents.
Alienation - Losing care and custody. Not protecting from loss or access.
Control and Custody of Records - HHS records/materials are the property of the Federal government, not the property of individual employees or contractors acting as an agent for the Government, and may not be removed from the Department without proper authority. All employees/contractors shall maintain records and non-record documentary materials separately from one another.
Database – A set of data, consisting of at least one data file, that is sufficient for a given purpose.
Database Management System – A software system used to access and retrieve data stored in a computer database.
Data File – Related numeric, textual or graphic information that is organized in as strictly prescribed form and format.
Disposal – The action taken regarding temporary records after their retention periods expire and consisting usually of destruction or occasionally of donation. Also, when specified, “disposal” refers to the actions taken regarding non-record materials when no longer needed, especially their destruction. (See NARA, “A Federal Records Management Glossary.”)
Disposition – The action taken with regard to records following their appraisal by NARA (36 CFR 1220.14). The actions include transfer to agency storage facilities or Federal records center; transfer from one Federal agency to another; transfer of permanent records to the National Archives; and disposal of temporary records. “Disposition” is also the action taken regarding non-records materials when no longer needed, including screening and destruction. (NARA, “A Federal Records Management Glossary”).
Electronic Mail (Email) -The e-mail system is a data transmission system and not an appropriate location to maintain Federal Records. If the email message is a record, you must capture and save the date and time the message was sent or received as part of the record. The following will help in managing your mail box.
The email system is not a record keeping system. The record copy must be transferred to an appropriate record keeping system. The current process requires that the record copy be printed and maintained in paper.
When you leave, your access to the email account will be closed. All emails residing in the mail box will eventually be deleted. Emails under the control of HHS are subject to the discovery process.
Electronic Records – Any information that is recorded in a form that only a computer can process and that satisfies the definition of a Federal record in 44 U.S.C. 3301.[1] Electronic records include numeric, graphic and text information, which may be recorded on any medium capable of being read by a computer and which satisfies the definition of a record.
This includes, but is not limited to, magnetic media, such as tapes and disks, and optical disks. Unless otherwise noted, these requirements apply to all electronic records systems, whether on microcomputers, minicomputers, or mainframe computers, regardless of storage media, in network or stand-alone configurations. (FIRMR Bulletin B-1).
Electronic Records System – Any information that produces manipulates or stores Federal records by using a computer.
Information System – Is defined by the Office of Management and Budget (OMB) in Circular No. A-130 “….the organized collection, processing, transmission and dissemination of information in accordance with defined procedures, whether automated or manual.”
Mandatory Records Schedules - All records of the HHS shall be listed and described in an approved records schedule and shall be disposed of only as authorized by that schedule. Schedules shall be reviewed annually. Agencies should update their records schedules when there are program changes that will result in the establishment of new types of records, the transfer or termination of records no longer required, or an increase or decrease in the retention time of the records, to ensure the schedules accurately reflect current records and the functions they document (36 CFR 1228.50(d)).
When ever possible HHS should apply the NARA generated General Records Schedules (GRS) for routine administrative records. As required by regulation, HHS must ask NARA for a variance when not following the retention periods outlined by these schedules (36 CFR 1228.40(c)).
Non-record Materials – are those Federally-owned informational materials that do not meet the statutory definition of records (44 U.S.C. 3301), or that have been excluded from coverage by the definition. Excluded materials are extra copies of documents kept only for reference, stocks of publications and processed documents, and library or museum materials intended solely for reference or exhibit. (36 CFR 1220.14)
Office of the Secretary (OS) – is referenced in this Policy as the Operating Division and includes the Staff Divisions and the Offices of the Regions.
OMB Exhibit 300 - Capital Asset Plan and Business Case Summary – As prescribed and described in OMB’s Circular A-11, Preparation, Submission and Execution of the Budget.
OMB Circular A-130-Management of Federal Information Resources – Establishes policy for the management of Federal information resources. OMB includes procedural and analytic guidelines for implementing specific aspects of these policies. The policies in this Circular apply to the information activities of all agencies of the executive branch of the Federal government.
Operating Division – An entity of the Health and Human Services (HHS) Department that is an independent Agency.
Organization of Records - Records shall be maintained so that they are easily retrievable. Record systems shall be designed to furnish information necessary to protect the legal and financial rights of the Government and of persons directly affected by the Government's actions.
OS Operating Division (OPDIV) – The OSOPDIV includes the Inspector General, as well as the Office of the Secretary (and its Staff Divs) as a combined, single entity.
Personal Records (36 CFR 1222.37) - All employees shall clearly designate as personal, and maintain separately from the records of the office, those papers of a private or nonofficial nature that pertain to their personal affairs. Materials labeled “personal,” “confidential,” or “private,'” or similarly designated, and used in the transaction of public business, are Federal records subject to the provisions of pertinent laws and regulations. The use of a label such as “personal” is not sufficient to determine the status of documentary materials in a Federal office.
Personal papers are excluded from the definition of Federal records and are not owned by the Government. Personal papers shall be clearly designated as such and shall at all times be maintained separately from the records of the office. If information about both private matters and Department business appear in the same document, the document shall be copied at the time of receipt, with the personal information deleted, and treated as a Federal record. Examples of personal papers include:
Materials accumulated by an official before joining Government service that are not used subsequently in the transaction of Government business;
Materials relating solely to an individual's private affairs, such as outside business pursuits, professional affiliations, or private political associations that do not relate to agency business; and
Diaries, journals, personal correspondence, or other personal notes that are not prepared or used for, or circulated or communicated in the course of, transacting Government business.
Records – includes all books, papers, maps, photographs, machine readable materials, or other documentary materials, regardless of physical form or characteristics, made or received by an agency of the United States 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, decision, procedures, operations or other activities of the Government, or because of the information value of the data in them. (44 U.S.C. 3301).
Records Disposition – is any activity with respect to:
- disposal of temporary records no longer needed for the conduct of business by destruction or donation to an eligible person or organization outside of Federal custody;
- transfer of records to Federal agency storage facilities or records centers;
- transfer to the national Archives of the United States of records determined to have sufficient historical or other value to warrant continued preservation; or
- transfer of records from one Federal agency to any other Federal agency. (44 U.S.C. 2901 [5]).
Records Management – the planning, controlling, directing, organizing, training, promoting, and other managerial activities involved with respect to records creation, records maintenance and use, and records disposition in order to achieve adequate and proper documentation of the policies and transactions of the Federal Government and effective and economical management of agency operations. (44 U.S.C. 2901 [2].
Records Schedule – means:
- an SF 115, “Request for Records Disposition Authority,” that has been approved by NARA to authorize the disposition of Federal records;
- a General Records Schedule (GRS) issued by NARA; or
- a printed agency manual or directive containing the records descriptions and disposition instructions approved by NARA on one or more SF 115s or issued by NARA in the GRS. (36 CFR 1220.14).
Records series – file units or documents arranged according to a filing system or kept together because they relate to a particular subject or function, result from the same activity, document a specific kind of transaction, take a particular physical form, or have some other relationship arising out of their creation, receipt, or use, such as restrictions on access and use. (NARA, “A Federal Records Management Glossary”).
Reference Material - shall be clearly marked and maintained separately from the records of the office.
Reviewing Official – either the employee’s manager of record; a Records Officer; or, a Freedom of Information Act (FOIA) Officer.
Scheduling – the process of developing schedules for the disposition of records, along with disposition instructions for nonrecord materials. (NARA, “A Federal Records Management Glossary”).
Sensitive Data – Sensitive data are data that require protection due to the risk and magnitude of loss or harm that could result from inadvertent or deliberate disclosure, alteration, or destruction of the data. The term includes data whose improper use or disclosure could adversely affect the ability of an agency to accomplish its mission, proprietary data, records about individuals requiring protection under the Privacy Act, and data not releasable under the Freedom of Information Act.
Staff Division (STAFFDIV): Sub-components of the Office of the Secretary Operating Division (OS OPDIV).
Vital Records - Mission area, OPDIV/STAFFDIV and offices shall maintain a program for the selection, protection, and reporting of vital records, in accordance with the provisions of 36 CFR 1236. There are two types of vital records:
a. Emergency Operating Records - Documents needed immediately, such as orders of succession.
b. Legal and Financial Rights Records - Documents essential to protect the legal and financial rights of the Government and of the individuals directly affected by its activities, such as social security records.
While your emergency operation records, should be identified managed in the Continuity of Operations Plan (COOP), Records Officers need to work with the COOP coordinators to be sure all of the records are protected. The location and access rights for the legal and financial rights records are to be included in the COOP.