(U) DO also accumulates files on organizations in which CIA has a foreign intelligence or a foreign counterintelligence interest; general subject files on activities of intelliaence interest, which are referred to as Operational Interest or OPINT files; and files on intelligence operations, which are termed Operational Activity (OPACT) or Project files. OPINT files are approved for selective retention while the basic files on each operational activity are permanent. At specified intervals, the DO reviews both series prior to their final disposition. The latter activity includes the screening of OPACT files to remove and destroy documents that are duplicate and/or non-record and the review of disposable OPINT files to identify and retain documents of continued interest to CIA. Because of the significance of the records, extended discussion of this process is warranted.

(U) The DO's screening activities are carried out by DO annuitants who work on behalf of a specific DO component, usually the one in which they served during their career in the DO. As they begin work as reviewers, annuitants are provided with a three day course on DO records and recordkeeping practices. However, they are trained primarily on-the-job by supervisory personnel who work closely with new staff.

(U) Screening files is consistent with N1-263-87-2, the DO schedule approved by NARA in 1989. Item 3a of this schedule calls for the permanent retention of all Project Files, including documents relating to their objectives, development, and implementation. Item 3b, however, authorizes CIA to review Project Files and destroy duplicates and other non-record material when no longer needed. Similar disposition instructions apply to Operational Interest Files.

(U) NARA reviewed several sample files, including documents from two files which DO reviewers had earmarked for disposal. Materials screened out as temporary consist primarily of copies of intelligence reports, which are retained permanently in another series, and routing slips that do not contain substantive information. Other temporary materials include routine administrative papers that are not deemed necessary to document the subject of the file as well as transmittal memorandums for attachments filed elsewhere and reference material relating to the main subject of the file that is readily available in other records.

(U) Removing materials of this sort can result in substantial reductions in the volume of individual files, down to only a small fraction of their original size in some cases. However, based on the samples examined and the explanation of the process provided by DO staff, it does not appear that the DO's screening activities are resulting in the disposal of significant documents. DO staff insist that reviewers err on the side of preservation when there is any question as to whether documents should be retained. Reviewers are also encouraged to consult with the agency's History Staff in such instances.

(U) NARA is nevertheless concerned that the DO has not developed any written screening criteria for reviewers to use. This could result in the improper disposal of valuable records, especially since the wording of the relevant schedule items is extremely broad and imprecise. NARA is also concerned that some of the materials typically screened from files are not, strictly speaking duplicate or non-record but instead are records. Even if documents pertaining to routine administrative matters may not warrant permanent retention, they are records that may be disposed of only in accordance with a NARA-approved records disposition schedule.

(U) At the very least, a revised schedule for operational records that provides more specific guidance regarding the types of materials to be screened out is in order. CIA recognizes this and has asked for NARA assistance in developing updated disposition instructions for these records. In implementing this project, NARA will re-evaluate the screening of these records as it has traditionally been carried out by DO staff. NARA's review will address whether the benefits of screening as it is now carried out outweigh the advantages of retaining operational files intact or limiting screening to multiple copies of the same document'and other materials that clearly are valueless. Destroying the copies of intelligence reports included in operational files may make research cumbersome for those interested in specific operations, even if the reports are available in other files. In addition, these reports and the other documents that are typically screened out of the files may add contextual information to the documents that typically are retained. As a result, screening may decrease the overall value of the series even if the documents removed from files lack value individually.

(U) After a revised schedule is approved, it should be used as the basis for written guidance to those who review operational files. This guidance should be included in the three day training that newly rehired annuitants are given and explained to those already on-board.

(U) Recommendation III/2: Submit schedules for all unscheduled series, including series where records are now maintained electronically, particularly permanent series where paper documents are no longer printed out and filed.

(U) Recommendation III/3: Ensure that all staff are familiar with the schedules that cover the records they accumulate.

(U) Recommendation III/4: Work with NARA in the development of a revised schedule for DO operational project files; use this schedule as the basis for written guidance that is provided to those who review and/or process older operational files.

(U) Working Papers and Chronological Files

(U) Two other problem areas were noted in some of the offices visited. The more serious and common of the two was a tendency on the part of some staff and/or agency components to inappropriately regard their files as non-record working papers or "soft" files that could be destroyed at will. A second problem NARA noted was the filing of incoming documents and other materials in disposable chronological files. Each of these is discussed below in more detail.

(U) Working Papers

(U) CIA offices and individual agency staff members accumulate such transitory materials as copies of documents used for convenience of reference, rough notes and drafts that were not circulated and contain no unique information of continuing value, and materials of an ephemeral nature, such as memos that change the time or place of meetings. These materials need not and should not be retained after their purpose has been served.

(U) Staff should be aware, however, that working files are records and may contain documents that warrant retention in order to ensure adequate and proper documentation of agency policies and actions. Documents falling into this category include but are not limited to drafts that were circulated for review and approval, intra-office memorandums that result in substantive changes to reports and other issuances, and notes taken at meetings that are the only documentation of what transpired. Staff should be made aware of the record status of working papers.

(U) During evaluation visits, NARA observed that in some offices staff re ard working files as non-record material to be disposed of at will. In some cases, this may not pose a serious problem. For example, as will be discussed at greater length in Chapter V, the files on specific operations and individuals accumulated at the CIA field sites NARA visited appear to be duplicates of files maintained at Headquarters. However, in other instances treating working papers as non-record materials that are invariably destroyed could lead to the inadvertent destruction of permanent files. For example, in the Office of Weapons, Technology, and Proliferation, an important document pertaining to a major office reorganization was located in a working file. This may be due to the improper use of the working paper designation. This office had not identified any permanent policy files for the past two years. In the DO office which maintains files on individuals and organizations of foreign intelligence and foreign counterintelligence interest to CIA, staff noted that on occasion they receive documents for filing that were found in the working files of DO desk officers who have left the agency or moved on to other assignments.

(U) NARA also noted a few instances in which an office viewed its files as non-record working papers because another office had primary responsibility for the matters to which their files relate. A DS&T component responsible for providing certain clandestine services regards requests for assistance as non-record working files because the information is preserved electronically and is also available in DO files. The office also regards as non-record work papers the files accumulated in connection with its participation in an intra-agency team because another office maintained the team's permanent records.

(U) CIA already has published guidance in place that adequately addresses the status of working papers. Nearly all of the organization-specific schedules CIA submitted in the 1975-1977 period contained items authorizing the disposal of working papers. These authorities were consolidated and standardized in Item l8a of Disposition Job NC1-263-85-1, the generic, agency-wide schedule NARA approved in 1985. This schedule item covers working papers and duplicates of documents and miscellaneous papers not covered elsewhere and calls for the annual screening of these files. After screening, duplicate and transitory information may be destroyed. However, substantive documents are to be placed in the appropriate official file.

(U) The agency regulation entitled "Creation of Agency Records," issued in February, 1997, specifically addresses working papers. Paragraph 2b(2)(a) specifies that drafts and working papers at the Deputy Director level will be filed in recordkeeping systems. At lower levels, drafts and working papers that were coordinated outside the unit of origin or contain information documenting substantive policy development, actions, or decision making are also to be filed in recordkeeping systems with the final version of the document to which they relate. The only working papers that need not be filed in a recordkeeping system are those accumulated below the Deputy Director level that were not coordinated outside the work unit and do not reflect substantive matters. This issuance also mandates the filing in recordkeeping systems of documents received in agency offices if they contain information that impacts on the business of the receiving organization.

(U) Additional guidance on drafts is available in a pamphlet on "What is a Record?" provided to new employees as of January 1995. This issuance instructs staff to preserve drafts circulated for comment outside of the "primary work unit" if the comments "become the basis for how the draft takes its final form," and particularly "when drafts contribute to the development and understanding of policy and decision-making."

(U) CIA must ensure that staff become aware of these requirements and implement them properly. These requirements also should be incorporated into the working papers item included in the full text CIA schedule; at present, it merely calls for filing "substantive documents" included in working papers in the appropriate official file and provides no additional guidance.

(U) Recommendation III/5: Ensure that all staff who create or maintain records are familiar withand properly apply existing agency guidance pertaining to what is a record and the record status of working files, particularly the relevant portions of the regulation entitled "Creation of Agency Records"; modify the description of working papers included in agency schedules so it incorporates the guidance contained in this regulation.

(U) Chronological Files

(U) Disposition Job NC1-263-85-1, Item 16, authorizes CIA to destroy chronological ("chron") files after a short retention period based on the assumption that these records consist solely of chronologically-arranged outgoing documents, copies of which are filed elsewhere along with any related incoming, correspondence and background materials. This disposal authority, as incorporated into the schedules used in each CIA directorate and its component offices, defines chron files as duplicates of correspondence retained for ready reference and notes that the subject file copy is the record copy.

(U) However, in a few of the offices NARA visited, agency personnel treat as short-term chronological files materials that should be filed in permanent or longer-term policy or subject file series. For example, many of the basic records of the DI's Office of Weapons, Technology, and Proliferation are maintained in a chron file, which is screened for permanent documentation at the end of the year. A chron file held by the Directorate of Science and Technology was, in reality, a subject file pertaining to budget matters. NARA also found that several offices' chron files were used as finding aids to substantive policy and program records.

(U) Using chron files for substantive materials above and beyond copies of outgoing documents that are also filed in policy or subject file series clearly can result in the improper disposal of files. Screening chron files at the end of the year to extract policy documents is not an effective or efficient mechanism for ensuring the continued retention of such materials. Chron files that are used as finding aids should be treated as indexes and disposed of or retained in accordance with the disposition instructions for the records to which they relate, as called for in NC1-263-85-1, Item 1e.

(U) Recommendation III/6: Treat as chron files only copies of outgoing correspondence maintained for ready reference. Chron files that are used as finding aids to other records should be disposed of or retained as indexes in accordance with NCI-263-85-1, Item le.

(U) Agency Records Center (ARC) Disposition Activities

(U) As noted in Chapter II, since 1951 CIA has utilized an agency records center to store its inactive permanent and temporary records prior to final disposition. The ARC destroys temporary records whose retention period has expired. Ninety days prior to the scheduled date of destruction, notices of intent to destroy records are generated using a mail-enabled database application within Lotus Notes. Notices are sent to the appropriate component IMO as well as to the directorate IMO, the agency General Counsel, the Inspector General, and the History Staff. All these offices must concur before the ARC carries out the destruction.

(U) In addition, since September 1995, a board, which is chaired by the agency IMO and includes representatives from the directorates as well as a History Staff representative, meets on a quarterly basis to discuss records disposition issues. This group also reviews notices of intent to destroy records at the ARC and related folder lists and records retirement paperwork. The CIA historian who works with the board believes that the vast majority of the records center accessions reviewed (ca. 95 percent) are appropriate for disposal. However, he has found that working files may sometimes contain unique information of historical value. He also noted that in some instances, permanent material was intermixed with temporary records.

(U) It would appear that ARC holdings that are earmarked for destruction are, in the main, properly scheduled and that CIA has initiated procedures to ensure that records improperly coded as temporary will be preserved. CIA itself has determined that many "permanent" ARC accessions are improperly scheduled and has initiated a project to deal with this problem so that preservation action will be taken only on records that are, indeed, permanent (see Chapter II). Initial work has concentrated on files retired by OIT and its predecessors that pertain to records management.

(U) CIA should continue this project and extend it to the records retired by other directorates and components where significant mis-schedulincg, is suspected. CIA should also use this effort as an opportunity to determine if there are gaps in the ARC's holdings of permanent records (no holdings of series earmarked for retirement, missing chronological blocks, etc.) and take appropriate follow-up action (contact program offices, examine accessions retired as temporary, etc.). This work should be carried out in close concert with NARA to ensure against their advertent disposal of permanent records and to avert public misperceptions about the project. NARA has already reviewed some "permanent" accessions identified for disposal and has concurred in nearly every instance with CIA's evaluation that the files were indeed disposable.

(U) Recommendation III/7: Continue the project to apply correct schedule items to ARC accessions improperly retired as permanent; include NARA review as part of the process

(U) Transfer of Permanent Records to NARA

(U) Until 1980, CIA schedules did not include any instructions as to when permanent series would be transferred to NARA's legal custody. CIA acknowledged that NARA would eventually accession permanent CIA records but these early schedules stated that the time of transfer would be determined at a later date. Disposition jobs approved from 1980 to 1989 called for the transfer of permanent records to NARA "when national security considerations permit" (except for certain unclassified records of the DS&T component responsible for open source collection; these records are to be transferred when 10 years old). In the late 1980s, NARA pressed CIA for more precise transfer instructions, and in 1988 CIA adopted the wordingthat has been used ever since: "Transfer to the National Archives when 50 years old, pending CIA determination that continued Agency retention is not required." This approach established 50 years as the basic time frame for transfers but allowed the CIA to retain files of especially great sensitivity as well as records for which the agency still had an operational need.

(U) In light of the standard transfer instructions for CIA records, it is not surprising that NARA has accessioned relatively few CIA textual series, totaling in the aggregate ca. 1000 cubic feet. About half of these records are unclassified reports prepared by the DS&T component responsible for open source collection. NARA also has accessioned monographs prepared by the CIA History Staff as well as certain of the background files this staff utilized. Other transfers, particularly the most recent ones, consist in the main of copies of documents that deal with matters of high research interest that have been subjects of conferences sponsored by the Agency's Center for the Study of Intelligence. These collections deal with such subjects as the CIA's role in the Cuban Missile Crisis, the development of the agency during the Truman Administration, and the estimates of Soviet strength prepared at the height of the Cold War. Most of these records consist of sanitized copies of individual documents, often drawn from many separate record series. Even the most comprehensive of these collections, the Soviet estimates, consists solely of copies of the final estimates themselves, not the related background papers that document their formulation.

(U) With the end of the Cold War and the U.S. Government's commitment to openness, CIA retention of permanent files for 50 years is no longer appropriate. The time of transfer for most CIA series should be reduced, particularly for non-textual records and electronic systems where the lengthy period of retention poses preservation problems. Permanent records should be transferred in coherent blocks (i.e., chronological segments of record series), not individual documents drawn from a variety of separate files. All documents in the series (or chronological segment thereof) should be transferred, including those that still must be withheld in their entirety as well as the originals of documents that are releasable only with redactions. (Transfer procedures should also take into account CIA's plans to scan its classified records and carry out declassification and redaction on the electronic version of documents only; see Chapter IV for additional information concerning this project and its implications.)

(U) Transferring records by series is essential if NARA is to achieve proper intellectual control over its permanent holdings and also to meet the needs of researchers who want access to coherent blocks of organizational records, not artificially-created collections. Likewise, it is a near universal practice for agencies to transfer entire series, including documents that still cannot be made available to the public. NARA has secure storage areas for sensitive records and staff with the requisite security clearances to handle them. CIA's current practice of withdrawing still-sensitive records prior to transfer entails added processing costs when records are eventually accessioned and also increases the possibility that some documents may be inadvertently lost or misfiled.

(U) As outlined above, 50 years after CIA's creation NARA's holdings of CIA records are skimpy and unsystematic. This situation inhibits access to historically important information and subjects the Executive Branch of Government to criticism. In addition to developing updated generic transfer instructions for permanent series, NARA and CIA must work together to develop a plan and timetable for the transfer of specific records in the near term. The goal of this effort should be the accessioning into the National Archives by the end of 2003 of most permanent CIA files that were cut-off prior to the inauguration of President Kennedy in 1961, particularly files accumulated at high levels within the agency (e.g., files of the DCI), finished intelligence products and related background papers, and files of offices concerned with budgetary matters, legal issues, and congressional relations. This will, for the series accessioned, bring CIA transfers closer to the 30 year line that is the norm for defense and national security agencies. Based on its experience with this transfer, NARA can, approximately five years from now, develop a plan for the transfer of records accumulated during the Kennedy and Johnson Administrations.

(U) Recommendation III/8: Work with NARA to develop transfer instructions for permanent records that reduce the age at which CIA records are typically accessioned by NARA and provide for the transfer of entire series (or chronological segments thereof). Take into account CIA plans to review files for declassification electronically.

(U) Recommendation III/9: Work with NARA to develop a timetable for the transfer of specific files to the National Archives, with the goal of transferring by the end of 2003 most permanent files cut-off prior to 1961.

(U) CHAPTER IV: AGENCY-WIDE ELECTRONIC RECORDS MANAGEMENT

(U) PROGRAM REQUIREMENTS

(U) Develop and implement an agency-wide program for the management of all records created, received, maintained, used, or stored on electronic media;

(U) Develop and maintain up-to-date documentation for all electronic records systems;

(U) Develop and secure NARA approval of records disposition schedules for electronic records and ensure implementation of their provisions; and

(U) Integrate the management of electronic records with other records and information resources management programs of the agency.

(U) At present, CIA does not have a regulation that addresses electronic recordkeeping per se. Rather, several agency records management regulations promulgated early in 1997 address various aspects of this issue. The introductory paragraph of the agency regulation entitled "Information and Records Management Program," which establishes CIA's overall information management program and provides its broad outlines, specifies that this issuance "applies to all records and information regardless of their media." The agency regulation entitled "Creation of Agency Records," explicitly includes e-mail, word processing documents, spreadsheets, and databases among the record types that must be managed in agency recordkeeping systems. This regulation further specifies that electronic recordkeeping systems must be inventoried and holds program managers responsible for "defining migration strategies" when electronic information systems are in the planning phase.

(U) The agency regulation entitled "Maintenance of Agency Records" mandates the maintenance of records, regardless of media, in a retrievable and readable format through out their life cycle. This regulation also states that the agency will adhere to NARA's guidance regarding electronic records, as contained in 36 CFR 1234, and requires migration plans and the creation and maintenance of "clear and thorough" systems documentation to ensure that records can be read and retrieved and their approved dispositions can be carried out.

(U) An agency regulation entitled "Disposition of Agency Records" calls for the transfer of permanent records to NARA in accordance with NARA media standards or other agreements made between NARA and CIA. This regulation re-states requirements contained in other records management regulations concerning the need to migrate electronic records and create and maintain sufficient system documentation.

(U) The issuances outlined above are consistent with NARA guidance and provide an adequate regulatory foundation for the management of CIA electronic records. It should, however, be noted that prior to 1997, when these regulations were issued, there was no guidance in place that specifically addressed electronic records, although the general definition of records used by CIA included electronic media. The lack, until recently, of guidance that deals with issues unique to electronic records may account for some of the problems discussed below.

(U) Recent Initiatives to Strengthen the Program

(U) In June 1994, CIA's Office of Inspector General (IG) Office issued a report recommending that the Office of Information Technology (OIT) assert a stronger central leadership role in electronic records management. This recommendation stemmed from problems the agency had experienced in responding to Congressional requests for information. Instead of being able to quickly obtain the needed data using automated agency-wide indexes and abstracts, staff were forced to devote a great deal of effort to searching, at times in an uneven and duplicative fashion, a wide array of files. These files included electronic systems, unscheduled local servers, and miscellaneous collections held in individual offices and the Agency Records Center (ARC).

(U) The IG attributed the problems outlined above to a lack of a coordinated agency records management program with top level support, particularly in the area of electronic recordkeeping. The IG report stressed that OIT needed to adopt a broad perspective covering all aspects of records and information management, as opposed to its traditional more narrow focus on technology and related technical issues. This report also called for the development of an agency-wide strategic plan for information systems so that CIA could deal in a credible and efficient manner with internal and external information needs.

(U) As a follow-up to the IG report, the Associate Deputy Director for Administration for Information Systems (ADDA/IS) has issued the "Information Systems Strategic Plan." This plan calls for business process re-engineering in the automation area and has as its ultimate goal the maintenance of all CIA recorded information in an electronic format within an electronic recordkeeping system. To accomplish this, the plan requires the coordination of all records and information management activities and re-engineering, the entire records management process within CIA, while at the same time ensuring that access to sensitive information is restricted to those with a need to know.

(U) Electronic Records Management Program Office (ERMPO)

(U) In addition to the strategic plan, another major result of the IG report was the creation within OIT of the Electronic Records Management Program Office (ERMPO) in July 1995. ERMPO is intended to serve as a proactive, component-wide focal point for electronic records management and planning. This new program office provides guidance to directorate and component IMOs and other Points of Contact (POCs) in the electronic records management area and coordinates their activities. ERMPO was not, however, assigned responsibility for developing the CIA's internal electronic mail regulation. Instead, staff assigned to the Director of Information Management worked with the Directorate of Administration's Office of Communications to develop this directive. It was issued in February 1997. ERMPO also is directing the development of several shared information systems which will have a major impact on agency operations and recordkeeping and, ultimately, on NARA (these systems are discussed below).

(U) ERMPO has had mixed success. On the one hand, it has missed several self-imposed deadlines; it has not been able to release its products on schedule nor has it completed an agency-wide inventory of electronic systems. On the other hand, it has underway significant new systems that will, if implemented successfully, change agency recordkeeping in major ways. As CIA's electronic records program expands, ERMPO's role will likewise grow.

(U) Major Electronic Systems Under Development by ERMPO

(U) ** PERM-- Pro-active Electronic Records Management

(U) CIA officials foresee PERM becoming the electronic repository of agency records by FY 2002. PERM will accept data originating in a variety of existing agency systems. As they enter PERM, the record copies of electronic documents will be centrally captured and managed by creating tags containing such data elements as: document type; content and content-related information drawn from a controlled list of subject headings included in an agency file guide; disposition instructions; and security classification. The system will collect and display as much information as possible concerning each document from the time of creation or designation as a record through its migration to PERM. It will automate records creation and maintenance as well as document retrieval and will also provide an audit trail to monitor access to restricted information.

(U) The first phase of PERM's development has focused on electronic mail, which is used throughout CIA and has high visibility government-wide at the present time. Furthermore, CIA regards e-mail as the electronic record type that is easiest to deal with from a technical standpoint. Although CIA has a successful e-mail delivery/maintenance system, PERM is not able to function as an electronic records management system. It does not yet have the functionalities the latter must address, particularly in the area of determining whether or not individual messages have record status.

(U) Phase Two of PERM will focus on Microsoft Office Suite products (e.g., Power Point), word processing, spreadsheets, etc. Phase Three will address information systems such as cable messaging systems and administrative information systems. In the short run, CIA envisions PERM providing such benefits as the ability to conduct thorough searches of electronic documents to locate specific. records and information and to create a variety of statistical reports (e.g., the number of classified agency documents, the number of documents eligible for declassification review, etc.). In addition, PERM will explicitly impose responsibility for records-management actions on each records creator (e.g., assignment of record status and disposition instructions to documents). In the longer term, CIA believes PERM will eliminate the need to retrospectively scan and apply optical character recognition (OCR) processing to existing hard copy documents. It will provide automated "alerts" as documents become eligible for declassification review and will enable the agency to be more confident that the results of document searches are complete. Finally, PERM will simplify issues arising from the need to migrate electronically maintained information, but only to the extent that it incorporates other databases and office automation applications, supersedes other operating systems, and becomes the system of record for CIA's electronic records.

(U) At present, CIA's systems development plans for PERM do not include a fully developed migration strategy which complies with NARA regulations. To comply with 36 CFR 1234, the CIA must begin to address migration within the context of life cycle planning for electronic records system design and implementation, especially to provide a clear path for migrating to the next application or platform information that must be retained when an existing system is superseded. The very nature of PERM poses this issue quite clearly. It is an application within Lotus Notes, a proprietary software widely used throughout CIA. Absent an appropriate migration strategy, it will be difficult over time to assemble the requisite software, documentation, and metadata to support and interpret data for future use. Yet in the future CIA must be able to access current and non-current information that is required to meet its operational needs.

(U) **SMART-- Space Management and Retirement Tracking

(U) The Space Management and Retirement Tracking (SMART) system is a second significant system ERMPO is developing. The impetus for SMART stems from a plan to consolidate multiple aging legacy systems used to track agency hard copy records. Some employees indicated to NARA that problems CIA experienced in retrieving information in order to respond to Congressional inquiries, particularly in regard to covert activities, also contributed to the decision to develop SMART.

(U) SMART incorporates the functionality of pre-existing systems, particularly those used at the ARC, and is designed to track objects, specifically hard copy records, at the box, folder, and/or document level. It is intended to automate the retrieval process by utilizing, a bar code system for box, folder, and document-level control. SMART also will include disposition information. A SMART sub-system pertaining to records retirement became operational in July, 1997, but other elements of the system have not yet been implemented, Because SMART was specifically designed to track hard copy objects, it is not fully integrated into the overall agency electronic records plan. At present, there are no guidelines for entering information into SMART about magnetic or other nontextual special media CIA uses to store or transfer electronic information. These deficiencies need to be corrected as soon as possible.

(U) **MORI-- Management of Officially Released Information

(U) Entry, storage, and retrieval of classified full-text versions of released documents;

(U) On-line image editing and redaction;

(U) Automated case management with distributive workflow capabilities; and

(U) On-line database of decision support materials to provide information which would support declassification decisions.

(U) The tracking system portion of MORI will capture the subject(s) of the information CIA releases, to whom it was released, how much was released and withheld, and why any withheld information wasnot releasable. This, CIA believes, will ensure a complete audit trail on all releases and ensure that agency security concerns are met.

(U) MORI was funded as an agency-wide initiative in FY 94 to "improve the Agency's ability to systematically, rapidly, and thoroughly search and retrieve information stored in its files and databases ... [and to] provide a central database of all officially released unclassified agency information." This project stemmed from an internal Agency task force, the MORI Task Force of 1994. Special collections already entered into MORI include documents relating to CIA actions in Guatemala, the so-called October Surprise of 1980, the assassination of President Kennedy, and the exposure of U.S. troops to toxic agents during the Gulf War. In addition, the collections included in two legacy systems, the Officially Released Information System (ORIS) and the Information Privacy System (IPS) have already been converted into MORI in their entirety.

(U) Phase One of MORI is Document Management, the entry into the system of individual documents, either through direct electronic entry or the scanning and OCR processing of hard copy. The use of these two techniques will permit MORI to display and print any document in the system. The system allows full text searching for keywords or structured queries for specifictopics, dates, or names.

(U) Phase Two of MORI is Case Management. The most significant aspect of this phase is the capability for on-line review, analysis, and redaction of individual documents, eliminating the need to copy paper documents, block out portions that are not yet releasable on the copy, place appropriate markings on the original, and then produce a public release copy with any still-sensitive information excised. CIA believes this will speed the review and redaction process and enable the agency to produce redacted public use copies of documents in which the information that has been excised cannot be restored by the requestor. Phase Two, through integrated query and reporting functionalities, will also enhance CIA's ability to track and monitor the status of requests. In Phase Three, Workflow, distributed tasking and coordination capabilities will be developed.

(U) It is the CIA's intention to retain the electronic version of the information included in MORI generally for 25 years. Paper documents will be returned to their original file series after scanning, and, if permanent, will eventually be transferred to NARA. CIA has no intention, once documents have been reviewed on-line, to segregate or otherwise identify original paper documents that still require protection. Nor will CIA redact original documents that contain information that must remain classified.

(U) To the extent MORI is used for the declassification of permanent records under the RDP, the system has significant implications for CIA and NARA, particularly as to when and how permanent records may be transferred to the National Archives. Many of the records reviewed under the RDP will, by virtue of their age, be appropriate for immediate transfer to NARA, particularly if transfer dates are reduced as has been proposed in Chapter III of this report. Unless CIA segregates or otherwise identifies information that still must be protected, NARA cannot make the original paper records available to researchers when the are accessioned since NARA does not have the resources to go through files to remove and/or redact documents that are not yet releasable in their entirety. If, however, CIA wishes NARA to consider accepting as the medium of transfer the scanned images and/or electronic text resulting from OCR processing, as maintained and redacted on MORI, then the storage, retrieval, and transmission of this data must be consistent with standards developed for use throughout the intelligence community. RDP managers are actively taking part in the government-wide Declassification Productivity Managers Council, including its Automation Working Group, which is seeking to develop such standards.

(U) As MORI becomes fully operational, CIA must ensure that specific review projects undertaken under the RDP encompass all the records in an entire series (or chronological segment thereof), as opposed to individual documents. Only if all records in a series are converted can data in MORI be transferred to the National Archives, even if the electronic product meets yet-to-be-developed community-wide standards acceptable to NARA. The sole exception would be items in a series that cannot be scanned, such as oversize (bulky) enclosures. This whole series approach to document conversion has already been utilized in CIA in a system adopted by the DO. As discussed in Chapter III, all records in a series (or chronological series segment) should be transferred to NARA, including documents containing information that cannot yet be declassified.

(U) Electronic Mail

(U) In February, 1997, after evaluation visits were completed, CIA issued an agency regulation which provides guidance to agency personnel on the use of e-mail. (This regulation replaces several earlier issuances relevant to e-mail promulgated by individual components.) CIA's e-mail guidance states that all electronic messages are records, except those that "clearly fall within the category that is defined as non-record material and must be filed and maintained in accordance with NARA-approved disposition schedules. The regulation further specifies that unless an electronic recordkeeping system is in place, e-mail messages that are scheduled for retention for more than 30 days should be printed to paper and filed appropriately. Originators of e-mail messages are responsible for determining record status and assigning the appropriate file category. Other than referring users to component IMOs for guidance, the regulation does not indicate what types of messages might fall into the non-record category.

(U) Additional e-mail guidance is contained in the other agency records management regulations that were issued early in 1997. CIA's "Creation of Agency Records" regulation specifies that receipts for e-mail messages will be created and maintained when necessary and also calls for the maintenance of distribution lists for record e-mail messages in a manner that ensures that addressees can be identified. This issuance also tasks program managers with determining when the creation and maintenance of e-mail message receipts is needed.

(U) CIA's recently issued e-mail regulation and the relevant sections of other recent regulations are thorough and consistent with NARA guidance. NARA suggests two additions. The e-mail regulation should specify that encrypted messages that must be retained in a recordkeeping system (i.e., more than 30 days) should be stored in an unencrypted form to ensure that the information can be accessed. Also, if CIA staff use the calendaring function included in LOTUS Notes, it should incorporate into its guidance the requirements contained in 36 CFR 1234.24(a)(5).

(U) Recommendation IV/3: 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.

(U) Lack of Inventories and Schedules

(U) Many in CIA believe that electronically maintained information is not a record or if it is a record, it is almost invariably disposable. They also believe that when the retention of electronic data is required, it can and should be preserved in a hard copy format. For example, as discussed above, the DO has made major strides in electronic recordkeeping. However, its current issuance on the subject, a DO instruction entitled "Managing Electronic Records," calls for the creation and filing of paper or microfilm as the mechanism for preserving record information contained in automated working files. As has been noted, DO believes all of its databases are either covered by the GRS or may be disposed of as reference copies.

(U) There are thousands of unscheduled CIA electronic records systems. Until they are scheduled, CIA is legally obligated to preserve the information they contain even though most, in all likelihood, lack archival value.

(U) ERMPO has begun an effort to develop a centralized catalogue/inventory of CIA records, and initially hoped to have a complete product by the end of Fiscal Year (FY) 1997. However, at the end of FY 1996, most major agency components had yet to submit inventories for inclusion in the centralized catalogue, including the DS&T, DO, and DI. DA had only submitted data on 66 systems. In order to assist in this undertaking, existing inventories are available to use in preparing the centralized catalogue. For example, DO's catalogue has hundreds of entries (which were migrated into the centralized catalogue during FY 1997), while DI has published a guide that describes hundreds of DI and non-DI information systems. DI is also working on an inventory of all directorate software applications, while its Crime and Narcotics Center has compiled an inventory of its systems. While Directorate IMOs hope that these products and similar ones will provide much of the information needed for the centralized catalogue, these reports were not prepared as part of an inventorying/scheduling effort and, therefore, may lack all the data necessary to prepare schedules.

(U) ERMPO should complete the centralized catalogue and ensure that the resulting product has the required information needed to support the scheduling process. To that end, the content and format of the centralized catalogue should reflect the guidance NARA has provided in the Disposition ofFederal Records handbook, the Managing Electronic Records instructional guide, and NA Form 14028, NARA's Information System Description Form.

(U) Completion of the centralized catalogue as a comprehensive inventory has taken longer than CIA initially anticipated. In the interim, the pre-existing inventories and listings of electronic systems should provide the basis for the initiation of a major scheduling effort aimed at the most significant, mission-related systems of each CIA directorate as well as at the agency-wide systems ERMPO is developing.

(U) Schedules for permanent electronic systems should include transfer instructions that take into account 36 CFR 1228.188, which calls for the transfer of electronic media to NARA legal custody as soon as they become inactive or when the agency cannot provide proper care and handling sufficient to ensure preservation of the information.

(U) Until they are scheduled, CIA must treat all systems not covered by the GRS as permanent in accordance with 36 CFR 1234.30, which mandates annual sampling, media refreshment, and media migration. Scheduling these systems will satisfy legal requirements and, in addition, relieve CIA of a considerable financial burden by greatly reducing the number of systems subject to the standards for permanent electronic records contained in the CFR.

(U) Recommendation IV/4: Complete the centralized catalogue project so the agency will have a comprehensive, agency-wide inventory of electronic records. After the centralized catalogue is completed, implement measures to keep it current as additional systems are developed.

(U) Recommendation IV/5: Using the centralized catalogue data as well as pre-existing inventories and lists, work with NARA to initiate and carry out a project to ensure that all CIA electronic record systems are eventually covered by NARA-approved schedules. This effort should begin as soon as possible, using existing inventory information, and should encompass the review in coordination with NARA of housekeeping systems to determine which are covered by the GRS and which are not. Develop schedules for non-GRS records, beginning with those that pertain to CIA's core missions and are the most likely to be appraised as permanent.

(U) CHAPTER V: RECORDS MANAGEMENT AT FIELD SITES

(U) The work assignments and activities of individual intelligence officers at field sites stem from an approved set of directives. Some directives are sent to multiple stations while others may be applicable to only one. Periodic meetings are held at stations concerning activities and progress towards meeting the goals specified in directives. No formal notes are taken. However, memorandums that document the assignment of tasks specified in directives and the status of actions taken are produced and sent to CIA Headquarters via cable.

(U) [NOTE: The following two paragraphs (21 lines of text) are security classified and have been removed from the unclassified version of this report.]

(U) NARA evaluators were given access to field files and examined the Headquarters files corresponding to six of these field files. This review supports DO's assertion that field files are duplicative of records found at Headquarters. However, given the small number of files reviewed, NARA cannot say with certainty if this is the case for all or most DO field offices.

(U) The agency position that field files are non-record is contrary to the agency's own internal guidance contained in its "Creation of Agency Records" regulation, issued in February, 1997. This issuance limits the non-record material designation to library and museum material preserved solely for reference or exhibition purposes, extra copies of documents preserved solely for convenience of reference, and stocks of publications or processed documents. The same regulation includes in the agency's definition of records such materials as rough notes, interim versions of documents and supporting background materials, and correspondence relating to matters of short term interest.

(U) CIA should designate field files as records that are covered by the working files item of Disposition Job No. N1-263-85-1/Item 18a. This schedule item calls for the periodic review of files and the placement in the appropriate official files of any substantive/non-duplicative documents.

(U) The maintenance of field files is subject to considerable central direction and oversight from DO Headquarters. As noted in Chapter I of this report, pairs of DO auditors periodically conduct records management inspections of each field site and prepare a report which both Headquarters and the field site are sent. The results of the audits are briefed to field management and documented in a cable sent to Headquarters for division managers, the Chief of DO's Information Management Staff, and the DO IMO. There is, however, no formal structure for correcting any deficiencies that are found. Other requirements mandated from Headquarters stem primarily from security concerns and are geared to ensuring that record holdings are kept to a minimum and can be destroyed quickly in an emergency.

(U) [NOTE: The following four paragraphs (15 lines of text) are security classified and have been removed from the unclassified version of this report.]

(U) Recommendation V/1: Ensure that DO personnel at field offices are aware of the record status of the files they accumulate, and dispose of those files in accordance with DO instructions and the NARA-approved schedule for working files.

(U) CHAPTER VI -- AUDIOVISUAL AND CARTOGRAPHIC RECORDS

(U) PROGRAM REQUIREMENTS

(U) Agencies are also responsible for submitting schedules to NARA to cover cartographic records not already approved for disposal in General Records Schedule 17. NARA regulations prescribing the transfer of permanent cartographic records are found in 36 CFR 1228.186.

(U) FINDINGS AND ANALYSIS

(U) The agency regulation entitled "Information and Records Management Programs" incorporates the statutory definition of records (44 U.S.C. 3301) that makes it clear that records include all media, not merely paper. Likewise, other CIA records management regulations apply to all records regardless of media. However, these issuances do not include specific guidance concerning the creation, maintenance, and disposition of special records as contained in 36 CFR, Chapter 12, Subchapter B and NARA management guides (e.g., "Managing Audiovisual Records" and "Managing Cartographic and Architectural Records").

(U) Recommendation VI/1: Issue specific guidance concerning the creation, maintenance, and disposition of nontextual records that incorporates NARA guidance. This can be done either through a separate issuance or by incorporating guidance into the appropriate records management regulation or OIT's "Information Management Handbook," which is presently being re-drafted.

(U) Audiovisual Records

(U) CIA accumulates a wide variety of audiovisual records, either as products of intelligence gathering or in connection with agency administrative operations. Included are aerial photography resulting from U.S. overhead reconnaissance activities, sound and video recordings of foreign radio and television broadcasts, and recordings of speeches and other appearances by the Director and Deputy Director of Central Intelligence. The conditions under which these and other audiovisual records are maintained vary. Likewise, some of these records are covered adequately by current schedules, some appear to be unscheduled, while the schedules for other series warrant revision. Some schedules are implemented properly; others are not. In addition, some audiovisual records are maintained on obsolete media and may not be readable with available equipment.

(U) Audiovisual Records of the DS&T - Open Source Collection

(U) The DS&T is one of the most important components of CIA from the standpoint of audiovisual records. A DS&T component responsible for open source collection accumulates sound and video recordings of foreign radio and television broadcasts. The bulk of these records are disposable. However, items 3Oc and 36c(3) of Disposition Job N1-263-84-11 call for the transfer to the National Archives of recordings meeting selection criteria that identify as permanent radio and television broadcasts originating in specified countries. Permanent records are to be transferred to NARA when no longer needed to support current requirements.

(U) In 1993, CIA transferred ca. 3000 dictabelts, several videos, and a motion picture film that fall under these items. Records span the period 1950 to 1975. When the NARA evaluators visited CIA in 1996, staff could not identify later records that had been identified as permanently valuable under the approved schedule. CIA should locate these records and transfer post-1975 increments of this series in a more timely fashion. Prompt transfer will help avert the problem NARA has experienced with the 1950-1975 series segment -- dictabelts are an obsolete medium that is very costly to convert to contemporary formats that meet the requirements for archival records. Since these recordings are obtained from open sources, transfers when records are 5 years old should satisfy CIA security needs as well as its administrative requirements. In addition, the selection criteria for permanent recordings should be revised to reflect the current world situation, i.e., the specific nations for which certain broadcasts are permanent were so designated because they were under Communist control, which is no longer the case for most.

(U) In addition to the materials discussed above, the DS&T component responsible for open source collection also maintains videos acquired from open sources or accumulated by other CIA components, primarily components of the DI, including an office which is a video production activity. These video recordings are not scheduled. However, DS&T applies to these records disposition instructions for motion picture film contained in the DS&T schedule and has retained videos of intelligence interest as well as agency-produced videos. These videos should be scheduled so that the record elements, as required by 36 CFR 1228.184, are preserved and, in the case of permanent recordings, are properly identified. In addition, a schedule geared to these records would accurately reflect their specific nature and content.

(U) Current video formats used are either VHS or three-quarter inch. DS&T plans to use Super VHS in the future. These formats do not meet the standards for permanent videos contained in 36 CFR 1232.30(c), which explicitly states that "video cassettes in the VHS format are unsuitable for use as originals of permanent or unscheduled records due to their inability to be copied without significant loss of image quality."

(U) Most videos accumulated by DS&T's open source collection component are stored in a facility that appears to have adequate environmental controls. When the NARA evaluation team visited, the temperature in the storage vault was 65 degrees with a relative humidity of 25%, which is appropriate. However, thousands of videos are maintained at the ARC, where, as noted in Chapter II, humidity levels may be subject to seasonal fluctuations and may cause damage to the films.

(U) Recommendation VI/2: Use formats that conform to 36 CFR 1232.30 for permanent and unscheduled video recordings.

(U) Audiovisual Records of the DS&T -- National Photographic Interpretation Center(NPIC)

(U) NPIC was established in 1961 as the focal point for CIA photographic intelligence and the processing and interpretation of overhead imagery, including imagery obtained from reconnaissance satellites. NPIC maintains negative roll film in its film library for approximately 12-18 months and then retires it to the ARC. VVhile at NPIC, film is maintained under conditions that do not meet archival standards. These records are maintained in an open office environment that lacks adequate temperature and humidity controls. At the ARC, a large segment of the film is held in the cool storage vault while the remaining records are stored in the ARC's general stack area. Film at the ARC appears to be in good condition despite the fact that for ca. 1 year it is stored under questionable conditions at NPIC. As noted earlier in this report, the possibility that humidity levels at the ARC may fluctuate is a cause for some concern, especially in the case of aerial film and other non-textual records.

(U) NPIC's master negatives are scheduled for permanent retention and one very significant transfer of records to NARA has taken place. In 1996, pursuant to Executive Order 12951, ca. 800,000 images acquired from the first satellite imagery program, CORONA, were declassified and transferred to the National Archives. Imagery from other programs, including the U-2 and other airborne reconnaissance programs, remains in agency custody but preparations are underway to transfer it to NARA.

(U) NPIC also maintains a still photography collection of technical intelligence for use by analysts and others in the intelligence community. This collection, which has been built from a variety of sources, including open materials, contains millions of prints and is organized geographically and/or by type of equipment. Caption information generally includes source of the image and its security classification. A local database provides search capability keyed to captions and keywords to about half of the collection. Master negatives are stored at the ARC and the collection is scheduled for permanent retention in the National Archives. However, no records have as yet been transferred to the National Archives even though the earliest photographs date from the early 1930s. CIA should implement the transfer of older photographs to the National Archives along with the corresponding negatives. Print files should be periodically cut off to facilitate future transfers of chronological blocks of photographs.

(U) In the fall of 1996, NPIC became part of the newly formed National Imagery and Mapping Agency (NIMA). It has not yet been determined if older NPIC records stored at the ARC will be transferred to NIMA.

(U) Other Significant Audiovisual Records

(U) The CIA's Agency Information Staff (AIS), a component of the Office of the Director of Central Intelligence, produces videotapes and still pictures of special events. The videos are currently stored in office space lacking environmental controls, although AIS intends to eventually transfer them to the ARC. AIS has not systematically retained the still pictures it accumulates, other than photographs used in an agency-wide newsletter. Both series of records are unscheduled.

(U) The DCI's Public Affairs Staff (PAS) maintains transcripts and sound recordings of speeches, briefings, and meetings involving the Director and Deputy Director of Central Intelligence. The recordings and transcripts of these meetings are earmarked for permanent retention and eventual transfer to NARA. However, there are significant gaps in PAS holdings of sound tapes; while they appear complete from 1993 to the present, there are few earlier recordings, particularly for the period 1986-1992. It also should be noted that PAS staff who maintain the transcripts and recordings were not aware that these records are scheduled for permanent retention in both media. The cassettes used to record speeches are better than standard grade but do not meet NARA standards for permanent records.

(U) CIA generates posters for use within the agency. However, these records are not scheduled nor are they systematically maintained at a central agency-wide collecting point or by individual offices. CIA should schedule posters relating to the agency's history and basic functions for permanent retention and add NARA's Electronic and Special Media Records Services Division (NWME) to its poster distribution list. Existing posters documenting the agency's mission should be gathered for a one-time transfer.

(U) Cartographic Records

(U) CIA uses cartographic products for intelligence publications, briefings, and to plan and carry out operations. There are several significant bodies of CIA cartographic records. The most important is held by a component of the DI's Office of Current Production and Analytical Support (CPAS), which produces maps for other agency components and other federal agencies. Some CPAS products are produced in very small quantities while other projects may entail the production of 20,000 copies. In 1996, CPAS began creating maps electronically.

(U) In addition to providing maps to the requesting office, CPAS retains copies for its own use and also retires a copy of each map it prepares to the ARC. Some maps are unclassified and are distributed to ca. 200 organizations. Most, however, are classified.

(U) The record set of CPAS maps is sent to the ARC on a quarterly basis. Small (8" x 10") maps are stored in acid free folders and cartons. Larger maps are put in map folders, which are rolled and wrapped in kraft paper. Although a few of the map edges have slipped outside the folder edge and show minor tears, maps are generally in good condition. These records are scheduled for permanent retention only in paper form. The electronic version of these important records must also be scheduled.

(U) In addition to the maps it produces, CPAS also holds a collection of maps created by the Office of Strategic Services (OSS). These maps are stored at both the ARC and CPAS. Because of their age and fragile condition, these records should be transferred to NARA immediately. NARA already holds nearly all permanent OSS textual records and the OSS map collection would supplement the collection in NARA.

(U) A second significant repository of cartographic materials is the CIA Map Library, which is currently part of the DS&T component responsible for open source collection (until 1992, it was administered within the DI). The Map Library holds four million maps, most of which are unclassified. Maps are acquired from other agencies, by purchase from open sources (e.g., travel guides, tourist maps, etc.), and from other CIA elements, especially CPAS. The Map Library provides reference services to CIA and to other federal agencies. It regards its holdings as a working reference collection, portions of which are disposable when no longer needed under NC1-263-85-1, item 17 (Reference Files). Older, superseded materials are periodically weeded out. Classified materials that have been weeded are offered to other CIA components or destroyed. Unclassified materials are regularly offered to the Library of Congress.

(U) To ensure against the inadvertent disposal of historically significant cartographic records and/or the misperception that this is taking, place, a separate item covering the collection should be added to the DS&T schedule. As part of the appraisal process, NARA either will confirm that the entire collection is, indeed, reference material or will identify any portions that warrant preservation and eventual transfer to the National Archives.

(U) NPIC also has a Map Library that provides support for its own analysts, for CIA components, and for the intelligence community. Most of its holdings, which include both paper and electronically maintained maps, were acquired from the Defense Mapping Agency. The Library also produces some maps electronically. The Library's staff view their collection as a reference file. The holdings of the NPIC Library should be scheduled; during the appraisal process, NARA will determine if any of these materials warrant preservation. With the transfer of NPIC to NIMA, NIMA will be responsible for preparing the schedule.

(U) Other Nontextual Records Issues

(U) "Missing Records"

(U) Most agencies maintain collections of still pictures documenting substantive agency functions and activities. However, no such collections were located at the CIA during the evaluation, other than aerial photography. As noted above, the Agency Information Staff does not systematically retain photographs of significant events it covers. NARA evaluators sought, but could not locate, photographic collections in the Office of the DCI, the DI, the DO, or the DS&T. Even if prints of some still pictures are included in textual series (e.g., incorporated into reports), the lack of systematic collections of original negatives is troubling. Absent a systematic effort to retain prints, negatives, and slides documenting the activities of leading officials and major agency programs, an important part of CIA's history will be lost.

(U) Recommendation VI/3: Inventory non-textual records and develop schedules for all unscheduled series as well as specific schedule items for certain major collections now covered by generic authorities, as identified in this report (e.g., the DS&T's Map Library).

(U) Agency Records Center Issues

(U) Many of the most important audiovisual and cartographic records CIA accumulates are retired to the ARC. For this reason, NARA is particularly concerned about the possibility that humidity levels at the ARC may vary seasonally and exceed recommended levels, thereby endangering many of the nontextual records stored there. Videos stored in the ARC are in danger of catastrophic loss due to tape binder failure and/or fungal contamination. Likewise, NPIC negatives are subject to fungal growth, and those that are in color may experience significant image fading; even if humidity levels are adequate, color film is in danger of significant fading unless it is stored in a genuinely cold environment of 35 degrees Fahrenheit or less. The fact that the 50 year transfer date for CIA records applies to most nontextual series heightens NARA concerns regarding ARC storage conditions.

(U) Some specific preservation concerns vis-a-vis nontextual ARC holdings are noted above. During evaluation visits to the ARC, many other problems were observed. These include: a number of instances where microfiche was housed in containers that were too narrow, resulting in bending at the edges; positive film images and vu-graphs used in briefings stored vertically without adequate support, either without sleeves or in sleeves that were torn; the storage of most motion picture film in regular stack areas without proper environmental controls, as opposed to cool storage; and engineering drawings in tightly rolled bundles, wrapped in acidic kraft paper.

(U) CIA's ability to review nontextual ARC holdings for preservation action is hampered by several factors. ARC staff are not permitted to open most of the accessions in which these records were retired and therefore are unable to identify accessions that contain records that need to be stored in a controlled environment. In addition, the ARC database does not generally include media codes for records retired prior to the late 1970s, so it is difficult to identify older accessions that include nontextual records. For more recent accessions, the ARC database includes media codes that are generally accurate, though some exceptions were noted. There is uncertainty among IM0s as to when nontextual records closely associated with textual files should be retired separately. This uncertainty also extends to how accessions that include a mix of textual and special records should be coded in the ARC database. Finally, the ARC database does not allow the creation of listings and reports based on the date of the records in accessions so that the oldest nontextual accessions cannot readily be identified. Reports can be derived based on the date of retirement. However, when the ARC database was implemented in 1978, all older accessions were given 1978 accession numbers, increasing the difficulty of locating among all accessions that pre-date 1978 the ones that contain the older nontextual records.

(U) Conclusions

(U) NARA's evaluation revealed serious problems in the area of nontextual records. CIA's overall records management issuances do not adequately address these records. Some of the agency personnel who create and maintain special media do not recognize them as federal records that may be disposed only in accordance with NARA-approved schedules. Certain important series have not been scheduled and, in other instances, significant records do not appear to be maintained systematically. Storage conditions at the ARC are not ideal for nontextual records. Many accessions of special records were improperly packed prior to retirement. These problems are exacerbated by the fact that CIA retains custody of nearly all nontextuial records for a very lengthy period since, with only a few exceptions (e.g., recordings of foreign radio and television broadcasts), CIA schedules call for the transfer of permanent records to NARA when 50 years old, regardless of medium.

(U) Nontextual records are usually transferred by federal agencies to NARA earlier than textual files, primarily because of preservation concerns. Ideally, still photographs, motion picture film, and video and sound recordings should be transferred no later than 10 years after creation. NARA's preferred method of acquiring posters is by adding the Electronic and Special Media Records Services Division (NWME) to the distribution lists used by agencies for internal and external dissemination of this type of record. Cartographic and architectural drawings should be transferred systematically when records are 30 years old or less. CIA must either transfer such records to NARA in accordance with these guidelines or provide the ARC and other holding areas with the resources to implement preservation programs that will ensure compliance with federal regulations, including the copying of records created on obsolete media to contemporary formats.

(U) Recommendation VI/4: Modify schedules to accelerate the transfer of non-textual records to NARA custody; immediately transfer the OSS map collection to NARA.

(U) Recommendation VI/5: Develop and implement a plan to preserve nontextual series that must remain in CIA custody for more than 10 years. Include upgrading storage conditions in the ARC to meet NARA standards for the storage of permanent nontextual records, copying permanent records maintained on obsolete media to contemporary formats, and reviewing the ARC's nontextual holdings to identify accessions in need of preservation action. Particular attention should be paid to locating nontextual records contained in accessions retired to the ARC prior to 1978.

(U) APPENDIX A: RECOMMENDATIONS

(U) Recommendation I/2: After they have completed agency-required records management training classes, require IMOs to periodically take additional training to ensure their familiarity with records issues, policies, and procedures.

(U) Recommendation I/3: Develop a one-day course dealing with the recordkeeping responsibilities of program staff, including the application of approved records schedules to their files and basic records concepts such as distinguishing records from nonrecord materials.

(U) Recommendation I/4: Develop selection criteria for the OIT component-wide internal audits to ensure that serious records management issues and deficiencies are systematically addressed. DO selection criteria could serve as a model for developing selection criteria for OIT audits.

(U) Recommendation I/5: Ensure that the OIT component-wide Audit Implementation Progress Reports are received by AIRMP in a timely manner and that they address the correction of cited deficiencies.

(U) Recommendation I/6: Ensure that sufficient resources are allocated to allow AIRMP to reach its goal of conducting nine audits per year.

(U) Recommendation I/7: Develop a mechanism to ensure that DO audit recommendations are implemented. The OIT audit follow-up procedures can be used as a model.

(U) Recommendation II/1: 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 important policy and decision-making actions, including those discussed via electronic mail (e-mail) or during telephone conversations. E-mail communications that meet the definition of records should be printed out and placed in the appropriate file. Telephone conversations should be documented through Memorandums to the File.

(U) Recommendation II/2: Ensure that employees follow CIA guidance requiring the creation and maintenance of files to document agency activities.

(U) Recommendation II/3: Monitor the implementation of the "Agency File Guide" to ensure that it is effective and meets the needs of the directorates.

(U) Recommendation II/4: Ensure that adequate indexes are created where necessary and that staff who need to use them have familiarity with them.

(U) Recommendation II/5: Require the timely creation of indexing information concerning individuals of foreign intelligence or foreign counterintelligence interest following guidance in the existing DO instruction.

(U) Recommendation II/6: Inspect new accessions retired to the ARC to ensure that records are scheduled properly and to identify any preservation problems and needs, including compliance with CIA regulations concerning the use of acid-free folders for permanent series. This review can either be conducted by component IMOs prior to shipment of records or by ARC staff as part of the accessioning process.

(U) Recommendation II/7: Continue and extend the ARC preservation project. Implement a preservation project for older records held in locations other than the ARC.

(U) Recommendation II/8: Continue the recent initiatives to revitalize the Vital Records Program. Ensure that the "Vital Records Handbook" is disseminated upon completion, and that IMOs continue reviewinc, older vital records in the ARC and identifying more recent vital records.

(U) Recommendation II/9: Consider conducting a mock emergency preparedness drill to ensure that, in an emergency, records are easily retrievable, all equipment needed to read the records is available, and system documentation is adequate to operate any system that contains vital records.

(U) Recommendation III/1: Review full text and skeleton schedules for declassification; provide full text schedules to NARA even if portions are security classified.

(U) Recommendation III/2: Submit schedules for all unscheduled series, including series where records are now maintained electronically, particularly permanent series where paper documents are no longer printed out and filed.

(U) Recommendation III/3: Ensure that all staff are familiar with the schedules that cover the records they accumulate.

(U) Recommendation III/4: Work with NARA in the development of a revised schedule for DO operational project files; use this schedule as the basis for written guidance that is provided to those who review and/or process older operational files.

(U) Recommendation III/5: Ensure that all staff who create or maintain records are familiar with and properly apply existing agency guidance pertaining to what is a record and the record status of working files, particularly the relevant portions of the regulation entitled "Creation of Agency Records"; modify the description of working papers included in agency schedules so it incorporates the guidance contained in this regulation.

(U) Recommendation III/6: Treat as chron files only copies of outgoing correspondence maintained for ready reference. Chron files that are used as finding aids to other records should be disposed of or retained as indexes in accordance with NC1-263-85-1, Item le.

(U) Recommendation III/7: Continue the proiect to apply correct schedule items to ARC accessions improperly retired as permanent; include NARA review as part of the process.

(U) Recommendation III/8: Work with NARA to develop transfer instructions for permanent records that reduce the age at which CIA records are typically accessioned by NARA and provide for the transfer of entire series (or chronological segments thereof). Take into account CIA plans to review files for declassification electronically.

(U) Recommendation III/9: Work with NARA to develop a timetable for the transfer of specific files to the National Archives, with the goal of transferring by the end of 2003 most permanent files cut-off prior to 1961.

(U) Recommendation IV/1: 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 records systems design and implementation.

(U) Recommendation IV/2: Ensure that the major new systems ERMPO and individual directorates are developing can fully meet the needs they were designed to satisfy. Specifically:

(U) a. Include in PERM the capability for creators and recipients of e-mail to designate whether messages are record, non-record, or personal;

(U) b. Ensure that SMART has the capability to retrieve special media records in the ARC; and

(U) c. Ensure that all documents in a series (except documents that by their nature cannot be converted, e.g., bulky enclosures) are included in MORI. Ensure that systems are compatible with standards developed for the entire intelligence community.

(U) Recommendation IV/4: Complete the centralized catalogue project so the agency will have a comprehensive, agency-wide inventory of electronic records. After the centralized catalogue is completed, implement measures to keep it current as additional systems are developed.

(U) Recommendation IV/5: Using the centralized catalogue data as well as pre-existing inventories and lists, work with NARA to initiate and carry out a project to ensure that all CIA electronic record systems are eventually covered by NARA-approved schedules. This effort should becan as soon as possible, using existing inventory information, and should encompass the review in coordination with NARA of housekeeping systems to determine which are covered by the GRS and which are not. Develop schedules for non-GRS records, beginning with those that pertain to CIA's core missions and are the most likely to be appraised as permanent.

(U) Recommendation V/1: Ensure that DO personnel at field offices are aware of the records status of the files they accumulate, and dispose of those files in accordance with DO instructions and the NARA-approved schedule for working files.

(U) Recommendation VI/1: Issue specific guidance concerning the creation, maintenance, and disposition of nontextual records that incorporates NARA guidance. This can be done either through a separate issuance or by incorporating guidance into the appropriate records management reaulation or OIT's "Information Management Handbook," which is presently being re-drafted.

(U) Recommendation VI/2: Use formats that conform to 36 CFR 1232.30 for permanent and unscheduled video recordings.

(U) Recommendation VI/3: Inventory non-textual records and develop schedules for all unscheduled series as well as specific schedule items for certain major collections now covered by generic authorities, as identified in this report (e.g., the DS&T's Map Library).

(U) Recommendation VI/4: Modify schedules to accelerate the transfer of non-textual records to NARA custody; immediately transfer the OSS map collection to NARA.

(U) Recommendation VI/5: Develop and implement a plan to preserve nontextual series that must remain in CIA custody for more than 10 years. Include upgrading storage conditions in the ARC to meet NARA standards for the storage of permanent nontextual records, copying permanent records maintained on obsolete media to contemporary formats, and reviewing the ARC's nontextual holdings to identify accessions in need of preservation action. Particular attention should be paid to locating nontextual records contained in accessions retired to the ARC prior to 1978.

(U) APPENDIX B: EVALUATION REVIEW AND FOLLOW-UP

(U) AUTHORITIES

(U) 44 U.S.C., Chapter 29
(U) 36 CFR, Chapter XII, Subchapter B, Part 1220, Subpart C, NARA Evaluation Program

(U) FOLLOW-UP STEPS

(U) The CIA will submit to the Archivist of the United States an action plan to implement the recommendations in this evaluation report no later than 90 days after the date of transmittal of the final report to the head of the agency.

(U) The action plan will include: specific actions the agency plans to take in response to each recommendation, the proposed month and year for completing each planned action, and major milestones with dates for tracking the completion of implementation actions that are expected to extend longer than three years past the date of the action plan. If the CIA does not plan to implement a specific recommendation, the reason for not acting will be documented in the action plan.

(U) Progress Reports

(U) The CIA will submit a progress report on the implementation of the action plan to NARA every six months until the action plan is completed.

(U) NARA Review

(U) NARA will analyze the adequacy of the CIA's action plan; provide comments to the CIA on the plan within 60 calendar days from receipt; assist the CIA in implementing recommendations; and inform the CIA when progress reports are no longer needed.