Ensuring adequacy of documentation in any information system depends on the clear articulation of recordkeeping requirements. Recordkeeping requirements:
- Specify the creation and maintenance of specific records to document Agency operations and activities.
- Facilitate action by Agency officials and their successors.
- Permit continuity and consistency in agency.
- Make possible a proper scrutiny by Congress and other duly authorized agencies.
- Protect the rights of the Government and those affected by its actions.
- Document important meetings and the formulation and implementation of basic policy and decisions.
A. Creation of records and adequacy of documentation
Questions to ask are:
- Has the program or office provided guidance for all employees on the definition of Federal records and nonrecord materials, including those created using office automation, and guidance on the ways in which the records must be managed?
- Does each program or office have written guidance on what records, including electronic records, are to be created and maintained and the format of the official copy?
- Has the program or office issued guidance and instructions for documenting policies and decisions, especially those arrived at orally?
- Has the program or office issued guidance on the record status of working papers/files and drafts?
- Has the program or office issued guidance on personal papers?
- Do program or office procedures require creation of finding aids such as captions and indexes to facilitate access to individual files or record items, when appropriate?
B. Contractor records
Questions to ask are:
- Do contracts identify which contractor-created records are Federal records?
- Does the program provide contractors with the regulations and procedures governing Federal records?
- Particularly when electronic records are involved, do contracts specify the delivery of background data that may have further value to the Agency in addition to the final product?
- Do contracts involving development of electronic systems specify the delivery of systems documentation to the Agency along with the final product?
- Particularly when electronic records are involved, do contracts specify the delivery of final products and background data in a format that is compatible with program records maintenance and retention guidelines?
- Are deferred ordering and delivery of data clauses included in contracts when it is impractical to identify in advance all electronic data that should be delivered to the Government?