OMB’s Records Management Policy

1. Purpose
2. Scope and Accountability
3. Background
4. Policy
5. Roles and Responsibilities
6. Waiver Process
    

1. PURPOSE
   
   The Records Management Policy establishes principles, responsibilities, and requirements for managing records to ensure that the Agency is in compliance with Federal laws and regulations, policies, and best practices for managing records. This Agency-wide policy provides the framework for specific guidance and detailed operating procedures governing records management organization and implementation.
    
2. SCOPE AND APPLICABILITY
   
   This Policy addresses all records made or received by OMB under Federal law or in connection with the transaction of public business, and preserved or appropriate for preservation as evidence of OMB functions, organization, and activities or because of the value of the information they contain.
    
3. BACKGROUND
   
   The Federal Records Act of 1950, as amended, requires all Federal agencies to make and preserve records containing adequate and proper documentation of their organization, function, policies, decisions, procedures, and essential transactions. These records are public property and must be managed according to applicable laws and regulations.
   
   The Federal Records Act also requires agencies to establish a records management program, defined as a planned, coordinated set of policies, procedures, and activities needed to manage its recorded information. Essential elements include issuing up-to-date records management directives, properly training those responsible for implementation, and carefully evaluating the results to ensure adequacy, effectiveness, and efficiency.
   
   Records serve a number of purposes including: administrative and program planning needs, evidence of OMB activities, protection of legal and financial rights, oversight by Congress and other authorized agencies, documentation of the Agency's history, and the continuation of key functions and activities in the event of an emergency or disaster. Records serve as the Agency's memory; they are of critical importance in ensuring that the organization continues to function effectively and efficiently.
    
4. POLICY
   
   This Policy establishes specific requirements under which OMB records are effectively and efficiently managed throughout their lifecycle to facilitate the accomplishment of OMB's programmatic and administrative missions, to preserve official OMB records in accordance with applicable statutory and regulatory requirements, and to promote access to information by OMB staff, OMB partners, and the public, as appropriate.
   
   Each office within OMB is required to establish and maintain a records management program with the following minimum requirements:
   • Create, receive, and maintain official records providing adequate and proper documentation and evidence of OMB's activities.
      
   • Manage records, in any format, in accordance with applicable statutes, regulations, and OMB policy and guidance.
      
   • Maintain electronic records, including electronic mail records, in the enterprise-wide electronic content management system, when available, and migrate legacy systems, when feasible.
      
   • Print and file records in a paper recordkeeping file system when an enterprise-wide electronic content management system is not available.
      
   • Maintain records according to the Agency-wide file structure allowing for timely access and retrieval.
      
   • Secure records to protect the legal and financial rights of the government and persons affected by government activities.
      
   • Implement a plan to protect vital records and assess damage to and the recovery of any records affected by an emergency or disaster.
      
   • Ensure instructions for disposition of records as specified in the approved records schedules.
      
5. ROLES AND RESPONSIBILITIES
   
   The Agency Records Officer is responsible for:
   • Leading and managing the Agency-wide national records management program.
      
   • Ensuring Agency senior officials are aware of their programmatic and individual records management responsibilities.
      
   • Advising OMB on records management issues and developing Agency-wide records management policies, procedures, guidance, and training materials.
      
   • Coordinating the approval of the Agency's records schedules and the transfer of records to the National Archives.
      
   • Promulgate and communicate Agency-wide policies and guidance that reflect records management missions and goals and incorporate Federal requirements.
      
   • Designate other records management staff as required by regulations.
      
   • Assign overall responsibility for the records management aspects of centrally provided information technology infrastructure, including local area network applications.
      
   • Conduct periodic evaluations of records management programs within OMB as part of the Agency’s review and oversight program.
      
   • Coordinating records management issues with other Federal agencies, including Federal oversight agencies such as the Office of Management and Budget (OMB), the Office of Administration (OA), National Archives and Records Administration (NARA), , and the General Services Administration (GSA).
      
   • Providing technical advice and training to all Agency organizations on establishing and maintaining effective records management programs.
      
   • Evaluating recordkeeping practices to determine the effectiveness of the program.
      
   • Drafting and updating records schedules for records created and maintained by the organization.
      
   • Implementing approved records schedules to ensure that records are not destroyed without proper authorization.
      
   • Reviewing file plans and procedures at least every three years to ensure they are current and updating them as necessary.
      
   • Assisting in planning and implementing information management technology and reviewing the purchase of records management equipment and services to ensure they conform to Federal statutory and regulatory requirements.
   
   The Records Liaison Officers (RLO’s) are responsible for creating and preserving records that adequately and properly document the organization, functions, policies, decisions, procedures, and essential transactions of OMB. In addition, the RLO’s are responsible for:
    
   • Creating and updating procedures for their offices in accordance with established OMB and program policies.
      
   • Performing evaluations of their records management and vital records program.
      
   • Developing file plans and procedures so records are organized and can be found when needed.
      
   • Assisting with disposition activities, including retirement of inactive records, transfer of permanent records to the National Archives, and destruction in accordance with approved records schedules.
      
   • Reviewing office records schedules annually to ensure they are current, and initiate changes if not.
      
   • Ensuring confidential records are protected in accordance with Federal and OMB requirements, and keeping access lists to ensure sensitive information is released only to authorized individuals.
      
   • Coordinating the identification and maintenance of vital records and submitting an annual list of vital records through senior management to the Agency Records Officer.
      
   • Initiating and keeping records retirement, transfer, and destruction documentation.
      
   • Conducting briefings and training sessions on the records management program.
      
   • Reviewing and recommending requests for records equipment, services, and supplies.
      
   • Providing records management briefings for all managers and training to staff within their organizations.
   
   Each OMB Division is responsible for:
    
   • Designating a Records Liaison Officer (RLO) accountable to the Records Officer or other official designated to oversee the program.
      
   • Ensuring the RLO has adequate skills, resources, time, and appropriate authority to perform the job.
      
   • Implementing a records management program within their area of responsibility to accomplish the objectives identified in Federal regulations and OMB policies and procedures. Minimum program components include responsibilities for:
     • Evaluating the value of records within their span of responsibility to serve as a basis for assigning records retention and disposition instructions, determining which records within their physical or legal custody are vital, and implementing the most responsive and cost-effective means for managing records.
        
     • Implementing a vital records plan to ensure the continuation of key functions and activities in the event of an emergency or disaster.
        
     • Providing oversight for contractors, grantees, or other non- OMB employees managing official OMB records.
        
     • Ensuring records and other types of required documentary materials are not unlawfully removed from OMB by current or departing officials, employees, or agents.
   
   The OMB General Counsel’s Office is responsible for:
    
   • Assisting the Divisions in determining what records are needed to provide adequate and proper documentation of OMB activities and in specifying appropriate disposition for OMB records.
      
   • Assisting in determining the retention of Agency records that may be needed for internal investigation and audit purposes.
   
   The OMB Records Officer and IT Program Manager are responsible for:
    
   • Working with the RLO’s and NARA to establish and update records schedules for electronic systems.
      
   • Implementing proper recordkeeping procedures for existing information systems and ensuring recordkeeping requirements are included in proposed systems.
      
   • Ensuring that information systems intended to carry out electronic records management comply with NARA's and OMB's requirements for electronic recordkeeping systems.
      
   • Maintaining electronic information systems in accordance with approved records schedules and NARA requirements.
      
   • Working with the RLO’s to transfer permanent systems to the National Archives in accordance with approved records schedules and NARA requirements.
      
   • Ensuring that Internet and intranet postings containing official records are maintained in accordance with OMB's recordkeeping requirements.
   
   Continuity of Operations (COOP) Program planners are responsible for:
    
   • Working with records management staff to implement the vital records plan to ensure the continuation of designated COOP essential functions.
      
   • Ensuring that vital records are accessible from designated COOP locations.
   
   All OMB employees are responsible for:
    
   • Creating and managing the records necessary to document the Agency's official activities and actions, including those records generated by OMB contractors and grantees, in accordance with OMB recordkeeping requirements.
      
   • Destroying records only in accordance with approved records schedules and never removing records from OMB without authorization.
      
   • Filing records for safe storage and efficient retrieval and maintaining personal papers and non-record materials from official OMB records.
      
6. WAIVER PROCESS
   
   The Agency Records Officer in consultation with the OMB General Counsel, may grant waivers to any provisions of this Policy for sufficient cause.
   
   Applications for waivers to specific provisions should contain (1) identification of the Policy provision; (2) a listing of reasons why the Policy cannot be applied or maintained; (3) an assessment of impacts resulting from non-compliance; and (4) the signature of the General Counsel.
   
   The Agency Records Officer will notify the requesting office in writing of the disposition of the decision on the waiver request within 60 days of receipt of the request.

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