3 Requirements to Follow for Federal Record Storage

When it comes to records management, federal government entities have obligations above and beyond standard businesses. For example, they are required to follow specific United States laws and regulations pertaining to federal record storage. 

The full scope of regulations pertaining to federal record storage is quite sizable. It is detailed in full in Title 36, Chapter 12, Subchapter B of the Code of Federal Regulations (CFR), as well as the website of the National Archives

However, the extensive number of regulations can be distilled into three key federal record storage principles that are most important for federal government organizations to follow.

1. Preservation

The first principle for federal record storage is preservation. Most records possessed by federal agencies are subject to Freedom of Information Act (FOIA) requests and must be retained and accessible for a set period of time, depending on the type of record. 

These retention periods are set out in standards known as General Records Schedules (GRS). The GRS contains information about how long records (both digital and physical) should be stored for possible use. Each federal agency has its own GRS, and most state, county, and city governments have their own GRS as well. 

For example, per page 17 of the GRS, a federal entity’s budget reports can be destroyed when five years old, but longer retention is authorized if required for business use.

Per page 53, medical records may be destroyed ten years after the most recent encounter with the patient, but, again, longer retention is authorized if needed for business use.

Failure to comply with GRS preservation standards is a federal offense, and it can lead to fines, imprisonment, or both.

2. Safety

The second principle for federal record storage is safety. The National Archives website says, “To manage your records in storage and ensure that they will be available, if needed, for Federal Government business, you must store your records in a safe and non-damaging facility.”

There are extensive requirements for what constitutes a safe and non-damaging facility, but to summarize these requirements, a building that is designed for federal record storage must have adequate protection against:

  • Vermin
  • Fire, flooding, and other natural disasters
  • Mold and other hazardous materials
  • Unlawful or unauthorized entry or admittance
  • Unlawful or unauthorized removal of records

This is by no means an exhaustive list. Still, in sum, a federal record storage facility must be able to ensure that the records kept there remain safe from the elements and unsanctioned human interference. 

These requirements also apply to storing physical hardware (e.g., servers) in which electronic records are stored, and electronic records need to be kept both intact and safe from external stimuli that could damage their contents (e.g., malware or viruses).

3. Sustainability 

The third principle for federal record storage is sustainability

In this context, “sustainability” refers to “the ability to access an electronic record throughout its lifecycle, regardless of the technology used when it was originally created. A sustainable format is one that increases the likelihood of a record being accessible in the future.”

For example, an electronic record that can only be opened by a specific software that is no longer being updated or that only works on a specific type and age of machine would not be considered a sustainable format. 

For example, documents that are stored on 3.5-inch floppy disks. Those documents are only accessible to people who have computers with the appropriate disk drives – almost unheard of in 2022. 

If electronic records are in an unsustainable format, the National Archive continues, this “may cause Federal records to become obsolete and inaccessible before they are eligible for deletion as authorized in the approved records schedule” – which, as mentioned previously, could constitute a federal offense. 

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