Electronic Record Management Policy
December 26, 2014
Policy Review Date:
Research Foundation President
Joshua B. Toas, Chief Compliance Officer
This document provides The Research Foundation for SUNY (RF) policy for electronic record (e-record) management. It provides the background of the federal government authorization and RF approval for use of e-records, defines an e-record, provides the requirements for management of e-records to ensure compliance with the policy, and identifies the sources of reference.
Federal Government Authorization
The federal government provides grantees with the authorization to use e-records and alternate storage mediums according to:
- Office of Management and Budget CFR Part 200: �200.335 for collection, transmission and storage of information.
- Code of Federal Regulations: National Archives and Records Administration, 36 CFR 3, Part 1234, Subparts A and B, Electronic Records Management;
and the Federal Acquisition Regulations, 49 CFR 1, Part 4, Subpart 4.7, Contractor Records Retention.
- Department of Health and Human Services (DHHS) Office of Grants and Acquisition Management (OGAM) Action Transmittal, Use of Electronically
Imaged Record Storage, Transmittal No. OGAM AT99-1, August 9, 1999: "The purposes are to establish the authorization to substitute electronically
imaged records for originals and to encourage grant recipients to do so." Grantees under DHHS cognizance can implement use of e-records in
substitution for original records upon developing a policy/procedure in accordance with the Action Transmittal, and notifying and receiving approval from
RF Approval by DHHS
- On June 15, 1998, RF developed and submitted a draft document titled, Electronic Records Guidelines, to DHHS for approval - using OMB Circular A-110
and the Code of Federal Regulations as the basis for the request.
- On October 27, 1998, RF received approval from James E. Cook, Jr., Director, Office eof Audit Resolution and Cost Policy, DHHS, OGAM. The approval
letter includes the following statements: "Based upon our desk review, the Foundation's guidelines for the management of electronic records appear to
establish adequate guidance for addressing records management requirements, including recordkeeping requirement and disposition, with an electronic
information system." "The draft procedures and guidelines are to be used by each operating location that chooses to use and maintain electronic
records in establishing its electronic records system."
E-Record Versus Text Record
The definition of an e-record as compared to a text document is:
- An e-record is defined as information that is recorded in a form that only a computer can process. E-records include numeric, graphic, and text
information that may be recorded on any medium capable of being read by a computer. The mediums for recording e-records include magnetic media
(e.g., tape, disk), CD-ROM, microfilm (e.g., microfiche, film chips, microprints, roll film), and optical disk.
- A text document is defined as narrative or tabular documents (e.g., letters, memos, reports) in loosely prescribed form and format.
Operating locations that choose to use and maintain e-records must establish procedures that provide for the:
- creation and use of e-records
- security of e-records
- selection and maintenance of alternate storage mediums
- retention, disposition, and destruction, of e-records
Creation and Use of E-Record
Operating locations that maintain the office of record copy of documents must establish a procedure to implement the use of e-records in substitution for original records. The procedures must ensure the:
- process maintains the integrity of the original records, is reliable and secure, and that authenticity can be validated.
- image process preserves accurate images of original records - including signatures, worksheets, relevant notes, and other papers necessary to
reconstruct and understand the original record.
- index system provides secure, on-time, and convenient access and retrieval of imaged records (e.g., each document should be identified sufficiently to
enable authorized personnel to retrieve, protect, and carry out disposition of the document in the system.)
- retention of original records for a minimum of one year after imaging to permit periodic validation of the imaging system.
- transfer and disposition of e-records maintain the integrity, reliability, and security of the original/e-records, and to retain a description of the transfer for
Security of E-Records
Operating locations must establish an effective e-records security procedure to:
- ensure that only appropriate, authorized personnel have access to e-records.
- provide for the backup and recovery of e-records as protection against information loss.
- ensure that appropriate, authorized personnel are trained to protect sensitive, proprietary, or classified e-records.
- minimize the risk of unauthorized alteration or erasure of e-records.
- document that similar kinds of electronic generated/stored records were created by the same processes each time, and have a standard method for
- prevent the unauthorized change of an e-record and ensure protection against system problems (e.g., power interruptions).
- identify the electronic medium for e-record storage throughout the lifecycle, and the maximum time that e-records remain on each storage medium.
Selection and Maintenance of Alternate Storage Medium
Operating locations must select appropriate alternate mediums and system for storing e-records throughout the retention period. The mediums and systems must:
Retention, Disposition and Destruction of E-Records
Operating locations must retain, dispose, and destroy e-records according to the RF Record Retention Policy, and must apply additional considerations for e-records. The additional considerations include the:
- establishment of procedures for regular disposition (e.g., recopying, reformatting, other necessary maintenance)to ensure the sue and retention of e
records throughout the lifecycle.
- identification of sensitive, proprietary, or classified information prior to the destruction of e-records.
- previously used electronic mediums must not be reused if the previously recorded information (e.g., sensitive, proprietary, classified) can be compromised
by reuse in any way.
- Office of Management and Budget 2 CFR Part 200
- U.S. Government Printing Office for the Code of Federal Regulations: National Archives and Records Administration, 36 CFR 3, Part 1234, Subparts A and B,
Electronic Records Management Federal Acquisition Regulations, 48 CFR 1, Part 4, Subpart 4.7y, Contractor Records Retention: http://www.gpoaccess.gov/index.html
- DHHS GrantsNet for the OGAM AT 99-1: http://www.hhs.gov/grantsnet/ogamat.htm
Note: On or after December 26, 2014, 2 CFR Part 200 is effective and applies to all new awards issued. Funding awarded prior to this date and/or incremental funding may still be governed by OMB Circular A-110, A-21, or A-133, depending on the awarding agency's specific terams and conditions.
- November 14, 2001 - Replaces previously issued document "Microfilming Records" (AE-A71, AC-X-D, BE-X-R, PAR-X-F, PE-A-93, PP-X-G).
- December 26, 2014 - changed OMB reference to 2 CFR Part 200.
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