November 26, 2022

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Information Management: Selected Agencies Need to Fully Address Federal Electronic Recordkeeping Requirements

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<div>What GAO Found Seventeen agencies GAO selected for review varied in the extent to which their policies and procedures addressed the electronic recordkeeping requirements in the Managing Government Records Directive and the Federal Records Act ( FRA ) and its amendments. More specifically, 14 of the 17 agencies established records management programs, while three agencies did not. Of those 14 agencies with established records management programs, almost all addressed requirements related to incorporating electronic records into their existing programs, but many did not have policies and procedures to fully incorporate recordkeeping functionalities into electronic systems, establish controls and preservation considerations for systems, and issue instructions on email requirements (see table). Assessment of Selected Agencies' Policies and Procedures Addressing Key Electronic Records Requirements NARA provided guidance and assistance to the selected agencies, including guidance on electronic records management and training. All of the agencies stated that the assistance was generally helpful and that they relied on it to some extent for implementing the key requirements discussed in this report. Further, NARA oversaw the selected agencies' implementation of federal records management regulations through their self-assessment progam. However, NARA had not ensured that the selected small or micro agencies that self-assessed to be at high risk of improper records management in calendar year 2017 were taking appropriate actions to make improvements to their records management programs. NARA officials stated they conduct follow-up with the agencies that report poor scores, but they do not proactively require the agencies to address their weaknesses. Until NARA requires these agencies to develop plans to make necessary improvements, these agencies will likely miss important opportunities to improve their record management practices. Why GAO Did This Study The Federal Records Act , a subsequent directive, and NARA regulations establish requirements for agencies to ensure the transparency, efficiency, and accountability of federal records, including those in electronic form. In addition, NARA plays an important role in overseeing and assisting agencies' records management efforts. GAO was asked to evaluate federal agencies' implementation of the aforementioned requirements related to electronic records. The objectives were to determine the extent to which (1) selected agencies' policies and procedures address the electronic recordkeeping requirements in the Managing Government Records Directive and the Presidential and FRA Amendments of 2014 and (2) NARA assisted selected agencies in managing their electronic records. To do so, GAO selected 17 agencies and reviewed their records management policies and procedures. GAO also reviewed laws and requirements pertaining to NARA's roles and responsibilities for assisting agencies in managing their electronic records. Further, GAO analyzed NARA guidance and other documents that discussed NARA's efforts in carrying out these responsibilities.</div>
Office of the Archivist The Archivist of the United States should require small and micro agencies that were determined to be at high risk of not complying with statutory and regulatory records management requirements to develop plans and timelines to address their records management weaknesses (Recommendation 1)

Open

The National Archives and Records Administration concurred with this recommendation. As of May 2021, we had not received information pertaining to planned actions for this recommendation. Once the agency states that it has taken action, we plan to verify whether implementation has occurred.

Office of the Archivist The Archivist of the United States should monitor the agencies’ progress towards these efforts on a regular basis. (Recommendation 2)

Open

The National Archives and Records Administration concurred with this recommendation. As of May 2021, we had not received information pertaining to planned actions for this recommendation. Once the agency states that it has taken action, we plan to verify whether implementation has occurred.

Armed Forces Retirement Home The Chief Executive Officer of the Armed Forces Retirement Home should establish a time frame to develop an inventory of electronic information systems used to store agency records that includes all of the required elements. (Recommendation 3)

Open

The Armed Forces Retirement Home did not state whether or not it concurred with this recommendation. As of May 2021, we had not received information pertaining to planned actions for this recommendation. Once the agency states that it has taken action, we plan to verify whether implementation has occurred.

Armed Forces Retirement Home The Chief Executive Officer of the Armed Forces Retirement Home establish a time frame to update its policies and procedures to include all of the required electronic information system functionalities for recordkeeping systems. (Recommendation 4)

Open

The Armed Forces Retirement Home did not state whether or not it concurred with this recommendation. As of May 2021, we had not received information pertaining to planned actions for this recommendation. Once the agency states that it has taken action, we plan to verify whether implementation has occurred.

Armed Forces Retirement Home The Chief Executive Officer of the Armed Forces Retirement Home should establish a time frame to update the agency’s policies and procedures to include the (1) following records management controls required for electronic information systems: usability, content, context, and structure and (2) required preservation mechanisms to ensure that records in its electronic recordkeeping system will be retrievable and useable. (Recommendation 5)

Open

The Armed Forces Retirement Home did not state whether or not it concurred with this recommendation. As of May 2021, we had not received information pertaining to planned actions for this recommendation. Once the agency states that it has taken action, we plan to verify whether implementation has occurred.

Armed Forces Retirement Home The Chief Executive Officer of the Armed Forces Retirement Home should ensure existing policies and procedures describe the rules for using personal email accounts when conducting official agency business to include instructing the employee to (1) copy an official electronic messaging account of the employee in the original creation or transmission of the records and (2) forward a complete copy of the record to an official electronic messaging account of the employee no later than 20 days after the original creation or transmission of the record. (Recommendation 6)

Open

The Armed Forces Retirement Home did not state whether or not it concurred with this recommendation. As of May 2021, we had not received information pertaining to planned actions for this recommendation. Once the agency states that it has taken action, we plan to verify whether implementation has occurred.

Office of the Secretary The Secretary of Commerce should establish a time frame to ensure all records schedules are up-to-date and submitted to NARA. The schedules should include all required information, including when eligible temporary records must be destroyed or deleted and when permanent records are to be transferred to NARA. (Recommendation 7)

Closed – Implemented

In response to our recommendation, in May 2021, we reviewed evidence showing Commerce’s newly established timeframes to ensure all records schedules are up-to-date and submitted to NARA by December 2022. By establishing a time frame to submit all records schedules to NARA, Commerce decreases the risk of maintaining records that are no longer relevant or needed.

Office of the Secretary The Secretary of Commerce should ensure the electronic system that manages email provides the capabilities to manage permanent and temporary email records and to identify, retrieve, and retain records. (Recommendation 8)

Closed – Implemented

In response to our recommendation, in May 2021, Commerce provided evidence that it now uses an email solution to manage its permanent and temporary email records that meet NARA’s requirements. Commerce stated that through the collaboration of the new Records Manager and email operations team, the department will continue to ensure that their email solution meets NARA’s requirements of having the capability to identify, retrieve, and retain records. By taking these actions, Commerce is decreasing its risk that its emails are not able to be preserved or accessed when needed.

Consumer Financial Protection Bureau The Director of the Consumer Financial Protection Bureau should establish a time frame to develop an inventory of electronic information systems used to store agency records that includes all of the required elements. (Recommendation 9)

Open

The Consumer Financial Protection Bureau concurred with this recommendation. As of May 2021, we had not received information pertaining to planned actions for this recommendation. Once the bureau states that it has taken action, we plan to verify whether implementation has occurred.

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