Records Managers

NARA Bulletin 2009-02

June 18, 2009

TO: Heads of Federal agencies

SUBJECT: Guidance Concerning Managing Records in Multi-agency Environments

EXPIRATION DATE: June 30, 2012

  1. What is the purpose of this bulletin?

    This bulletin provides guidance on managing records produced when Federal agencies collaborate in multi-agency environments. When doing so, collaborating agencies create Federal records which must be managed according to the Federal Records Act, associated regulations, and the instructions below.

  2. What are multi-agency environments?

    Multi-agency environments are collaborative endeavors in which two or more Federal agencies share information to meet common goals. Multi-agency environments have common characteristics:

    • there is a common purpose for all participants,
    • the partners are aware of and purposely involved in the collaborative effort,
    • the partners are working together under an agreement, and
    • the partners have a common interest in the trustworthiness and disposition of the information.

    Examples of multi-agency environments demonstrating these characteristics could include:

    • five agencies develop a system to document restoration of a nature preserve,
    • three agencies with overlapping missions use the Internet to collaborate on policy development, and
    • two agencies establish a collection of shared case files on an emergency response to a natural disaster.

    However, an agency may collect information from other agencies for its own purposes. This practice would not establish a multi-agency environment, because there is no knowing collaboration or agreement among the information providers. An example is when a single agency collects data from a variety of sources for its own analysis.

  3. What technologies are being used to support multi-agency environments?

    Federal agencies are establishing these environments through a variety of technologies, such as:

    • databases that aggregate content from multiple agencies,
    • wikis that provide collaborative workspace for multiple agencies,
    • web portals that organize content from multiple agencies, and
    • case files with information collected from multiple agencies on related topics that are stored in one place, but may be accessible to some or all contributors.

  4. What information needs to be managed in multi-agency environments?

    E-mails, documents, and electronically stored information in a multi-agency environment (as defined in Item 2), that meet the definition of a Federal record must be managed in accordance with the Federal Records Act (44 U.S.C. 3301) and associated regulations. Records may include information brought into the multi-agency environment from non-Federal partners.

  5. Who is responsible for managing records in multi-agency environments?

    All participating agencies must ensure that provisions are made for proper management of records in multi-agency environments per 36 CFR 1224.10. The agencies must develop a consensus and strategy for complying with the regulations. This means that one or multiple Federal agencies may manage records within the multi-agency environment. This applies even when multi-agency environments include private organizations, state, local, Tribal, or foreign governments.

    Factors that may help determine which partner or partners can best coordinate the records management responsibilities include but are not limited to:

    • an agency has physical custody of the records (e.g., owns the electronic servers),
    • an agency has a predominant need for the records over that of the other partners,
    • an agency has a longer business use for the records than other agencies (if that is the case, the records must be scheduled using the longest retention period), and
    • an agency has been designated as the lead agency or Executive Agent by statute or other directive.

    In some cases the most effective approach may require coordinating a division of records management responsibilities among the participating agencies.

  6. What are the records management responsibilities in multi-agency environments?

    When establishing a multi-agency environment, the original participating agencies must ensure that records management requirements are integrated into the design, development, and implementation of the multi-agency environment, as follows:

    • identify records that need to be created and maintained,
    • create and preserve records that document the organization, functions, programs, policies, decisions, procedures, and essential transactions of the multi-agency environment. Such records include those necessary to protect the legal and financial rights of the government and of persons directly affected by the activities of the agencies,
    • provide for the disposition of records by creating new or applying existing NARA-approved records schedules that determine how long records need to be maintained, and
    • transfer permanent records to NARA.

    As new members join an existing multi-agency environment, participants may need to review these records management responsibilities.

  7. What are the agency responsibilities for records contributed to a multi-agency environment and also maintained separately by the agency?

    Agencies that contribute records to multi-agency environments must determine whether they need to maintain and use copies of the records separately from the multi-agency environment or from the partner or partners who have taken on records management responsibilities. If so, the agency must manage these records separately even though the records are also managed in the multi-agency environment.

  8. Who can I contact for further assistance?

    NARA's National Records Management Program can provide assistance. See "List of NARA Contacts for Your Agency" at http://www.archives.gov/records-mgmt/appraisal/.

ADRIENNE THOMAS
Acting Archivist of the United States

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