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Frequently Asked Questions (FAQ) About Contact Lists Used for Email and Electronic Messaging Communications

August 29, 2024

 

1. What is the definition of contact lists in the context of this FAQ?

Generally, a contact list is just that – a list of contact entries that may include one or more of the following data elements: name, job title, email address, phone number, agency / company name, and / or physical mailing address.  

Contact lists are used to support communication functionality within systems and applications. They are usually affiliated with email and / or messaging functions and are either auto-populated, manually-populated, or both. 

Certain data from contact lists can also populate the metadata affiliated with email and electronic message records.

2. How are contact lists created and used?

NARA has identified two primary types of contact lists used by the federal government to facilitate email and electronic messaging communication:

Active Directories. Active directories, or their equivalent, are shared, centralized contact lists. They are created and managed centrally by the agency; individual users may not edit them. Active directories may be made up of records from other systems, such as human resources systems. Active directories also tend to act as identity management tools. They are usually limited to the contact information for staff of the owner agency.  

Individual User Contact Lists. Individual user contact lists, or their equivalent, are managed by individual account users. They likely exist for each individual email account, and may also exist on individual personal devices such as phones. Individual user contact lists can usually be auto-populated by the system or application, and manually populated or edited by the user. They may include contact information for agency staff, staff of other agencies, personal contacts, and / or individuals from private entities. 

3. Are active directories federal records and do they require NARA-approved disposition authority?

Yes. Active directories are federal records due to how they are created and used. They require NARA-approved disposition authority.  

Active directories are disposable under General Records Schedule (GRS) 3.2, item 30, System Access Records. They are not included in GRS 6.1, Email and Other Electronic Messages Managed Under a Capstone Approach.  

4. Are individual user contact lists federal records and do they require NARA-approved disposition authority?

No. Individual user contact lists are nonrecord and therefore do not require NARA-approved disposition authority. Individual user contact lists, as nonrecord, may be managed and disposed of according to agency policy. 

5. Does my agency need to include a copy of contact lists with our transfers of permanent email and electronic messages?

No. Copies of individual contact lists and active directories are not required to be included with any permanent transfers. NARA has concluded that the metadata associated with email and electronic messages is sufficient. Additional information on requirements for the transfer of permanent email and electronic messages to NARA may be found in the “Questions about Transfers” section of the FAQs for GRS 6.1. 

6. Can officials take copies of their individual user contact lists with them when they leave office, such as during a presidential transition?

Generally, yes. Approval is not required from NARA since these are nonrecord. Agencies should develop their own policies related to nonrecord material, including when it is appropriate to take copies upon separation from the agency. 

Agencies are encouraged to consider issues of sensitivity concerning certain contact entries (such as those for non-public facing employees) within these policies.  

More information on records management during a presidential transition and records of senior officials may be found here.  

7. What other NARA guidance is available related to email, electronic messages, and contact lists?

8. Whom may I contact with additional questions?

Questions about the GRS 6.1 may be referred to GRS_Team@nara.gov. Other questions about this FAQ may be referred to your agency’s assigned NARA Appraisal Archivist. 

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