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Records Management Program <[log in to unmask]>
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From:
"Schildmeyer, Greg" <[log in to unmask]>
Date:
Mon, 13 Dec 2004 17:11:12 -0600
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Records Management Program <[log in to unmask]>
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You all are getting this really confused.  I'm seeing several conflicting
citations here.  Let me see if I can shed some light on this.

First of all, you appear to be referencing two different series of records,
and apparently confusing them.  One description is for pre-employment
background checks, which every Federal employee would undergo at the time
they are hired, and which are typically fairly routine.  The other is
investigations for a security clearance (Secret, Top Secret, Q, etc.) which
is more extensive and only for employees, applicants, or contractors who
would need access to sensitive data or facilities.

The link that was provided as being GRS 18, Item 22 actually went to the
Bureau of Land Management records schedule, which is a nice record schedule
in itself, but not the authoritative GRS.  The actual NARA GRS 18 link is
http://www.archives.gov/records_management/ardor/grs18.html.  Item 22 does
deal with Security Clearance investigation records.  I was unable to find,
either under GRS 18 Security, GRS 1 Personnel records, or any other GRS, a
series describing Pre-employment background check records.  NARA seems not
to have provided this.

Department of Energy, however, has included an item dealing with these
pre-employment background investigations in its agency records schedule.
Agencies are free to do this when the GRS does not meet their needs for some
reason.  This is item 21.3 in their schedule at
http://cio.doe.gov/RBManagement/Records/PDF/RS-DOEADM18.PDF.  The next item,
22, deals with the Security Clearance investigations, and mirrors the NARA
GRS.  They're two different kinds of records.  If one reads the dispositions
of these two different series in the context of how each is created and its
purpose, the dispositions make logical sense.

I hope this helps.

Greg Schildmeyer
Director of Records Management
State of Missouri
(A former Fed)

-----Original Message-----
From: Roach, Bill J. [mailto:[log in to unmask]]
Sent: Monday, December 13, 2004 4:21 PM
To: [log in to unmask]
Subject: Re: records on background checks


>>The GRS citation I gave was for HIRED AND EMPLOYED individuals, which
is GRS 18/22a...There is no DOE Schedule for these documents, I've
checked time and time again... that's why we cite the GRS requirement.<<

The DOE Administrative schedule states:

>>(If applicant is hired, the pre-employment investigation file is
transferred to the person's personnel security file).<<

The next item in the Administrative schedule, item 22 identifies the
retention timeframe for the records of those hired:
"Personnel Security Files document the processing of individuals for DOE
access authorizations (security clearances), regardless of whether
access authorizations are granted. These files may include copies of the
following: pre-employment investigations; requests and justifications
for access authorizations, security forms,
reports of background investigation(s); personnel security interview
transcripts and/or summaries (including the audio cassettes), case
evaluation sheets, security incident/infraction report forms;
correspondence with the individuals, the individuals' employers, and
other agencies; security badge information, medication evaluations,
security termination statements, and other material relevant to the
access authorization process. (SF-312s are related to "access" and
should not be maintained in the individual's Security File.)

Cut off file upon termination of authorization processing, when access
authorization is terminated, or when the contract relationship expires.
Retire inactive records 5 years after cutoff. Destroy not later than 10
years after date the individual's authorization is terminated or upon
notification of death of the individual, which ever is sooner.

(NOTE: Prior to destruction, remove the individual's Personnel Security
Questionnaire or equivalent document and retain it for 75 years after
the date the individual's authorization is terminated. These documents
will be used for the Health and Mortality Study.)"

I read these to be DOE requirements.  What am I missing?

Bill R

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