LETTER TO MICHAEL J. KURTZ FROM <SANITIZED> (W/ATTACHMENTS)
Document Type:
Collection:
Document Number (FOIA) /ESDN (CREST):
05496176
Release Decision:
RIPPUB
Original Classification:
U
Document Page Count:
70
Document Creation Date:
December 28, 2022
Document Release Date:
March 30, 2018
Sequence Number:
Case Number:
F-2017-02159
Publication Date:
December 15, 2003
File:
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Wash ington.D, C.20505
15 December 2003
Dr. Michael J. Kurtz
Assistant Archivist for
Records Services - Washington, D.C.
National Archives and Records Administration
8601 Adelphia Road
College Park, Maryland 20740-6001
Dear Dr. Kurtz:
(U) We believe we have taken the requested actions to close
out ten more of the recommendations in your Evaluation of the CIA
Records Management System. The attached progress report details
our actions with respect to the following recommendations: I/1,
1/3, II/1, II/la, 11/4, 11/7, 111/7, IV/1, IV/3, and IV/4. In
addition, the progress report also addresses your requests for
additional material.
(U) Finally, I would like to meet with you to discuss the
more difficult problems that remain. There have been a number of
meetings and useful discussions between our respective staffs.
These discussions have sharpened our understanding of some of the
issues, but have not led to their resolution.
(U//Perele4 Please call me
at your convenience after
report.
progress
Enclosure
1
Or
you have
reviewed
our
Director, Information Management Services
Chief Information Officer
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15 December 2003
Progress Report on the NARA Evaluation
of CIA Record Keeping Practices
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Table of Contents
(U) Overall Records Management
Recommendation I/1
Recommendation 1/3
(U) Records Creation and Maintenance
Recommendation II/1
Recommendation II/1a
Recommendation 11/4
Recommendation 11/7
(U) Records Scheduling and Disposition
Recommendation 111/7
(U) Agency-Wide Electronic Records
Recommendation 1V/1
Recommendation IV/3
Recommendation IV/4
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(U) Attachments
2. Employee Bulletin: "Records Responsibilities of CIA Employees and
Managers"
3. Memorandum: "Records Responsibilities of Senior Officials of the
Central Tnt llinence Aapncv"
5. what's News at CIA:
Managers"
6 Fmn7ovee 141:77E-tin. "Non-Textual Records Preservation"
"Records Responsibilities of Employees and
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Recommendation In:
(U) Ensure that there are sufficient IMOs in both OIT and the Directorates to
implement the recommendations in this report.
(U) Review workloads and staffing levels to determine whether or not IMOs
should be assigned to organizations where day-to-day records management
duties are currently handled by POCs.
Action Items Identified from Latest Correspondence:
� (U) Describe how the fifth directorate is being provided IMO support.
� (U) Implement the Information Management Checklist, and describe how
recommendation implementation will be tracked and follow-up made.
CIA Response:
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Recommendation 1/3:
(U) Develop a one-day course dealing with record keeping responsibilities of
program staff including the application of approved records schedules to
their files and basic records concepts such as distinguishing records from
non-record materials.
Action Items Identified from Latest Correspondence:
� (U) Contact David Langbart to review the second generation CST.
CIA Response:
(U/friaere7 As requested in your 17 April 2003 reply, an appointment was set up
with David Langbart, and the second generation CET was reviewed on 15 July
2003.
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Recommendation II/1:
(U) Ensure that employees, including Deputy Directors and other high-level
decision makers, are aware of requirements in Federal law and regulation to
document and maintain in appropriate files all policy and decision-making
actions, including those discussed via electronic mail (e-mail) or during
telephone conversations.
Action Items Identified from Latest Correspondence:
� (U) Modify the Employee Bulletin on "Records Responsibilities of CIA
Employees and Managers" to more fully address electronic records
management.
� (U) Modify the memorandum on "Records Responsibilities of Senior
Officials of the Central Intelligence Agency" as noted.
� (U) Forward a copy of the personal papers guidance that has been
issued.
CIA Response:
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(u/Aolnr) The Employee Bulletin on "Records Responsibilities of CIA Employees
and Managers" (attachment #2) and the memorandum on "Records Responsibilities
of Senior Officials of the Central Intelligence Agency" (attachment #3) were
modified and reissued in accordance with your 17 April 2003 reply.
(U//44744 In regards to the personal papers guidance cited throughout your
replies, we believe sufficient reference to personal papers has been made
within other guidance we have issued. more specifically, it appears in our
Employee Bulletin on "Records Responsibilities of CIA Employees and Managers"
(attachment #2), where we also direct employees to 36 CFR � 1222.36 for
further information Additionally, it has been referenced
in a What's News at CIA article titled "Records
Responsibilities of Employees and Managers" (attachment #6).
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Recommendation II/la:
(U) E-mail communications that meet the definition of records should be
retained in a record keeping system.
Action Items Identified front Latest Correspondence:
� (U) Modify the Employee Bulletin on "Records Responsibilities of CIA
Employees and Managers" as noted.
� (U) Add the following question to the Information Management Checklist:
Has the Agency's email policy been distributed to all
employees in the directorate/component/office?
CIA Response:
(U/PNM544 The Employee Bulletin on "Records Responsibilities of CIA Employees
and Managers" was modified and issued in accordance with your 17 April 2003
reply (attachment #2).
CU/PROM As noted in our response to Recommendation Ill, the IM Survey has
replaced the IM Checklist., Nonetheless, the question you provided in your 17
April 2003 reply has been added to the next iteration of the IM Survey
scheduled for FY 2004.
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Recommendation 11/4:
(U) Ensure that adequate indexes are created where necessary and that staff
who need to use them have familiarity with them.
Action Items Identified from Latest Correspondence:
(U) Finalize and implement the Information Management Checklist
CIA Response:
(U/firrrAs noted in our response to Recommendation I/1, the IM Checklist
was replaced by the IM Survey, which was implemented January thru March 2003.
Therefore, all recommended changes to the IM Checklist have been integrated
into the next iteration of the IM Survey scheduled for FY 2004.
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Recommendation 11/7:
(U) Continue and extend the ARC preservation project. Implement a
preservation project for older records held in locations other than the ARC.
Action Items Identified from Latest Correspondence:
� (U) Implement the Information Management Checklist, and describe how
recommendations will be tracked once the list is distributed.
� (U) Revise the Employee Bulletin on "Non-Textual Records Preservation"
as noted.
CIA Response:
(U/fl'IrT) The Employee Bulletin on "Non-Textual Records Preservation" was
modified and reissued in accordance with your 17 April 2003 reply (attachment
#6).
(UnEkefide-) Please see our response to Recommendation I/1 for details
surrounding the IM Checklist.
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Recommendation III/7:
(U) Continue the project to apply correct schedule items to ARC accessions
improperly retired as permanent; include NARA review as part of the process.
Action Items Identified from Latest Correspondence:
(U) Allow NARA staff to visit the ARC to learn about the progress to
apply correct schedule items to ARC accessions and to do some spot-
checking to ensure conversions accurately reflect approved schedules.
CIA Response:
(U/MNiiiki.) NARA staff is welcome to visit the ARC at any time that is
convenient for them. However, we should note that although the ARC staff
does use the quality control checklist mentioned in our 30 September 2002
response, they only check to make sure an RCS item has been assigned. It is
the responsibility of the component IMO to assign the correct RCS item, and
it is subsequently the responsibility of the Directorate IMO to double check
the component IMO's selection before the boxes are sent down to the ARC.
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Recommendation IV/1:
(U) Comply with NARA guidance contained in 36 CFR 1234 when electronic
systems are developed, maintained, or upgraded. Of particular importance is
the need to include migration strategies as part of the life cycle planning
for electronic systems design and implementation.
Action Items Identified from Latest Correspondence:
� (U) Provide NARA with a copy of an Information Management Plan for a
specific electronic system.
CIA Response:
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Recommendation IV/3:
(U) Disseminate the Agency e-mail regulation to all Agency staff who use e-
mail and monitor its implementation. Update this issuance as NARA develops
new guidance concerning the maintenance and disposition of e-mail.
Action Items Identified from Latest Correspondence:
� (U) Describe the steps CIA is taking to monitor implementation of the
Agency's email guidance and regulations.
� (U) Modify the Employee Bulletin on "Records Responsibilities of CIA
Employees and Managers" as noted.
CIA Response:
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(U/7"fi0te#0) As noted above, the Employee Bulletin on "Records Responsibilities
of CIA Employees and Managers" (attachment #2) has been modified and issued
in accordance with your 17 April 2003 reply.
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Recommendation IV/4:
(U) Complete the centralized catalog project so the Agency will have a
comprehensive, Agency-wide inventory of electronic records. After the
centralized catalog is completed, implement measures to keep it current as
additional systems are developed.
Action Items Identified from Latest Correspondence:
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CIA Response:
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UNCLASSIFIED
OPR: CIO/IMS EB NUMBER: 002-03
1 October 2003
RECORDS RESPONSIBILITIES OF CIA EMPLOYEES AND MANAGERS
1. (U) This Employee Bulletin is being issued to remind all CIA employees of their
responsibilities under 36 CFR � 1220� 1236 to create, maintain and preserve records of
agency organization, functions, policies, decisions, procedures, and essential transactions.
2. (U) Every CIA employee produces records on a daily basis. Not all records are
treated the same, however. Each record type has a specific business use and, hence, a
specific retention period that may be as brief as "destroy when no longer needed" or as
enduring as those designated "permanent" that, in time, will be transferred to the National
Archives. All records have a specific retention period that must be approved (scheduled)
by NARA. All records shall be maintained, inviolate and readable, for the specified
retention period. Any unauthorized destruction of records deprives the Agency of
accountability, history, continuity, and legal defense AND may represent a criminal
offense.
3. (U) Records may be produced on any medium and/or communicated physically,
visually, verbally, or electronically. Memoranda of telephone conversations, discussions,
and meetings, e-mail messages, memoranda, contents of or output from a database,
instant messages, presentations, chat boards, audio and video recordings, correspondence,
cables, intelligence reports, and speeches may be records. Records might be arranged as
subject files, country files, chronological files, project files, or by other means. The
statutory definition of a record is as follows:
All books, papers, maps, photographs, machine-readable materials, or other
documentary materials, regardless of physical form or characteristics, made or
received by an agency of the US Government under Federal law or in connection
with the transaction of public business, preserved or appropriate for preservation
by that agency or its legitimate successor as evidence of the organization,
function, policies, decisions, procedures, operations or other activities of the
Government or, because of the informational value of the data in them. (44 US
Code 3301)
4. (U) All employees, regardless of rank or position, have an official responsibility to
adequately and properly document and maintain, in appropriate files, records produced or
received in the component to which he or she is assigned. All records must be
maintained in an approved record keeping system, which can be paper or electronic.
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5. (U) Please reference which contains the
policies and procedures associated with the Agency records management program and
each employee's responsibility under that program. In addition, tipulates that
official telephone conversations, meetings, and other conversations should be
documented in Memorandums to the File. Employees must prepare this documentation
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for all conversations in which Agency business is conducted. The maintenance of
chronologies in an office is a common Agency practice. Chronologies are records, and in
some cases, may be the only official record of the office activities. Chronologies that are
exact copies of office records held in an approved record keeping system are reference
and can be discarded annually or when no longer needed. Every employee maintains
what he/she calls "working files." Often, these files are duplicates of the office record
copy. However, any working paper or draft that was circulated outside the unit of origin
for comment or action and contains substantive information not captured in the final
document must be kept (along with the final) in the office record keeping system. E-mail
messages may also constitute records.'
including the proper
capture and maintenance of e-mail. If there are questions regarding retention and
disposition of an office chronology, a collection of working files, e-mail or other records,
the custodian must contact the component or Directorate Information Management
Officer (IMO) for guidance.
6. (U) There are no presumptions that work products, finished or in draft, or the
documentation of decisions, policies, and transactions (all records) produced by a CIA
employee are personal. Such work was produced for and remains the property of the
Agency, and represents a Federal record. However, employee-originated materials of a
strictly personal nature (despite using Government facilities) that do not relate to or have
an effect upon Agency business are excluded from the definition of Federal records. This
material must be kept separate from the Agency records. Personal papers, prior to being
removed from CIA or other Federal property, must be reviewed by the Directorate
Information Release Officer (IRO). See the Information and Records Management
Database (AGNS04) and refer to 36 CFR � 1222.36(c) for additional guidance on
personal papers.
7. (U) Prior to leaving an assignment or the Agency, each employee shall ensure that:
o the records he/she received or originated are in an approved record keeping
system;
o all other referential information is disposed of in accordance with approved
disposition schedules;
o no official materials, including copies, whether classified or not, are removed
from Agency facilities without authorization;
o the appropriate Directorate IRO has reviewed (for release) all information of a
purely personal nature, not associated with official Agency activities, before
removal from CIA or other government facilities.
8. (U) If you have any questions regarding the retention of federal records lease consult
with your Directorate (MSO/IMO I jDIIIMO 0
DST/IMO L DCI Area/IMO or
component Information Management cer.
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12 December 2003
MEMORANDUM FOR: Director, of Central Intelligence
Deputy Director of Central Intelligence
Deputy Director of Central Intelligence
for Community Management
Executive Director
Deputy Director for Intelligence
Deputy Director for Operations
Deputy Director for Science and Technology
Director of Security
Chief Financial Officer
Chief, Global Support
Chief Human Resources Officer
Chief Information Officer
Chairman, National Intelligence Council
General Counsel
Inspector General.
Associate Director of Central Intelligence
for Military Support
Deputy Executive Director
Director of Congressional Affairs
Director of Public Affairs
(b)(3) FROM:
Director ot Intormation Management
Services, CIO
SUBJECT: (U) Records Responsibilities of Senior Officials
of the Central Intelligence Agency
1. (U) The National Archives and Records Administration
(NARA) requires us to periodically remind all employees of
certain records management responsibilities.
2. (U) Senior officials of the Agency are responsible for
ensuring that adequate and proper documentation of the
organization, functions, policies, decisions, procedures,
activities, and essential transactions of the Agency is created
and maintained, and that final disposition is handled properly,
in accordance with applicable laws, regulations, and approved
records control schedules.
3. (U/i&) Agency employees originate or receive almost
every product or communiqu�ia computer and much of the Agency
business is transacted through email, inside and outside the CIA.
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Subject: (U) Records Responsibilities of Senior Officials of
the Central Intelligence Agency
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Accordingly, these records should be put into an approved record
keeping system, for example, the Proactive Electronic Records
Management System (PERM). Alternatively, email records may be
printed and put in a paper record keeping system.
4. (U//retTer) Each Directo;ate has a senior Information
Management Officer (IMO) whose charge is to assist you and your
staff on issues regarding records management and the appropriate
classification level to apply to these records. As needed, the
Directorate IMO, or one of the component IMOs in your area, can
also provide handouts and/or a brief presentation about proper
records management techniques. We also reminded employees of
their record keeping responsibilities in a recently issued
Employee Bulletin, Number 0002-03, dated 2 October 2003.
5. (u//rouo) Please contact your Directorate IMO or the
ChiefRecords and Classification Management Group/IMS/CIO
for any assistance that we may provide to facilitate
recordiceeping in your of
(b)(3)
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Subject: (U) Records Responsibilities of Senior Officials of .
the Central Intelligence Agency
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CIOIIMS7
1(12 Dec 0311
Distribution:
Original - DCI
1 - DDCI
1 - DDCl/CM
1 - ExDir
1 - DDI
1 - DDO
1 - DDS&T
1 - D/SEC
1 - CFO
1-C/GS
1 - C/HR
1 - CIO
1 - C/NIC
1 GC
1 - IG
1 - ADCl/MS
1 - D/ExDir
1 D/OCA
1 - D/OPA
2 - AD/CIO/IMS (Subj/Chron)
1 - C/RCMG/IMS
1 - DAC
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February 5, 2001
No. 835
'ratIMtveiSSiiszuriAmsEnnaataxmasoittw.-anasztedusameatrmaw,siwSnaagrawaw,?,
(U//A44510) Records Responsibilities of Employees and Managers
(LW/Mee) The National Archives and Records Administration requires us to periodically
remind employees, particularly during a change in Administration, of certain records
management responsibilities.
(UHArFrolte) Each employee, regardless of rank or position, has an official responsibility to
create and maintain the records, electronic and non- electronic, needed to document the
activities of the component to which he/she is assigned. These records include cables,
memoranda, e-mail, meeting minutes, instant messaging, audio and video recordings, and
speeches.
(U/horte0) Prior to leaving the Agency, employees should ensure that the records they have
received or created are in an approved recordkeeping system. Duplicate copies that
employees have maintained in their offices for reference purposes should be destroyed.
Employees leaving the Agency are reminded that no official materials, including copies,
whether or not classified, are to be removed from Agency facilities without authorization.
(MAW'S) An employee may take information of apurely personal nature not associated
with official Agency activities when departing CIA and public service.
(U/htte0) If you have any questions regarding the retention of federal records, please consult
with your Directorate or component Information Management Officer or
Chief/Records and Classification Management Group, Office of Information Management,
(This is UNCLASSIFIED es d ADMINISTRATIVE INTERNAL USE ONLY.)
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OPR: CIO EB NUMBER: 001-03
2 October 2003
(U) NON-TEXTUAL RECORDS PRESERVATION
(b)(3)
(U) This Employee Bulletin is being issued to ensure that Agency officers who permit their
records to be stored outside of the Agency Records Center (ARC) or another National Archives
and Records Administration (NARA) a i ty are aware of their responsibilities to
maintain all records in accordance with 36 CFR � 1220 � 1236.
(U) Of particular concern is the preservation of non-textual records appraised as permanent.
These media are particularly fragile and require appropriate handling and storage in order to
preserve the information contained therein. Examples of these types of records include motion
picture film; still photography; imagery; film strips; sound and video recordings; posters and
other graphic works; and multimedia productions with related finding aids and production
documentation. Other non-paper records requiring special handling include microfilm and
microfiche.
(U) Specific instruction for the preservation, maintenance, and transfer of these media to the
National Archives can be found in:
� 36 Code of Federal Regulations � 1228.266, Transfer of audiovisual records
� 36 Code of Federal Regulations � 1228.270, Transfer of electronic records
� 36 Code of Federal Regulations � 1232, Audiovisual records management
� 36 Code of Federal Regulations � 1234, Electronic records management
� The NARA Publication, entitled "Managing Audiovisual Records"
� Additional information can be found in ISO standards 18911, 18918, and 18920.
(U) Agency offices that store non-textual media in their areas or with another storage provider
(other than the ARC) must comply with the guidance noted above. At a minimum, managers
must ensure that:
� Audiovisual media records are stored in a facility where the temperature does not
exceed 70 degrees Fahrenheit and relative humidity is below 50 percent. (Lower
temperature and humidity levels prolong the useful life of these records.)
� Film records requiring long-term retention are of the polyester-based silver gelatin type
as opposed to cellulose-acetate film, which deteriorates over time.
� Equipment intended for projection or playback of all non-textual media is in good
working order.
� Permanent audiovisual records be inspected every two years for damage or
deterioration.
� All photographs are placed in inert plastic sleeves. (Inert plastics and other storage
materials are described in the ISO standard 18902:200)
� All media is packaged in inert plastic, non-corroding metal, or acid-free paper based
containers.
� Silver gelatin originals are separated from non-silver reference copies and, if necessary,
stored off-site of the customer premises.
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(U) NARA has determined that the ARC meets the Federal standards to ensure that records
maintained at the AARC are properly safeguarded and preserved. The ARC not only maintains a
controlled environment but also periodically reviews film and other non-textual media for signs
of potential deterioration.
(UllicittO) Component managers may wish to consider using the ARC to store non-textual
materials that they now maintain within their office or other facilities under their control.
Questions regarding the preservation of non-textual media can be addressed to ARC personnel or
to your Directorate or component Information Management Officer,
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