1.15.6. Managing Electronic Records

(1) Purpose. This IRM sets forth policy, assigns responsibilities, and explains requirements for the management of electronic records in accordance with Code of Federal Regulations (CFR) Title 36, chapter XII subchapter B, chapter XII, and United States Code (USC) Title 44, Title 36, chapters 29, 31, 33, and 35.

(2) Managing electronic records in systems and repositories that meet the requirements listed in IRM 1.15.6.1(3), ensures the IRS is compliant with the critical records management policies and regulations as established by the National Archives and Records Administration (NARA) and listed in the CFR. By adhering to these policies, the IRS will also increase business efficiency, and increase the value of information created.

(3) These requirements apply to all IRS electronic information systems and unstructured data repositories. At the IRS, these repositories must:

1. Store and preserve federal records and associated metadata. To meet these requirements, repositories must allow users to retrieve and use all records in the repository until the NARA-approved retention period is met.

2. Manage access and retrieval. To meet this requirement, repository administrators must establish appropriate user rights to access, search, and retrieve records, and prevent unauthorized access, modification, or destruction of records.

3. Execute dispositions. To meet this requirement, PGLD in coordination with repository owners, administrators, and users must: associate electronic records to their respective records schedules, destroy temporary records that are eligible for destruction; identify permanent records and carry out their transfer to NARA; and apply records holds or freezes on dispositions when required.

4. Backup systems. To meet this requirement, system administrators must design systems and processes to back up the electronic records using processes and media (system or file) that incorporate the appropriate functions in this section.

(4) Scope. This IRM section covers the following:

1. Basic requirements for electronic records.

2. Creation, maintenance, retention, and disposition of these records.

3. Usage and preservation of all electronic messages (including email, instant and text messaging platforms) that allow users to send messages in real time or for later viewing, and are used to send messages from one account to another account or from one account to many accounts.

4. A roles-based management approach to email records management. See IRM 1.15.6.7, Managing Electronic Mail Records.

5. Recordkeeping requirements when using personal or non-IRS communications tools to conduct IRS business.

6. Basic requirements for digitizing (scanning) temporary records.

7. IRS compliance requirements with NARA records management policies and regulations, improvement in business efficiency and faster responses to litigation and Freedom of Information Act (FOIA) requests.

(5) Audience. These procedures apply to ALL IRS employees and contractors.

(6) Program Owner. The Records and Information Management (RIM) Program office, under Privacy, Governmental Liaison and Disclosure (PGLD) is the program office responsible for oversight of the Servicewide records management policy.

(1) An electronic record contains information recorded in a form that is machine-readable (e.g., information that only a computer or similar system can process, and which, without a computer, would not be understandable to people). Recorded electronic information becomes a federal record when it satisfies the statutory definition of a “record,” and is the same definition applied to information recorded on paper. Basic definitions pertaining to electronic records management are:

1. Born Digital - records which have been generated entirely electronically, e.g. a document created in a word processing application, as opposed to a scanned image of a paper document.

2. Capstone - a roles-based/account-based approach to (electronic) management of email records that allows for the capture of records that should be preserved as permanent from the accounts of officials at or near the top of an agency or an organizational subcomponent (i.e., Capstone officials). See NARA Bulletin 2013-02 (Aug. 29, 2013).

3. Collaboration Tools - used to allow multiple users access to the same document for purposes of sharing information.

4. Database - (in electronic records) - a set of data, consisting of at least one file or a group of integrated files, usually stored in one location and made available to several users at the same time for various applications.

5. Database Management System - a software system used to access and retrieve data stored in a database.

6. Data File - numeric, textual, or graphic information that is organized in a strictly-prescribed form and format.

7. Digitizing - the process of converting paper or analog records to electronic records.

8. Digital Transformation (also known as digitalization) - the process of converting text, pictures, or sound into a digital form that can be processed by a computer, easily shared, and accessed. It could include comprehensive business process redesign and/or policy updates to reduce and/or eliminate paper.

9. Disposition - those actions taken regarding records no longer needed for regular current agency business and documented in Records Control Schedules (RCS).

10. Disposition Authority - the legal authorization for the retention and disposal of records.

11. Documentation - records required to plan, develop, operate, maintain, and use electronic records. Included are system specifications, file specifications, codebooks, record layouts, user guides, and output specifications.

12. Electronic Information System - a system that provides access to computerized federal records and other information.

13. Electronic Mail (Email) Records - records created or received on an electronic mail system including, but not limited to, correspondence among employees/colleagues containing briefing notes, policy decisions or reports for review, comment, or action; information requests from taxpayers requiring research, and any attachments, such as word processing and other electronic documents, which may be transmitted with the message.

14. Electronic Mail (Email) System - a computer application used to create, receive, and transmit messages and other documents. Exception: Excluded from this definition are: file transfer utilities (software that transmits files between users but does not retain any transmission data); data systems used to collect and process data that have been organized into data files or databases on either personal computers or mainframe computers; and word processing documents not transmitted on an email system.

15. Electronic Receipt - information in email systems regarding date and time of receipt of a message, and/or acknowledgment of receipt or access by addressee(s).

16. Electronic Recordkeeping System - a system whereby records are collected, organized, and categorized to facilitate their preservation, retrieval, use, and disposition.

17. Electronic Records Storage Media - material or platform used for the storage of electronic records.

18. Electronic Transmission Data - information in email systems regarding the identities of sender and addressee(s), and the date and time messages were sent (sometimes referred to as metadata).

19. Instant Messaging (IM) - Instant Messaging (IM) is an electronic messaging service that allows users to determine whether a certain party is connected to the messaging system at the same time. IM allows them to exchange text messages with connected parties in real time. Examples of instant messaging systems include Microsoft Office Skype for Business® and Lync®.

20. Metadata - consists of preserved contextual information describing the history, tracking, and/or management of an electronic document.

21. Migration - act of moving records from one system to another (i.e. due to system shutdown and upgrade to new platform) while maintaining the record’s authenticity, integrity, reliability, and usability.

22. Records Management Application (RMA) - software used to capture, categorize, locate, and identify records due for disposition, as well as store, retrieve, and document the disposition of records stored within its repository.

23. Social Media - internet or web-based technologies designed to disseminate information through social interaction. Examples include Facebook, Twitter, Flickr, YouTube, and other such technologies.

24. Structured Electronic Data - electronic data that resides in fixed fields within a record or file such as relational databases.

25. Text Message - an electronic communication (aka Short Message Service, SMS) sent and received by a mobile phone or other similar device.

26. Unstructured Data Record Content - unstructured data that meets the criteria of a federal record as defined in 44 USC 3301.

27. Unstructured Electronic Data - electronic data that does not reside in fixed fields, but is free-form text available in common office productivity tools such as word processors, spreadsheets, multimedia editors, presentations, diagrams, etc.

28. Unstructured Data Repository - a digital system or directory primarily used to store or collaborate on unstructured data such as SharePoint. Such repositories may or may not be equipped with out-of-the-box records management functionality.

(1) The National Archives and Records Administration (NARA) is responsible for issuing standards for management of federal records created or received on electronic systems. These standards apply to all Federal agency offices using office automation or information systems and will be followed by the IRS. The complete version of 36 Code of Federal Regulations (CFR) Part 1236, Electronic Records Management, is available at https://www.govinfo.gov/content/pkg/CFR-2011-title36-vol3/pdf/CFR-2011-title36-vol3-chapXII-subchapB.pdf.

(1) A Records Control Schedule (RCS) provides mandatory instructions for the disposition of records when they are no longer required by the agency. All IRS records, including records in electronic systems, must be scheduled (44 USC 3303) with NARA. The records must be covered by an agency schedule or a General Records Schedule (GRS). Records Control Schedules are available for each IRS major function and are published in IRS Document 12990. General Records Schedules are used by the IRS and other federal agencies for most administrative records requirements with some minor modification to certain series to comply with various Government Accountability Office (GAO) and Department of the Treasury specific requirements, and the GRS are published in Document 12829. Without an approved schedule, records are not authorized for destruction and must be held until a schedule is approved by the Archivist of the United States.

(2) The IRS Records Officer is the liaison with NARA and customer organizations for ensuring that electronic records and the related documentation are scheduled with NARA and retained for as long as needed by the IRS. The IRS Records Officer is responsible for:

1. Scheduling all electronic records, including masterfiles, related documentation and indexes, by submitting a new request for records disposition authority to the RIM Program office, or in some instances, by applying NARA’s GRSs. The information in electronic information systems, including those operated for the IRS by a contractor, must be scheduled as soon as possible, but no later than one (1) year after implementation of the system.

2. Transferring permanent electronic records and related documentation and indexes to NARA at the time specified in the Records Control Schedules for permanent records.

3. Providing guidance for the destruction or other disposal of temporary electronic records no longer having sufficient administrative, legal, research or other value warranting their further retention.
   
   IRM 1.15.3, Disposing of Records, provides additional guidance on IRS RCSs.
   

   Note: All RCS dispositions must be reviewed and approved by the IRS Records Officer and NARA prior to implementation and use by the IRS. Therefore, IRS staff are reminded not to develop or revise records retention instructions for organizational and functional (i.e., program) operations without first consulting the Servicewide RIM Program office.

(1) In accordance with OMB Circular A-130 and NARA Universal Electronic Records Management (ERM) requirements, records management requirements must be incorporated into the design of new electronic systems that produce, use, or store data files. Contact the RIM Program office at *Records Management for requirements information.

1. Acquisitions of Information and Technology Services must include records management requirements in solicitations. See NARA’s basic recommendations for RIM contract language, https://www.archives.gov/records-mgmt/policy/records-mgmt-language.

2. IT Investment Design and Management must fully incorporate records management functions, retention and disposition requirements into information life cycle processes and stages, including the design, development, implementation, and decommissioning of information systems, particularly internet resources to include storage solutions and cloud-based services such as software as a service, platform as a service, and infrastructure as a service. The RIM Program office must participate in the Systems Development Lifecycle (SDL) and Capital Planning and Investment Control (CPIC) processes to ensure permanent electronic records are appropriately identified and scheduled.

(2) Legacy/existing systems must be reviewed by the RIM Program office to ensure compliance with NARA electronic recordkeeping requirements.

(3) IT and IRS offices must maintain adequate and up-to-date technical documentation for each electronic system that produces, uses, or stores data files.

(4) Electronic System Shutdown (related to projects that follow the Enterprise Life Cycle (ELC) process). Electronic system owners must follow appropriate shutdown procedures when a system is scheduled for cancellation. Any records that have not yet met their required retention periods must be migrated into an approved recordkeeping system. When migrating records, all metadata must be preserved and accompanied with the transfer. The process is defined through the following series of actions to ensure orderly and efficient performance of essential shutdown activities.

1. If information is to be migrated to another system, you must:
   i. Notify the RIM Program office of changes to system (i.e., name change, or changes in functionality, etc.);
   ii. Determine if any changes should be made to the disposition of the new system based on changes in functionality; and
   iii. Manage the new system in accordance with an approved disposition authority.
   

2. If the information is not being migrated to a new system, you must:
   i. Notify the RIM Program office that this information will no longer be collected; and
   ii. Establish a plan to manage any legacy record data that has not yet met its approved disposition.

(1) Records and Information Management Program Office Responsibilities.

1. Configure Records Management Controls. RIM Program office is responsible for assisting Business Units with the implementation of appropriate records management controls (see 36 CFR 1236.20(b), Electronic recordkeeping) to ensure that all unstructured data recordkeeping systems are configured appropriately according to the Enterprise Records Management Taxonomy (ERMT) and the Records Control Schedules (RCS). Specifically, this includes:
   
   i. Working with Business Units to prepare, review and approve requirements for any system or repository capable of storing unstructured data.
   
   ii. Overseeing the association of unstructured data record content to an approved records schedule and disposition instruction according to 36 CFR 1236.20(b)(3), Organize records.
   
   iii. Overseeing the preservation of unstructured data record content for as long as needed to conduct agency business and meet NARA-approved dispositions according 36 CFR 1236.20(b)(6), Preserve records.
   
   iv. Overseeing the deletion of temporary records, and the transfer of permanent, unstructured data record content according to 36 CFR 1236.20(b)(7), Execute disposition.
   

2. Create and Manage the Enterprise Records Management Taxonomy (ERMT). RIM Program office is responsible for developing, maintaining and publishing the ERMT, coordinating with IT to incorporate this tool into unstructured data system or repository design, and educating stakeholders on the ERMT, its effects on the recordkeeping environment, and any subsequent duties required for management. ERMT is a standardized, hierarchical organization schema used to associate electronic records to their respective IRS business function and creator.

3. Create and Manage Automated Disposition Policies. RIM Program office is responsible for working with Business Units to ensure the appropriate development, maintenance and publication of automated disposition policies in unstructured data systems or repositories according to the respective NARA-approved Records Control Schedules. Automated disposition policies are rules configured in unstructured data systems or repositories to destroy or export records when criteria are met. Automated disposition rules which affect the destruction or export of unstructured data record content must be reviewed by the RIM Program office prior to configuration. This approval process should be built into unstructured data repositories to the highest extent possible.

(2) Information Technology Responsibilities. IT must provide storage locations for unstructured data that meet requirements described under (1a-d) above. IT must ensure that the records management functionality is appropriately enabled in all applicable document management systems. This includes the ability to appropriately apply NARA-approved records disposition authorities upon deployment of the system.

(3) All employee responsibilities. IRS employees MUST be able to distinguish between federal records and those non-record documents that may be business-related but do not meet the legal definition of a record (44 USC 3301) or warrant long-term retention. IRS employees MUST manage all information, both record and non-record, according to the guidance below.

1. Document Management Systems/Collaboration Environments (such as Documentum, SharePoint, etc.). Once all records management functionality is enabled according to IRM 1.15.6.1, these are appropriate platforms to store unstructured electronic records. RIM Program office, system administrators, and content owners must coordinate to establish/identify appropriate dispositions for the content stored within these records storage locations. Automated disposition policies must be configured to manage information in these environments to the highest extent possible.

2. File Shares (Shared Drives). These repositories do not currently provide the functionality necessary to electronically manage record information. Records (permanent and temporary) must be managed in accordance with the criteria listed in IRM 1.15.6.1, or moved to a compliant Document Management System/Collaboration Environment. If either option is not possible, manual processes and procedures must be developed and a copy provided to the RIM Program office. Written procedures must include the following:
   
   i. Ensuring records are covered by NARA-approved dispositions.
   
   ii. Communicating those NARA-approved dispositions to the users of the file share so retention requirements are well understood.
   
   iii. Reviewing annually the file share to take disposition actions required by NARA-approved schedule and document action taken.

3. Laptop/Desktop Hard Drives. These storage locations do not provide the functionality necessary to electronically manage record information. Laptop/Desktop Hard Drives should only be used to store personal material, reference material, or working papers that do not need to be accessed/collaborated on by others. All final recordkeeping copies must be moved to a compliant Document Management Systemic/Collaboration Environment.

4. Individual Employee Networking sites (I Drives, MySites, OneDrive, etc.). These storage locations do not currently provide the functionality necessary to electronically manage record information. These individually assigned storage locations should only be used to store working papers or reference material that do not meet the legal definition of a federal record. All federal records must be moved to a compliant Document Management System/Collaboration Environment.

5. Removable Media. This type of media does not provide the functionality necessary to electronically manage record information. Media such as flash drives, CDs, DVDs, and removable storage drives may be used to transfer record to an approved recordkeeping system or to back-up material saved to a hard drive.
   
   In all cases in which removable media is used, an inventory must be maintained. The removable media must be properly labeled, stored under proper environmental conditions, tested regularly to check for degradation, and protected from unauthorized access or modification. Removable media storage labels should include the Business Unit/employee name, the applicable Records Control Schedules on the media (particularly if used to store records, see Note below), the date range of the files, and the version of software application(s) used.

   Note: The RIM Program office (Records office) may grant exceptions to this records storage policy as needed, based on suitable justification and a thorough assessment of evident and potential risks. For example, examination case closures that require storage of records on removable media due to software constraints or file size generally are considered a policy exception (see IRM 4.10.9, Examination of Returns, Workpaper System and Case File Assembly and IRM 4.33.1, Electronic Business, Managing Electronic Records from Taxpayers and Third Parties). Contact the RIM Program office at *Records Management to discuss the need for a policy exception.

6. Backups. Employees are responsible for the backup of information saved to individual laptop/desktop hard drives to ensure data is not lost.

Note: Contact your Business Systems Planning (BSP) office for assistance with determining the best environment to store your information. For general guidance on the management of unstructured data contact the RIM office at the *Records Management mailbox.

(1) IRS Role-based Approach Explained - Under the IRS role-based approach, IRS manages email records based on the role of the email account user and/or office rather than on the content of each email record. Email records are captured and managed according to user role using the following retention approach:

(2) Exceptions:

1. Email records associated with official recordkeeping files: When business needs require email records to be retained with other records (such as part of an investigation, contract, project, or other case file), forward or copy these email records to the appropriate recordkeeping system (i.e., electronic recordkeeping system or paper file) and maintain according to the Document 12990, IRS Records Control Schedules or Document 12829, General Records Schedules. This role-based approach does not replace existing business practices that require email messages and other related records to be retained together in established recordkeeping systems, which may be paper or electronic.

   Note: GRS 5.1, Item 020, Non-recordkeeping copies of electronic records, authorizes deletion of electronic email records once filed in an official recordkeeping system (such as with a related case file, or within another records management application).

2. Non-Records: ALL account holders must delete non-records when no longer needed for reference. Non-records include non-business related messages, "broadcast" messages (e.g., IRS messages to all staff), and advertisements.

3. Personal Messages: ALL account holders must delete personal messages to ensure separation from record email messages. Personal messages are those messages from family/friends or colleagues that do not have an effect on the conduct of agency business.

4. Short-term (Transitory) Messages: ALL account holders must delete short-term (transitory) messages immediately or once final action is complete. Short-term (transitory) messages are those business-related messages such as routine exchanges of information, inquiries about availability and other routine actions.

(1) Electronic records may be used as digital evidence for use in court proceedings, provided the electronic records have established "trustworthiness" as set forth in the Federal Rules of Evidence 803(8). This is accomplished by thoroughly documenting the recordkeeping system’s operation and any associated controls imposed upon it to maintain system and record integrity. IRS offices must implement the following procedures to enhance the legal admissibility of electronic records:

1. Document that similar kinds of records generated and stored electronically are created by the same processes each time and have a standardized retrieval approach;

2. Verify that security and audit procedures prevent unauthorized addition, modification, or deletion of a record and ensure system protection against such problems as power interruptions;

3. Identify the electronic media on which records are stored throughout their life cycle, the maximum time span that records remain on each storage medium, and the NARA-approved disposition of all records; and

4. Coordinate all of the above with the Office of Chief Counsel, the IRS Records Officer and senior records management staff.

(1) IT and IRS offices with responsibility for electronic records will implement and maintain an effective records security program that incorporates the following:

1. Ensures that only authorized personnel have access to electronic records.

2. Provides for backup and recovery of records to protect against information loss or corruption.

3. Ensures that appropriate agency personnel are trained to safeguard sensitive or classified electronic records.

4. Minimizes the risk of unauthorized alteration or erasure of electronic records.

5. Provides protection for electronic records that are restricted from disclosure by the Privacy Act, the Federal Information Security Management Act (FISMA), the Computer Security Act, and other statues, regulations, Executive Orders, or authorities.

6. Protects federal information that is collected, maintained, processed, disseminated, or disposed of by cloud service offerings, in accordance with Federal Risk and Authorization Management Program (FedRAMP) requirements.

(1) Disposition is the third and final stage of the lifecycle of electronic records. Disposition refers to the actions taken regarding IRS records after they are no longer needed in office space to conduct current agency business. NARA authorizes either the disposal of records or transfer of records to the National Archives for preservation and research. Disposition actions of electronic records include:

1. Transfer of records from the IRS to another Federal agency.

2. Transfer of permanent records to NARA.

3. Disposal of temporary records no longer needed to conduct agency business, usually by destruction or occasionally by donation.

(1) The legal requirements for the transfer of permanent records to NARA are documented in 36 CFR 1235, Transfer of Records to the National Archives of the United States, and set forth in general form in the paragraphs below. If you need additional guidance after confirming your records retention and disposition authority in the IRS Records Control Schedules, consult the IRS RIM Program office or your BU IRC for more detailed instructions and guidance on the transfer of permanent IRS records.

(1) Electronic records must be disposed of in a manner that protects any sensitive, proprietary, or national security information.

(2) Temporary electronic records must be destroyed in accordance with the RCS or GRS. If a litigation hold or other disposal suspension activity is issued, any routine, approved destruction of effected records must cease immediately. Records destruction will not resume until a revocation order lifts the hold. Once the hold is lifted, the approved records disposition/destruction can continue. IRS Business Units may retain records approved for destruction beyond the period outlined in the records schedule if the records in question pertain to a court order, executive order, law, or approved business justification. Once the circumstances pertaining to the extended retention of records are no longer applicable, the IRS Business Units must destroy the records in accordance with the records schedule.

(1) IRS must manage record material produced or posted using social media such as Facebook, YouTube, Twitter, Instagram, and other similar technologies.

(2) The following records management considerations must be addressed with the use of these technologies:

1. The IRS must capture and manage information that meets the statutory definition of a federal record (44 USC 3301) in accordance with an approved Records Control Schedule (RCS).

2. More than one office/agency may have a responsibility for the same records, depending on their use.

3. Records must be managed in accordance with the content and not the format.

4. Records determined to have permanent value must be transferred to NARA in an approved format. Records may have to be migrated from original format to one accepted by NARA at the time of transfer.

(3) For additional information and guidance, contact the IRS RIM Program office via *Records Management.

(1) IRS must ensure the proper management of record material produced using collaboration tools (e.g. wikis, blogs, web portals, etc.). Collaboration may happen in multiple contexts, such as person to person, office to office, agency to agency, or public to agency (i.e., via interactive websites).

(2) The following records management considerations must be addressed with the use of these technologies:

1. Information that meets the statutory definition of a federal record (44 USC 3301) must be captured and managed in accordance with an approved RCS.

2. Records must be captured in an accessible, usable format.

3. If the collaboration is not located on the agency’s network, the Business Unit must discuss procedures for the capture of record material with the IRS Records Program office via *Records Management.

   Note: This guidance does not cover voicemail/Viewmail or the exchange and sharing of real time information through Live Meeting, group training sessions or similar functions of a collaboration system. Business Unit creators are responsible for the official maintenance of training/presentation/briefing materials shared (or updated) using Live Meeting or screen shares. The instant messaging software server is not the recordkeeping repository for those documents, and copies maintained by meeting participants would be considered reference material eligible for destruction when no longer needed.
   
   The Business Unit initiating a Live Meeting or share session to conduct business must make a decision as to the most appropriate method for documenting the session, such as an audio recording or written minutes. All official meeting records including the agenda, minutes, handouts, presentation materials, and recordings, should be maintained outside the session by the host Business Unit in association with an approved disposition authority for that office.

(1) IRS Business Units must contact the RIM Program office via *Records Management prior to the start of large digitization projects to ensure the resolution, size, color, bit-depth, metadata, and other digital capture qualities and image standards are appropriate for the source records being scanned. This requirement is essential for digitizing permanent records.

(2) Paper records converted to an electronic medium may be destroyed in accordance with GRS 5.2, Intermediary Records, ONLY when the following scenarios have been met:

1. All standards in IRM 1.15.6.15.1, Digitizing Temporary Records, have been met and verified;

2. Paper records are no longer needed for legal, audit or other business purposes; and

3. Electronic records are stored and managed in an approved electronic recordkeeping system with a NARA-approved retention period.

(1) When are email messages records?

An email message is a record if:

• it documents the IRS mission or provides evidence of an IRS business transaction, or
  

• it can be used in other official actions.

Email messages are records unless solely personal in content and use, or are non-records. Personal and non-record emails should be maintained separate from official (record) emails.

(2) Do I have to manage incoming and outgoing email as records?

Yes, you should apply the standard described above to both incoming and outgoing email. The reason is that both the sender and recipient of email messages have the responsibility to document their activities and those of their organizations. Both the sender and the recipient have to determine whether a particular email message is a necessary part of that documentation or if it fills in gaps in other records series.

(3) How can email be an official record if it is not signed?

A signature does not make an email a record. Many types of records, such as incoming letters, formal and informal manuals, published reports, photographs, voice recordings and maps, do not contain signatures, but they can be records.

(4) If an email record is sent to several recipients, which copy is the official record?

It depends. Different copies of the same message may ALL be records. If you take any official action related to a message, and if the message is needed for adequate and complete documentation of the action, the message would be a record in your office, regardless of whether copies are retained elsewhere. If you receive a message for information purposes only and do not take any action related to it, your copy is not a record.

(5) Do these guidelines apply to IRS contractors?

Yes, these guidelines apply to IRS contractors and agents who act on behalf of the IRS, as well as ALL IRS employees. Contract terms should ensure that contractor systems satisfy the legal requirements for creating and maintaining adequate and complete records of IRS transactions when those transactions are carried out by contractors.

(6) Are there special requirements for retaining email messages as records?

IRS email is managed based on the role of the individual in the organization. However, if the email serves as significant documentation for record sets outside of the email system, such as case files, project files, etc., the email must be associated with the record set outside of the email system.

(7) What if the message does not qualify as a record?

Delete email that is not a record when no longer needed.

(1) What is a record?

A record is anything you create or receive related to your daily work activities.

(2) Are there examples of the types of messages I should not save?

Messages that are not substantive in nature do not require saving. Examples include:

• "The meeting is about to start. Are you joining?"

• "Do you have time for a quick call before the briefing?"

These routine notifications and reminders are short-term messages with no substantive business information. As such, messages like these do not contain information that needs to be preserved beyond the instant messaging session.

(3) What is instant messaging?

Instant Messaging ("IM" or "IMing") is the exchange of messages in real-time through a software application. Generally included in the IM software is the ability to easily see whether an individual is available. Instant messaging differs from email because it provides instant feedback.

(4) Can I use instant messaging to send SBU data?

Yes, instant messaging systems are acceptable and convenient methods of automatic encrypted file transmission, but do not supersede policy or work processes for certain programs and offices. To transmit a document from within an IM, click the page-and-paper-clip icon in the upper right corner of your conversation with another user. Follow the instructions to locate the file you wish to transmit. The other party must accept the request for the file to be transferred. Always remember to Think Data Protection. Only access or share SBU data or PII with an IRS employee who has a business need for the information. Do not forget that a response to the sending of the instant message could be a federal record and will need to be saved.

(5) What type of messages should NOT be sent using instant messaging?

Employees should not use electronic messaging systems to engage in discussions involving policy matters, business decisions, or documentation of other mission-critical functions. This may result in the creation of a federal record that requires preservation beyond the closeout of the instant messaging session.

(6) If I use electronic messaging for work, am I creating federal records?

In almost all circumstances, the daily work performed by federal employees (permanent and seasonal) and contractors involves receipt or creation of federal record information.

(7) What is the Conversation History folder and where is it located?

The IRS instant messaging system keeps a record of instant message conversations in the Office Outlook Conversation History folder. The Conversation History folder is located in MS Outlook on the left side beneath the Deleted Items folder (just above the Junk email folder).

(8) If I create or receive a record using instant messaging, how do I save it?

If you create or receive a record using instant messaging, before exiting your conversation, you should save it by selecting Ctrl + S. The message will be placed in your Conversation History folder, you may move it to other folders within Outlook.

(9) Is instant messaging the same as text messaging? Am I allowed to use text messaging?

Instant messaging via your laptop is NOT the same as using text messaging on your mobile device or smartphone. In accordance with IRM10.8.1, Information Technology (IT) Security, Policy and Guidance, Telecommunication Devices on the use of text messaging with government-furnished mobile devices or cellular phones to conduct official business is prohibited, except in emergency situations when other forms of communication are unavailable.

(10) Is the electronic messaging policy a new requirement?

No. There has always been a requirement for employees to save and appropriately manage records they create.

(11) May I send an instant message to non IRS partners/stakeholders?

No. IRS’s instant messaging application is an internal application that cannot be used to communicate with others outside of the Service.

(12) Who do I contact if I need help saving my instant message or have questions about records management training or other support options?

Please contact *Records Management if you require training or need assistance with any records-related aspect of using instant messaging.