What is an "electronic information system"?

The National Archives and Records Administration (NARA) defines an electronic information system (EIS) as a system that contains and provides access to computerized federal records and other information. (36 CFR 1236.2) An EIS includes the inputs and outputs that are generated, as well as the master files. The system may contain budgetary, fiscal, social, economic, scii fentific, technical, or program related data and information, operated in support of Agency programs and management responsibilities.

A database, a structured collection of related data, is one of the most familiar types of EIS. FAA staff use a wide variety of databases, including simple databases to track administrative tasks or transactions and more complex databases with multiple subsystems that are also available to the public. In addition to databases, FAA has many other types of EIS, including but not limited to, data warehouses, data registries, geographic information systems, and data interchange systems.

My organization maintains an EIS. Is the EIS a record?

The EIS itself is not a record, but the information contained within it may be a record because it may contain and provide access to computerized federal records and other information.

How long do I have to maintain the information within an EIS?

An EIS must be covered by an approved records schedule. The records schedule mandates how long the information is retained and what happens to it when it is no longer needed by FAA. Many EIS are already scheduled; check with your Records Officer or Records Management Officer (RMO) for assistance.

What if the EIS is unscheduled?

NARA requires that federal agencies have NARA-approved records schedules for all records, including electronic information systems. If your EIS is unscheduled, contact your RMO for assistance.

When should an EIS be scheduled?

You should schedule the EIS as early in its lifecycle as possible because the retention and disposition requirements may affect the design of the EIS. You can begin the schedule development process when the EIS is in the system design phase.

Do I need to print the information in the EIS to maintain the record copy?

No. Generally, the information contained within an EIS loses its context when removed from the EIS. However, you may have printouts from the EIS that support specific projects or activities. In those cases, the printouts should be maintained with the related records.

I maintain a database that is only for internal use to track projects. Does it need a separate schedule?

It's likely that the database is covered by an existing records schedule. Contact your Records Officer if you thing that the EIS needs to be added.

The EIS we maintain is being replaced by a new system. Should I use the records schedule covering the old system for the new system?

If you are discontinuing or replacing an EIS that is already scheduled, the schedule may need to be updated or a new one created. Contact your RMO for assistance.

The schedules for EIS have several disposition items. What is covered by each item?

Typically, each EIS schedule includes five disposition items. The standard items include:

  • Electronic software program – The database management system (DBMS), software programs, applications, and Web services that load, store, retrieve, display and manipulate the data.
  • Input – The source data that is either keyed into the database or electronically transferred into the EIS.
  • Electronic data – The data or content that resides in the EIS.
  • Output and reports – Electronic output that is transferred out of the system or printed reports.
  • System (or supporting) documentation – Information documenting how the system captures, stores, manipulates, and outputs the data.

There may be additional disposition items, depending on the EIS. For example, there may be other components requiring different retentions, such as electronic signatures.

My organization uses an EIS maintained by another organization. Do I need to be concerned about a schedule for the EIS?

The organization that maintains or sponsors the EIS is responsible for ensuring that it, and the electronic data within it, are scheduled and maintained as required.

However, it is possible that your organization has records that are used as input or output; in those cases, follow the disposition instructions for the related records. For example, if you are responsible for entering permit information into a permit tracking database, the records used for the input are covered by one of the permit schedules.

The schedule covering our EIS says to transfer the "electronic data" and "supporting documentation" to the National Archives. How do I do that?

Work with your RMO, IT staff and the National Archives to determine what method of transfer is acceptable and transfer a copy. The records schedule generally specifies when and/or how often the transfer needs to be done (e.g., annually, at each major version change). See Preparing Electronic Records for Transfer to the National Archives for assistance.

The transfer process seems unduly burdensome. Do we have to do it?

Yes, NARA regulations (36 CFR 1226.22) require that all permanent records, including EIS, be transferred to the National Archives as specified in the approved records schedule. Unauthorized deletion, removal or loss of records can result in criminal penalties (18 U.S.C. § 2071).

What do I do if I discover an EIS has been removed or destroyed without authorization?

You must report any unauthorized removal or destruction of records to the Agency Records Officer (RO), who will notify the Archivist of the United States (36 CFR § 1230.14). Your report to the RO must include:

  • A complete description of the records;
  • The volume of the records;
  • The office of origin;
  • An explanation of the circumstances involving the unauthorized destruction;
  • A description of actions taken to salvage, retrieve or reconstruct the records; and,
  • A statement of safeguards taken to prevent future losses.
My organization is designing a new EIS. What records management issues do we need to consider?

OMB Circular A-130, par. 8a(1)(k), requires agencies to incorporate records management and archival functions into the design, development, and implementation of information systems. Also, NARA regulations (36 CFR 1236.6) require agencies to establish procedures for addressing records management requirements, including recordkeeping and disposition requirements, for new systems or enhancements to existing systems. As an on-going requirement, system managers should work with their information management officer (IMO) and RMO to ensure records management requirements are included throughout the system’s lifecycle.

Where can I get additional guidance?

If you have questions about records, contact your program office, region, or center RLO.