1.15.6  Managing Electronic Records

Manual Transmittal

March 27, 2014

Purpose

(1) This transmits revised IRM 1.15.6, Records and Information Management, Managing Electronic Records.

Background

This IRM covers the creation, maintenance, use, and disposition of federal records created using IRS electronic information systems and personal computers, including electronic mail and other electronic applications.

Material Changes

(1) This IRM has been updated to include new references to the Internal Revenue Service (IRS) Records Control Schedules and the General Records Schedules previously published in the Internal Revenue Manual.

(2) This IRM has also been updated to reflect current guidance, references and citations.

Effect on Other Documents

This IRM replaces 1.15.6, Managing Electronic Records published June 1, 2010.

Audience

All divisions and functions.

Effective Date

(03-27-2014)


Kevin Q. McIver
Director, Real Estate and Facilities Management (REFM)
Agency Wide Shared Services (AWSS)

1.15.6.1  (03-27-2014)
Overview

  1. This section provides the basic requirements for electronic records, including electronic mail (e-mail). It also addresses the creation, maintenance, retention, and disposition of these records.

1.15.6.2  (06-01-2010)
Basic Electronic Records Management Definitions

  1. An electronic record contains information recorded in a form that is machine-readable (e.g., information that only a computer 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,” see IRM 1.15.2, which is the same definition applied to information recorded on paper. Basic definitions pertaining to electronic records management are:

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

    2. Data Base - (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.

    3. Data Base Management System - a software system used to access and retrieve data stored in a database.

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

    5. 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.

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

    7. Electronic Mail System (E-Mail) - 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 data bases on either personal computers or mainframe computers; and word processing documents not transmitted on an e-mail system.

    8. Electronic Mail Message - a record created or received on an electronic mail system including briefing notes, more formal or substantive narrative documents, and any attachments, such as word processing and other electronic documents, which may be transmitted with the message.

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

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

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

    12. 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.

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

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

    15. Unstructured Electronic Data - data that does not reside in fixed fields, but is free-form text such as word processing documents.

1.15.6.3  (03-27-2014)
Responsibility for Issuance of Guidance

  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 http://www.ecfr/gov.

1.15.6.4  (03-27-2014)
Creation, Use, and Maintenance of Structured Electronic Data

  1. For electronic information systems that produce, use, or store data files, disposition instructions for the data will be incorporated into the systems’ design.

  2. IRS offices will maintain adequate and up-to-date technical documentation for each electronic system that produces, uses, or stores data files. The minimum documentation required is as follows:

    1. Narrative description of the system, physical and technical characteristics of the records, including a records layout that describes each field (name, size, starting or relative position);

    2. A description of the form of the data (alphabetic, zoned decimal, packed decimal, or numeric);

    3. A data dictionary, or the equivalent information associated with a data base management system, i.e. a description of the relationship between data elements in databases, and any other technical information needed to read or process the records;

    4. A copy of the user’s manual or handbook on how to operate and use the system or database;

    5. Completion of IRS Form 12240 Information Systems Description , IRS Form 14510 New Records Series Data Collection, or other documentation verifying records scheduling authorization; and

    6. A sample of the data, reports, or other documents the system or data base may produce and to whom they are provided.

      Note:

      These elements and items will be submitted to the ARM for processing and submission to the Records and Information Management (RIM) Program Office.

  3. Capital Planning and Investment Controls. In accordance with OMB Circular A-130, IRS must incorporate records management functions into the design, development and implementation of information systems. In addition to ensuring the accessibility and proper accountability for their information systems, IRS must ensure that all electronic systems are evaluated through the Capital Planning and Investment Controls (CPIC) process. The current CPIC questionnaire includes a section on Records Management. It is important for these questions to be addressed at the beginning of the system development process to ensure that records management functionality is part of the system design phase.

  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. The process is defined through a systematic series of actions to ensure orderly and efficient performance of essential shutdown activities. The following records management actions must be taken when migrating, retiring, or shutting down an electronic system:

    1. If information is to be migrated to another system you must:
      1) Notify the RIM Program Office of changes to system (i.e. name change, or changes in functionality, etc.);
      2) Determine if any changes should be made to the disposition of the new system based on changes in functionality; and
      3) 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:
      1) Notify the RIM Program Office that this information will no longer be collected; and
      2) Establish a plan to manage any legacy record data that has not yet met its approved disposition.

1.15.6.5  (03-27-2014)
Creation, Use, and Maintenance of Unstructured Electronic Data

  1. At a minimum, electronic recordkeeping systems that maintain the official copy of unstructured data such as text documents, email, presentations, audio video files, image files, and PDF files electronically will provide:

    1. A method for all authorized users of the system to retrieve desired documents, such as an indexing or text search system;

    2. An appropriate level of security to ensure integrity of the documents;

    3. An appropriate audit trail or tracking system for data manipulation and version identification;

    4. A standard interchange format when necessary to permit the exchange of documents on electronic media between IRS computers using different software/operating systems and the conversion or migration of documents on electronic media from one system to another; and

    5. The disposition of the documents including, when necessary, the requirements for transferring permanent records to NARA (see IRM 1.15.6.9).

  2. IRS may also choose to use a DoD 5015.2-STD compliant Records Management Application to assist in the management of unstructured electronic records. Currently, IRS has 60,000 licenses of EMC Documentum that will allow for Enterprise level management of unstructured electronic record data. For more information about this product, please contact the IRS RIM Program Office.

1.15.6.6  (03-27-2014)
Standards for Managing Electronic Mail Records

  1. IRS instructions on identifying and preserving electronic mail messages will address the following unique aspects of electronic mail:

    1. Some transmission data (names of sender and addressee(s) and date the message was sent) must be preserved for each electronic mail record in order for the context of the message to be understood.

    2. Offices using an electronic mail system that identifies users by codes or nicknames or identifies addressees only by the name of a distribution list shall instruct staff on how to retain names on directories or distribution lists to ensure identification of the sender and addressee(s) of messages that are records.

    3. Offices using an electronic mail system that allows users to request acknowledgments or receipts showing that a message reached the mailbox or in box of each addressee, or that an addressee opened the message, shall issue instructions to e-mail users specifying when to request such receipts or acknowledgments for recordkeeping purposes and how to preserve them.

    4. Offices with access to external electronic mail systems shall ensure that federal records sent or received on these systems are preserved in the appropriate recordkeeping system, which may be paper, and that steps are taken to capture available transmission and receipt data needed by the agency for recordkeeping purposes.

    5. Some e-mail systems provide calendars and task lists for users and, therefore, those utilities may meet the definition of a federal record. Calendars that meet the definition of federal records are to be managed in accordance with the provisions of General Records Schedule 23, Records Common to Most Offices, Item 5 Schedule of Daily Activities published in IRS Document 12829.

    6. Draft documents that are circulated on electronic mail systems may be records if they meet the definition of a federal record. If a draft document meets the criteria, including any comments or changes made, must be captured "as is" and retained as a record for the IRS. (36 CFR 1222.12).

  2. IRS offices will consider the following criteria when developing procedures for the maintenance of electronic mail records in appropriate recordkeeping systems, regardless of format. The recordkeeping systems that include electronic mail messages must:

    1. Provide for the grouping of related records or topics into classifications according to the nature of the business purposes the records serve;

    2. Permit easy and timely retrieval of both individual records and files or other groupings of related records;

    3. Retain the records in a usable format for their required retention period as specified by a NARA-approved records schedule;

    4. Be accessible by individuals who have a business need for information in the system or for recordkeeping purposes;

    5. Preserve the transmission and receipt data as required by agency instructions; and

    6. Permit either retirement or separation of temporary records from permanent, as well as the transfer of permanent records to NARA. See 36 CFR Parts 1235 and 1236 for additional information.

  3. IRS offices will not store the official recordkeeping copy of e-mail messages that are federal records ONLY on the electronic mail system, unless the system has all of the features of an electronic recordkeeping system, some of which are specified in paragraph 2 above. If the electronic mail system is not designed to be a recordkeeping system, ask an E-Mail/System Administrator to instruct you on how to copy the information from the electronic mail system to a recordkeeping system or produce a hard copy for recordkeeping purposes.

  4. IRS offices that maintain their e-mail records electronically will move or copy them to a separate electronic recordkeeping system unless their system has the features specified in IRM 1.15.6.6.2 above. Backup tapes are not to be used for recordkeeping purposes.

  5. Offices may retain records from electronic mail systems in an off-line electronic storage format (such as optical disk or magnetic tape) that meets the requirements of 36 CFR 1236.28. Offices that create or have permanent e-mail records scheduled for transfer to NARA will store them in a format or on a medium that conforms to the requirements for transfer (see 36 CFR 1235) or will maintain the ability to convert the records to the required format and medium at the time of transfer.

  6. Offices that maintain paper files as their recordkeeping systems will print their e-mail records and the related transmission and receipt data.

  7. When email inboxes become too full, or hard drives need to be "cleaned up" , the following steps must be taken:

    1. Inventory email to identify personal messages, work-related non-record messages, and those email messages that meet the definition of a federal record.

    2. Personal messages must be deleted when no longer needed. These include such material as emails sent to and received from friends, family members, and list serves; messages about lunch dates; video and audio clips; and other messages received on non-work time.

    3. Work-related non-record messages must be deleted when no longer needed. These include information/reference email and word processing files received "for your information" or as a carbon (CC) or blind copy (BC), but which you were not expected to and did not take action on. Further examples may include copies of directives and interim guidance, notices, images, CAD drawings, and copies of reports.

    4. E-mail messages identified as federal records must be handled in accordance with their NARA-approved disposition schedule and kept in an approved recordkeeping system as discussed above. To identify the appropriate disposition, consult the Records Control Schedules Documents 12829 and 12990 or your ARM. A full listing of ARMs is located on the RIM website. IRS employees are instructed to retain all electronic copies and paper records until disposition instructions have been approved and distributed by the IRS RIM Program Office. Unlawfully destroying federal records is a violation of the Federal Records Act and carries stiff penalties.

  8. See Exhibit 1.15.6-1 for Common Questions About E-mail. The RIM Program Office currently has the following information available through its website:

    1. Managing E-mail training course;

    2. Document 12073, Managing Electronic Mail; and

    3. IRS Guidance for Sorting out E-files on Network Servers and Hard Drives

1.15.6.7  (06-01-2010)
Judicial Use of Electronic Records

  1. Electronic records may be admitted in evidence to federal courts for use in court proceedings if trustworthiness is established by thoroughly documenting the recordkeeping system's operation and the controls imposed upon it [Federal Rules of Evidence 803(8)]. IRS offices should 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 Counsel, the IRS Records Officer and senior IRM and records management staff.

1.15.6.8  (06-01-2010)
Security of Electronic Records

  1. IRS offices 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. Ensures that electronic records security is included in computer systems security plans prepared pursuant to the Computer Security Act of 1987.

1.15.6.9  (03-27-2014)
Retention and Disposition of Electronic Records

  1. The IRS Records Officer is the liaison with NARA and customer organizations for ensuring that electronic records and the related documentation are retained for as long as needed by the IRS. These disposition and retention procedures shall include provisions for:

    1. Scheduling all electronic records, as well as related documentation and indexes, by submitting an SF-115, Request for Records Disposition Authority to NARA or, in some instances by applying NARAs General Records Schedules. The information in electronic information systems, including those operated for the IRS by a contractor, will be scheduled as soon as possible, but no later that one year after implementation of the system.

    2. Transferring a copy of the electronic records and related documentation and indexes to NARA at the time specified in the records control schedule for permanent records.

      Note:

      SF-115 is completed by the IRS Records Management staff only.

  2. Records created within e-mail systems, which meet the criteria of a federal record, are subject to the same retention periods as the paper or hard-copy versions. Therefore, these records must be retained electronically according to the NARA-approved disposition authority or printed and associated with the appropriate recordkeeping system. Temporary e-mail records can be deleted only when they are eligible for destruction or when they have been printed and associated with the appropriate recordkeeping system. See additional information on the retention and transfer of permanent electronic records in subsection IRM 1.15.6.11.

  3. At the direction of a management official as to what is considered a record, the E-mail/Systems Administrators will establish procedures for regular recopying, reformatting, and other necessary maintenance to ensure the retention and usability of electronic records throughout their authorized life cycle.

  4. The responsibility for instructing users on how to copy and archive electronic mail records rests with the E-Mail/Systems Administrators at the user levels. With the proper direction from a management official, the user and/or end recipient should possess the expertise to identify and determine which records are worthy of preservation and/or archiving.

  5. The disposition of electronic mail records that have been relocated to an appropriate recordkeeping system is governed by schedules that control the records in that system. If the records in the system are not scheduled, contact the Area Records Manager or the RIM Program Office to get them scheduled and approved by NARA.

    Note:

    Approved disposition authorities for electronic records created as part of tax processing systems are included in separate Records Control Schedules 8 through 37 based on their use and/or associated activity (published in Document 12990). Many other administrative systems are included in the General Records Schedules 38 through 64 (published in Document 12829). Questions concerning the scheduling of an electronic system should be directed to the IRS RIM Program Office.

1.15.6.10  (03-27-2014)
Transfer Media and Formats for Permanent Records

  1. The legal requirements for the transfer of permanent records to NARA are documented in 36 CFR 1235 and set forth in general form in the paragraphs below. Consult the IRS RIM Program Office for more detailed instructions and guidance on the transfer for permanent IRS records.

1.15.6.10.1  (06-01-2010)
Magnetic Tape

  1. IRS offices may transfer electronic records to NARA on magnetic tape using either open-reel magnetic tape or tape cartridges. Open-reel tape should be on 1/2 inch 9-track tape reels recorded at 1600 or 6250 bytes per inch and blocked no higher than 32,760 bytes per block. Tape cartridges should be 18-track 3480-class cartridges recorded at 37,871 bpi and blocked at no more than 32,760 bytes per block.

1.15.6.10.2  (03-27-2014)
Compact Disk, Read Only Memory (CD-ROM) and Digital Video Disk (DVD)

  1. CD-ROMs may be used as transfer media for fielded data files or text files if they conform to the International Standards Organization (ISO) 9660 Standard and to the American Code for Information Interchange (ASCII); are not compressed unless NARA has approved the transfer of the compressed form in advance; and are individually addressable. The CD-ROMs may contain software files and temporary records, but permanent records must be in files that contain only permanent records.

  2. DVDs may be used to transfer certain types of permanent files. It is recommended to look for gold or silver colored DVDs for the best quality. If transferring records that have been copied to a DVD from another media, agencies must transfer the premaster videotape and two copies of the discs. All permanent files must be on one DVD and not mixed with temporary files.

1.15.6.10.3  (03-27-2014)
Formats

  1. Records will be in a format that is not dependent on specific hardware or software, written in ASCII or EBCDIC with all extraneous characters removed (except records length indicators for variable length records, marks delimiting a data element, field, record or file, or Standard Generalized Markup Language (SGML) tags). Records should not be compressed unless NARA has approved the transfer in the compressed form in advance. If the records are in ASCII, the electronic files should have standard ANSI labels as specified in Federal Information Processing Standard (FIPS) Publication 79 and/or ISO Standard 9600. If the records are in EBCDIC, the electronic files should have standard IBM OS or DOS labels.

  2. Data files and databases shall be transferred as flat files or as rectangular tables, that is, as two-dimensional arrays, lists, or tables. All records in a database or elements in a relational database should have the same logical format. Each data element within a record should contain only one data value. A record should not contain nested repeating groups of data items.

  3. Textual Documents in electronic form should be transferred as plain ASCII files; such files may contain SGML or XML tags.

  4. Electronic mail, scanned images of textual records, portable document format (PDF) records, digital photographic records, web content records, and digital spatial data files should be transferred to NARA in accordance with requirements available at http:// www.archives.gov/records-mgmt/initiatives/transfer-to-nara.html.

1.15.6.11  (06-01-2010)
Transfer of Documentation to Support Permanent Records

  1. IRS offices must provide adequate technical documentation for each permanent electronic file identified for transfer to NARA. Adequate documentation contains enough information to allow the records to be interpreted and understood in context. The extent, format, and content of the documentation varies for different types of electronic records. The documentation for a text file differs from the documentation for survey data or statistical files and from that for indices or tracking files. Within the types of records, documentation can vary as well. One survey might have very different documentation than another survey. This subsection provides some guidance to IRS offices regarding the content and potential sources of adequate documentation for permanent electronic records.

1.15.6.11.1  (06-01-2010)
Sources of Documentation

  1. Information about documentation might be in publications, administrative reports, annual reports, memoranda, user notes, system guides, inventories or control systems for electronic records, file descriptions, Privacy Act notices, or manual or automated data dictionaries. The information about documentation is more important than the format.

1.15.6.11.2  (06-01-2010)
Format of Documentation

  1. Some of the documentation for electronic records may only exist in paper form. When the documentation is in electronic format, identify and transfer the documentation data as separate files along with the files containing the electronic records. The transfer format standards for electronic records also apply to documentation files. Microform copies of documentation, when available, are also useful.

1.15.6.11.3  (03-27-2014)
Scope of the Documentation

  1. Three main types of information make up documentation: technical specifications, information about file content and structure, and context. Provided below is more information on each type:

    1. IRS Form 12240, and/or required technical specifications adequate for servicing and interpreting each file.

    2. Each file requires a specific definition of its structure and content. This includes a record layout and a codebook for each field containing coded information. Documentation may be in data dictionaries, file, user, codebooks, file or system manuals.

    3. Contextual information explains how the electronic records fit into the IRS programs or mission. This information answers the questions: "Who created the Records?" and "Why?" and "For What Purpose?"

    4. If several data files containing related information are transferred, the documentation should include a description or diagram of how the files relate to each other. At a minimum, the documentation should specify the key fields, including primary keys, used to uniquely identify each record in a file, and the foreign keys, which relate records in one file to records in another file.

1.15.6.12  (03-27-2014)
Transfer Forms

  1. The forms required to transfer permanent records to NARA are set forth below:

    1. The Standard Form 258, Agreement to Transfer Records to the National Archives of the United States, (completed by the IRS Records Staff only – see Exhibit 1.15.5–1 for a sample).

    2. NA Form 14097, Technical Description for Transfer of Electronic Records to the National Archives, or its equivalent, IRS Form 12240, must be completed and provided by the program office for attachment to the SF-258.

  2. Contact your ARM or the RIM Program Office for instructions and assistance in completing the systems form and identification of other documents necessary for transfer of the electronic records.

  3. Submit the NA Form 14097, or its equivalent, IRS Form 12240, along with the identified documentation through your ARM to the IRS RIM Program Office for completion, approval and submission to NARA.

1.15.6.13  (03-27-2014)
Managing Records Stored on Electronic Media

  1. IRS offices must plan for the proper management of records stored on such media as CDs, DVDs, removable hard drives, audio/video tapes, and USB drives. These media types are considered fragile and susceptible to record modification, erasure, and damage. IRS must prepare for technical obsolescence when using such media.

  2. Storage of record material must be done in accordance with approved records dispositions. All functionally similar records should be stored together and standard naming conventions should be utilized to ensure faster retrieval.

  3. An inventory of all removal media must be maintained.

  4. All removable media must be properly labeled.

  5. All removable media must be stored under proper environmental conditions and all security precautions must be taken to protect information throughout the life cycle of the records.

  6. Information stored on removable media must be periodically reviewed for deterioration to ensure availability of record information.

  7. A migration plan must be established to ensure access to record information due to technological obsolescence.

  8. For more detailed guidance, see the RIM Program website.

1.15.6.14  (03-27-2014)
Use of Social Media and Collaboration Tools (New Media)

  1. IRS must plan for the proper management of record material produced using Social Media such as Facebook, YouTube, Flickr, MySpace, and other similar technologies.

  2. IRS must plan for the proper management of record material produced using Collaboration Tools such as Microsoft SharePoint, Microsoft Office Communicator, and any other instant messaging or collaboration environments (i.e. wikis, blogs, web portals, etc.). Collaboration may happen in multiple contexts such as Office to Office, Agency to Agency, Multiple Agency, or public to Agency (i.e. via interactive websites.)

  3. The following records management considerations must be addressed with the use of these new 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 Records Control Schedule.

    2. Records must be captured in an accessible, usable format.
      1) Most collaboration software and instant messaging clients reside on the Agency server and can be captured at the server level in either plain text or through the use of a DoD 5015.2 certified application, such as EMC Documentum.
      2) If the collaboration environment is not located on the Agency’s server, procedures for the capture of record material must be discussed with the vendor/owner of the software or tool.

    3. A responsible office/Agency must be designated for the management of record material. In some cases, more than one entity may have a responsibility for the same records, depending on their use.

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

    5. 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.

  4. For additional information and guidance, please contact the IRS RIM Program Office

Exhibit 1.15.6-1 
Common Questions about E-Mail

When are e-mail messages records?

An e-mail message is a record if:

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

b. it can be retrieved if you, or anyone else, need to find out what had been done, or

c. it can be used in other official actions.

Treat e-mail messages the same way you would treat paper correspondence.

Do I have to manage incoming and outgoing e-mail as records?

Yes, you should apply the standard described above to both incoming and outgoing e-mail. The reason is that both the sender and recipient of e-mail 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 e-mail message is a necessary part of that documentation or if it fills in gaps in other records series.

How can e-mail be an official record if it is not signed?

A signature does not make something 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.

If an e-mail 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 the message is a record in your office's official files, then the copy you print or maintain on your PC is not a record and you may delete or destroy it. If you receive a message for information purposes only and do not take any action related to it, your copy is not a record.

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.

Are there special requirements for retaining e-mail messages as records?

The basic requirements applicable to all records apply to e-mail records as well. If they are not in an approved electronic recordkeeping system, then the e-mail messages identified as records must be printed out and placed in the appropriate record system. However, there are some specific elements for records sent or received through e-mail which also must be captured in addition to the message to satisfy recordkeeping requirements. You should ensure that:

  1. the e-mail record includes transmission data that identifies the sender and the recipient(s) and the date and time the message was sent and/or received;

  2. when e-mail is sent to a distribution list, information identifying all parties on the list the list must be retained for as long as the message is retained; and

  3. if the e-mail system using codes, or aliases to identify senders or recipients, a record of their real name(s) is kept for as long as any record containing only the codes or aliases.

    Example:

    If you are communicating with someone via the Internet and their e-mail address does not indicate who they are (e.g. the address is JerryR@ …) then a record must be made and kept with the message of who they are. If the message is to be kept electronically, this can be done by including their full name, title, and organization in the body of the message. If the message is printed out, then make a similar notation on the bottom of the message.

Why is it necessary to keep the transmission data about the sender, receiver, date, and time of the e-mail?

This information is essential, the same as the names of the sender and addressee, the date, or a time stamp from a letter, memorandum or envelope on paper. You would not delete this information from those documents.

What if the message does not qualify as a record?

Delete e-mail that is not a record when no longer of use.

Example:

An e-mail message advising section employees of a staff meeting or a training opportunity can be destroyed after it has been read, or the meeting/training period has passed.


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