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Current Situation

The Records Management Office (RMO) is currently working with IT Business Systems on the implementation of an electronic records management system.  Until such system is in place, transfer closed electronic records to a Google drive, or maintain in the source system.

At Berkeley Lab, records are being created and stored solely in electronic formats within electronic information and business systems as well as on drives and desktops.  Records generated, received, and maintained in an electronic format are not excluded from records management requirements.

Electronic records, generated through the use of computer-based applications, or captured through scanning or imaging, that have long-term retentions present a particularly unique challenge if the Laboratory is to remain in compliance with the Department of Energy’s records program.
 

Requirements

The Contractors Requirement Document of the DOE Records Management Order 243.1C   requires that Berkeley Lab manage electronic records accordingly: 

Electronic Records. Electronic record keeping (ERK) functionality must either be maintained or built into the system technical requirements management process for new or existing systems used to create or receive records. If such system functionality is not available within electronic information systems (EIS), records must be captured in a system that satisfies NARA’s Universal Electronic Records Management (UERM) Requirements. 

Records management controls must be present in EIS to ensure the reliability, authenticity, integrity, usability, content, and context of DOE records created or received in its business processes. Compliance with electronic records management requirements means the following is implemented at the soonest possible lifecycle refresh or into the baseline for a new system or service. 

Ensure records controls are maintained when using commercial or government cloud environments, managed services, or on-premise environments.  

Controls should be in place to monitor changes to third-party terms of service that may affect the management of the records. If the cloud services are changed or updated, the contractor must continue to meet its records management responsibilities by migrating the records to another system or repository. The system receiving the migrated records must have appropriate security and records management controls in place to manage the records throughout the entire lifecycle, including preventing the unauthorized access or disposal of records. 

Metadata for a record must, where possible, consist of a description of the content of the record; the structure of the record (form, format, and relationships between record components); the business context in which the record was created, relationships with other records and metadata, identifiers and other information needed to retrieve the record, and the business actions and events involving the record throughout its lifecycle.

Records systems must define metadata to enable the identification and retrieval of records; associate records with changing business rules, policies, and mandates; (e.g.; associate records with records owner, authorizations, and rights with regards to the records; associate records with their business activities; and track processes carried out on records).

The metadata for a record must be protected from unauthorized deletion and must be retained or destroyed in accordance with the record's appropriate authorized retention schedule. Once the record has been captured, the associated metadata must be fixed and kept as transactional evidence. Analog records that require digitization must follow NARA regulations for digitization, including metadata, which varies depending on either the permanent or temporary status of the record.  

When dispositioning permanent records, metadata must be preserved and included with the transfer. To protect records against technological obsolescence, regardless of the storage environment and media, the contractor must:  Determine if the NARA approved retention period for the records will be longer than the life of the system. If so, agencies must migrate the records and their associated metadata before retiring the current system. Ensure hardware and software can retain the electronic records’ functionality and integrity regardless of the storage environment. To retain functionality and integrity, the contractor must: 

  • Keep the records in a usable format until their authorized disposition date. If records must be converted for migration, records must be maintained and disposed of in the authorized manner after conversion; 
  • Ensure electronic forms are designed using software for screen fillable data entry, utilize digital signatures, and promote fully digital workflows;
  • Plan for technology obsolesce, and ensure updated hardware and software remains compatible with current data formats as necessary and data is preserved as a federal record until disposition requirements are met;  
  • Maintain a link between records and associated metadata when converting or migrating. This includes capturing relevant associated metadata at the point of migration (for both the records and the migration process);  
  • Ensure verification of successful records transfers (including metadata) after migration. Access rights and permission rules for electronic records should be based on the activity or business function related to the records. 

Information Systems

The creators and maintainers of records need to ensure that Laboratory electronic records are managed throughout their life cycle in accordance with approved records schedules. Records management should be considered when planning for the acquisition of a new system or a significant upgrade to an existing system:

    • Identify information systems that contain or provide access to Laboratory records.
    • When planning for a new information system or an upgrade to an existing system, determine whether the system will contain or provide access to Laboratory records.
    • Contact the Records Management Office (RRO) to determine the correct records retention schedule which establishes how long the records must be kept.
    • The information systems owner(s), in consultation with Berkeley Lab IT's Business Systems Department, should develop a schedule to migrate records to new hardware, software, or other media to ensure that records will be accessible, retrievable, readable, and preserved throughout their retention period. 
    • The following are some factors to consider when developing a migration plan and schedule:
      • The frequency with which the records will need to be accessed. 
      • The media on which the records will be stored; the hardware software, and/or equipment that will be required to access the records; and the cost-effectiveness of continuously upgrading them.
      • Transferring records to a platform-independent, non-proprietary format, as a cost-effective alternative to continuously upgrading system hardware and software.
      • The volume of records that may be generated over the life of the system, and their required retention period and how these factors will affect the cost-effectiveness of the various options for migrating them.
      • The frequency with which records will need to be migrated to ensure their preservation.
      • How migrated record information will be authenticated to ensure that the information does not change and that the original records are not altered.
      • Implement the migration plan and update as appropriate in response to changes in technology and other factors.
         

Local Repositories

There are steps that the individual employee can take to help better protect records created and maintained in local repositories (such as workstation desktop filing systems or network servers):

    • Declare a record
      • When electronic documents (Microsoft Word files, spreadsheets, Microsoft PowerPoint slides, database reports) are finalized, submitted, used in a transaction, or otherwise meet the definition of a record, employees need to identify that document as a record.
         
    • Save records to Google drives
      • Save electronic records with standardized titles that are meaningful and use corporate language and business terminology. 
      • Include details such as the author and subject of the document, version number, date, type of document, etc. 
      • Create folders on the Google drive and file associated documents.
         
    • Retention and preservation
      • Retention must be in compliance with the Department of Energy and National Archives records retention schedules in effect at LBNL (contact RMO for guidance).
      • Ensure that the records are maintained as long as the records schedule(s) require.



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