Records Management Editing and Proofreading Services

Copies are not spare. Under 36 CFR 1222.12(d), the record status of a document "does not depend upon whether it contains unique information."¹ Multiple copies of one document "may each have record status depending on how they are used in conducting agency business."¹ The federal definition excludes "duplicate copies of records preserved only for convenience," which is a narrower exclusion than it first appears.² The regulation makes status turn on how a copy is used in conducting agency business rather than on what it contains.¹

Two conditions, and a draft has to meet both

Working files are the case where the rule is explicit. Section 1222.12(c) provides that preliminary drafts, rough notes, and similar materials are records that must be maintained "to ensure adequate and proper documentation" on two conditions.¹ The first is that they were "circulated or made available to employees, other than the creator, for official purposes."¹ The second is joined to the first by the word and. They must also "contain unique information, such as substantive annotations or comments that adds to a proper understanding of the agency's formulation and execution of basic policies, decisions, actions, or responsibilities."¹

A draft that went to three colleagues and came back unmarked meets one condition. A draft covered in comments that never left the author's own directory meets the other. The rule is written so that neither is enough on its own, and a filing decision made on circulation alone reads only half of it.

The statutory definition turns on verbs

The definition in 44 U.S.C. 3301 is built from words the regulations then gloss one by one. Records are recorded information "made or received" by an agency "under Federal law or in connection with the transaction of public business" and "preserved or appropriate for preservation."² Section 1220.18 defines documentary materials as recorded information "regardless of the medium or the method or circumstances of recording."³ It defines personal files as materials belonging to an individual "that are not used to conduct agency business."³

Section 1222.10(b) then glosses the operative words. Made is "the act of creating and recording information by agency personnel in the course of their official duties, regardless of the method(s) or the medium involved."⁴ Received is "the acceptance or collection of documentary materials by or on behalf of an agency or agency personnel in the course of their official duties regardless of their origin."⁴ Preserved is "the filing, storing, or any other method of systematically maintaining documentary materials in any medium by the agency."⁴

What has to travel with a message

Electronic mail carries a preservation requirement that is easy to lose in migration. Section 1236.22(a)(1) requires that "the names of sender and all addressee(s) and date the message was sent must be preserved for each electronic mail record."⁵ The stated reason is "in order for the context of the message to be understood."⁵ The same paragraph adds that an agency "may determine that other metadata is needed to meet agency business needs."⁵ Attachments that are an integral part of the record are preserved as part of it, or "linked to the electronic mail record with other related records."⁵ Where a system identifies users by codes or nicknames, or identifies addressees only by the name of a distribution list, the agency retains "the intelligent or full names on directories or distributions lists."⁵

The same section returns to drafts, and sends them somewhere else. Draft documents "that are circulated on electronic mail systems may be records if they meet the criteria specified in 36 CFR 1222.10(b)."⁵ That is the general definitional gloss rather than the two-condition test in 1222.12(c), so a draft in an inbox is measured against the statutory words themselves.

Seven named controls, and one system that does not count

Section 1236.10 names seven controls: reliability, authenticity, integrity, usability, content, context, and structure.⁶ Agencies "must incorporate controls into the electronic information system or integrate them into a recordkeeping system that is external to the information system itself."⁶ Context is defined there as cross-references to related records "that show the organizational, functional, and operational circumstances about the record."⁶ Content is the mechanism preserving "the information contained within the record itself that was produced by the creator of the record."⁶

Section 1236.20(c) then rules one common arrangement out. System and file backup processes and media "do not provide the appropriate recordkeeping functionalities and must not be used as the agency electronic recordkeeping system."⁷ The provision is about the system of record rather than about how many copies exist.

The schedule is written by someone else

Agencies "must distinguish between records and nonrecord materials" by applying the statutory definition, and the Archivist's determination on that question binds them.¹² Which schedule then covers a record is settled the same way, inside the agency. Neither question is put to an editor, and we answer neither. What an editor can do is read a schedule item against the thing it claims to describe. One reading happens when the item is written. The series title goes with the description beneath it, and the retention instruction goes with the event or the period it is supposed to name.

Another reading happens years later, when a paper series has been replaced by an electronic system and the description written for the first is still attached to the second. A term in that description may by then mean something different in the office using it, and the shift shows on the page. Every document that reaches us is private.