NARA Guidance on Managing Web Records Background

January 2005

NARA Guidance on Managing Web Records, Main Page

GENERAL BACKGROUND, RESPONSIBILITIES, AND REQUIREMENTS

Table of Contents

       Introduction

1. How are agencies currently using the web?
    
2. Who has records management responsibilities for agency websites?
    
3. What statutory and regulatory requirements apply to agency web operations?
    
4. What are Federal website-related records?
    
5. What website records must be managed?
    
6. Does managing agency websites as Federal records mean that I must keep all page changes for a long time?

Introduction

Web site operations are an integral part of agency programs. This guide provides an initial, high-level framework that you can use to manage both the content records on an agency website and the records documenting website operations. This guidance, which is based on statutory requirements, also provides principles that form a sound basis for agency website management operations. It will help you reach agency program objectives by relating good records management practices (e.g., maintaining trustworthy websites) and existing tools for meeting agency objectives (e.g., risk assessments).

While the examples in this guidance primarily discuss public Internet websites, the guidance is equally applicable to websites that may be on agency intranets, virtual private networks, and security-classified websites.

This guidance does not address unique issues relating to web portals that are managed by multiple agencies. For example, when agencies jointly sponsor websites, one party must claim ownership of records management responsibilities. Those unique web issues will be dealt with in subsequent guidance.

1.  How are agencies currently using the web?

Federal agencies are currently using the web in a variety of ways. Table 1 lists these various activities, in order of increasing complexity. This presentation is only an example and is not meant to be exhaustive or prescriptive about how agencies use the web.

Table 1.  Types of Federal Agency Web Site Operations

Web site maintained as a relatively stable repository for agency publications

• How used: Web site serves information that changes infrequently, such as electronic versions of printed agency publications.
• Change frequency: Updates add information that rarely is changed.

Web site maintained as a more fluid repository for agency publications and information

• How used: Web site serves information that changes frequently.
• Change frequency: Updates include revision, removal, and addition of information on an as-needed basis.

Web site as a limited communications tool

• How used: Web site allows minimal interaction with the agency, primarily by the public (e.g., end users can submit questions or comments via public mailboxes referenced by web pages).
• Change frequency: Pages may be relatively stable or fluid; messages sent via web mailbox generally are captured through the agency e-mail system and not as part of the website.

Web site as search or query-based access to agency information

• How used: Website is used as an application interface for agency services, including databases or forms used to submit requests for off-line services.
• Change frequency: Forms for displaying information may change infrequently, but databases that provide information posted to the forms updated continuously.

Web site as interface to multiple applications and information services

• How used: Web site is a significant tool delivering agency's major services online, on-demand, e.g.,
  • Conducting public, electronic town meetings
  • Using the website to solicit comments on proposed regulations.
     
• Change frequency: Information both supplied by the end-user and displayed on the websites is varied in nature and changes frequently.

In reality, websites serve multiple purposes, and most agencies conduct more than one of these activities. Web sites can be seen as an automated "customer service window" through which customers interact with a business on many issues. They can ask questions, get directions or information, make complaints, seek refunds, apply for jobs, order merchandise, or make payments. Each of these activities generate different records and must be analyzed to determine the appropriate level of management.

Records created from conducting program activities over websites have a variety of characteristics, depending on how the website is used. These characteristics influence the selection of an appropriate unit of analysis for a risk assessment (e.g., website in toto, specific program portions of website, etc.), as is discussed in MANAGING WEB RECORDS, section 2. Knowing the purpose, work processes, and type of content is basic to understanding how to manage the web site.

2.  Who has records management responsibilities for agency websites?

Responsibilities for managing Federal agency websites and related records are assigned to different offices and individuals within agencies, depending on how each agency is organized.

The head of the agency, who is responsible for protecting the integrity of agency programs and trustworthiness of agency information (see 44 U.S.C. Chapter 31) has statutory responsibility for the agency's records management program. The agency Records Officer is responsible for ensuring adequate management and control over agency records, including agency website-related records, and development of an overall records management program.

Other records management-related responsibilities for web records are diffused throughout the agency to the programs and functions that create web content and website operations records. Just as an agency's web presence requires a collaborative effort, so does managing the web records that are created. NARA believes agencies must take a team approach to implement this guidance effectively. NARA recommends that the team should include the individuals who have the following responsibilities relating to web content and website operations:

• Developing management procedures for agency website operations and the records that document those operations
• Ensuring that required web management and operations records are created and maintained
• Coordinating the overall presentation of an agency website
• Approving what program-related content material gets posted
• Contributing to the content pages that are posted on an agency's website
• Contractor provision of additional content creation, graphics design, editorial, technical, or other services supporting website development and operations
• Legal counsel advice on or review of potential legal issues (e.g., incorporation of copyrighted materials in website design or e-FOIA)

Agencies are assisted in these responsibilities by:

The National Archives and Records Administration (NARA), which is responsible for issuing policies and guidance to assist Federal agencies to comply with statutory and regulatory recordkeeping requirements related to web site operations; and

The Office of Management and Budget (OMB), which has responsibilities under 44 U.S.C. Chapter 35 for coordinating Federal information policy.

3.  What statutory and regulatory requirements apply to agency web operations?

The Federal Records Act applies to all agency records, including web records (see section 5). The E-Government Act of 2002 (Public Law 107-347), places a number of requirements relating to websites on OMB, NARA, and agencies. Agencies must comply with a variety of other statutes and regulations for their agency website operations, most of which are described in the Federal Web Content Manager's Toolkit. Also, NARA has issued guidance for transferring permanent web content records to the National Archives.

4.  What are Federal website-related records?

Most Federal agencies use web-based technologies to assist in carrying out their mission. They may simply disseminate information also available in other forms or conduct business (e.g., e-Government initiatives). Agencies must document all of their agency programs (44 U.S.C. 3101), including websites, that are part of its overall public message.

Website-related records include (1) web content records, which represent information presented on a website, and (2) website administrative records, which provide evidence of the management and operations of the website.

Federal personnel, contractors, and partners supporting Federal web operations should understand that agency web content may meet the definition of a Federal record ¹   therefore must be managed as such. Records relating to managing websites, tracking use (metrics), file posting, and documenting decisions about web content and design are also Federal records.

Federal websites are part of an agency's approach in serving the public. The agency determines, in accordance with 44 U.S.C. 3103, what records must be created and maintained to provide "adequate and proper documentation of the organization, functions, policies, decisions, procedures, and essential transactions of the agency and designed to furnish the information necessary to protect the legal and financial rights of the Government and of persons directly affected by the agency's activities." It is NARA's view that much, if not all, documentation related to agency website operations should be managed as Federal records. As such, they must be scheduled and can only be deleted with a NARA-approved disposition authority.

5.  What website records must be managed?

You must manage those web site related records that result from agency web operations, including those that are needed to ensure trustworthiness for each site and those needed to document agency programs. Use the concepts of reliability, authenticity, integrity, and usability, as discussed in MANAGING WEB RECORDS, section 1.1, to establish criteria for identifying the website records needed to document agency programs. To help you identify the types of web site related records your agency may have, the following list suggests potential series of records that might result from agency website operations. These web site related records may exist in electronic or non-electronic format. NARA does not expect that your agency will produce all of these types of records, and you may have other types of records not on the list. This list also is not intended to instruct agencies about composition or management of their websites.

• HTML-encoded pages: The content pages composing an agency website, inclusive of the HTML markup.
• Records generated interactively on the website: Records that are created dynamically in real-time when a user interacts with an agency website (e.g., on-the-fly, text-based page creation, forms filled out online, etc.).
• Additional content files referenced within HTML-encoded pages: Files having the ability to "self-execute" (e.g., CGI scripts, Java/ActiveX applets, customized programs that generate online sound or moving images) as well as files that are static (e.g., these include graphic files, multi-national character sets, etc.). Both self-executing and static pages are external to the HTML-encoded content pages but referenced in the HTML syntax.
• Comprehensive list of URLs referenced by a website's hyperlinks: In effect, a bibliography of all uniform resource locators referenced via hyperlinks embedded within a website's content pages, along with a textual reference describing the destination of the hyperlink.
• Web site design records: Records such as graphic design layouts for pages or embedded image maps, and/or minutes of meetings documenting the production of such.
• Copyrighted web content and records documenting the use of such content materials: Many Federal websites incorporate copyrighted content (e.g., works for hire such as custom-produced graphics files) in individual web pages. Additional records may be deemed necessary for documenting the appropriate use.
• Web site program operations records: Program management files that document policies and procedures for agency website operations, including those that
   
  • Provide detailed procedures for documenting how records are selected, created, and approved for web posting, and how they will be revised or removed
  • Specify what records will be created and how they will be created for interactive sections of websites
  • Document procedures used in the operation of the site
  • Specify the relationship of the webmaster and other staff involved in preparing and posting web documents to program officials and the agency records officer
  • Demonstrate the development of policies and procedures to ensure Section 508 compliance
  • Otherwise, explain or illustrate site development and management procedures
• Web site system software-related records: Records related to the application software used in conjunction with the operation of the website. These include
   
  • Records produced in the analysis and selection of any commercial off-the-shelf (COTS) software
  • Records describing customization of COTS web-related software
  • Documentation relating to COTS web-related software
• Web site logs and statistical compilations: Records including raw data or summary logs of user access (frequency of "hits"), site posting logs (indicating when pages were posted, updated, or removed from the site), system load and search result statistics, and ad hoc reports containing such.
• Web site map: A linked, graphic, or text-based display of a website's hierarchy, similar to an organization chart.
• COTS software configuration files: Files used to operate the website and establish its look and feel including server environment configuration specifications.

6.  Does managing agency websites as Federal records mean that I must keep all pages and their changes for a long time?

No. As MANAGING WEB RECORDS and SCHEDULING WEB RECORDS discuss in greater detail, your agency business needs, including the risks to the agency programs and mission should the information not be available, are the major factors in determining how long you need to keep those pages. Your website schedule specifies the length of time you need to keep pages.

¹  i.e., they constitute "machine-readable materials, . . . made . . . by an agency of the United States Government . . . in connection with the transaction of public business . . . ( 44 U.S.C. 3301 )."