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Appendix F – Vital Records

17.0     VITAL RECORDS

The provisions of the ACF Vital Records Program (VRP) are applicable agency-wide. The VRP supports the continuation of communications and information flow as well as the continuation of essential agency functions. The implementation of this program ensures records that provide the agency with the information it needs to conduct business under other than normal operating conditions are identified and available when needed.  Vital records provide an agency with the information it needs to meet operational responsibilities under abnormal operating conditions, to resume normal business afterwards (emergency operating records), and to carry out the agency’s essential legal and financial functions (legal and financial rights), pursuant to 36 CFR 1236.14.

Vital Records are essential agency records needed to meet operational responsibilities under national or regional emergency or disaster conditions. Vital records are divided into two categories:

  • Emergency Operating Records are vital records essential to the continued functioning or reconstitution of an organization during and after an emergency. Included are emergency plans and directive(s), orders of succession, delegations of authority, staffing assignments, selected program records needed to continue the most critical agency operations, as well as related policy or procedural records that assist agency staff in conducting operations under emergency conditions and for resuming normal operations after an emergency
  • Legal and Financial Rights Records are vital records essential to protect the legal and financial rights of the Government and of the individuals directly affected by its activities. Examples of these records are records containing proof of ownership, financial interest (social security, payroll, retirement, insurance, and accounts receivable), legal proceeding decisions, contractual obligations, and similar records. These records were formerly defined as "rights-and-interests" records

 

17.1     Vital Records Concept of Operations

Through the Vital Records Program, several key processes are implemented regularly to properly identify records, determine storage, maintenance, access requirements, and protection of vital records/databases.

17.1.1   Identification and Maintenance of Vital Records    

Annually, ACF Continuity Program personnel request ACF components to review their vital files, records and databases to make any updates.  The Vital Records Officer coordinates with the Office of Information Services (OIS) to provide guidance to ACF components on how to identify, maintain and store their vital files and records.  [Note: During COOP activation and operations, the Vital Records Officer is designated the Records Management Officer (see Section 15.4.1).]  The primary focus is upon their Emergency Operating Records which must be accessible at each AOF.  Each ACF Component, Program, or Regional Office is responsible for the identifying requirements to access their records.

 17.1.2   Back-up and Protection of Vital Records

Existing ACF IT Disaster Recovery planning identifies that all contents of the ACF network drives are mirrored at hotsites in Rockville, MD and Bethesda, MD.  The Office of Information Services (OIS) assumes the responsibility of providing off-site back-up for identified vital files and records.  OIS maintains drive configuration and provides access to the shared drive during normal operations and COOP operations at the AOFs.  Additionally, on a regular basis, back-up tapes from the ACF servers are sent to protected facilities at NIH and at facilities in Chicago, IL.

 17.1.3   Vital Records Training

The ACF Continuity Manager (or designee) coordinates with the Vital Records Officer to integrate vital records training into the annual COOP personnel training.  The training instructs COOP team members on how to identify, maintain vital records, the role vital records plays during a COOP incident, and how to access vital records at each AOF.  In addition to heightened awareness of vital records, the training enables COOP personnel to become better managers of vital files, records and databases within their division(s).

 17.1.4   Maintenance of Vital Records Plan Packet

The Continuity Manager (or designee) maintains the Vital Records Plan Packet for ACF.  The packet, stored in digital and hardcopy formats, contains the following:

  • The most current ACF COOP Team Roster with key agency contact information
  • Inventory of vital records identified by office components
  • Documentation of electronic access requirements (ACF user ID and password)
  • Location of physical keys and access codes for vital records storage
  • Location and directions to each AOF
  • A list of equipment and telecommunications required to access specific vital records
  • A copy of the ACF COOP Plan

The electronic version of the Vital Records Plan Packet is located on the ACF network drive and hardcopy versions of the Packet are located in ACF staged equipment storage areas at each AOF.  The hardcopy packet is updated annually with the vital records update and the electronic copy is updated as needed on the network drive and hotsites.

17.1.5   Periodic Review and Risk Assessment of Vital Records

Annually, a risk assessment of the vital records is conducted to identify any irreconcilable risks regarding the identification, maintenance, securing, and access to vital records.  This risk assessment is scheduled to coincide with COOP related exercises, ensuring that lessons learned specific to vital records from COOP related exercises are directly reflected in the risk assessment.  Also, access to vital records is tested semi-annually to ensure the program’s capability to ensure COOP team members have access to vital records.

A periodic review of vital files, records and databases is completed to coincide with COOP related exercises to identify any emerging issues in the program.  The review of the records is conducted to ensure the continued effectiveness of the Continuity Manager (or designee) in facilitating the identification, maintenance, protection, and access to vital records during COOP operations.

17.2     Records Recovery Procedures

Many ACF vital records are stored electronically and on the network drives; others remain in hard-copy format.  For both types of records, recovery procedures are necessary to restore electronic data and to restore physical records that may be damaged by fire, water, or other contaminants.  During the operations and reconstitution phases of COOP, the following processes should be followed to recover damaged records:

  • Notify the Records Management Officer (see Section 15.4.1) and other appropriate persons immediately in case of emergency to relate details about the nature of the emergency and the level of threat to the records
  • Assess the damage to records as soon as possible after the emergency and taking steps to stabilize the condition of the records so further damage will not occur
  • Assemble a records recovery team of available staff members to expedite stabilization of the records (generally only for major records disasters)
  • Consult with contractors who provide records disaster recovery services if the damage assessment shows a need for their expertise
  • Recover the records and the information that they contain, or providing replacement of any lost recorded information when recovery is not feasible
  • Resuming normal business using the recovered records and information
  • Create a resource list of disaster recovery firms for your geographic area and update the information at least annually
  • Test the records recovery procedures to ensure the recovery runs smoothly (including drills on using the equipment, supplies, and procedures for vital records recovery)
  • Utilize necessary IT troubleshooting procedures to recover lost electronic data from hotsite
  • If troubleshooting lost electronic records fails, retrieve back-up tapes from Iron Mountain records storage

Protection and recovery of mission-critical, non-electronic files are the responsibility of each office, if off-site storage is not practical.  ACF component offices should keep all operational and historical records in fireproof and waterproof file cabinets, which are available from several major document protection companies.  These cabinets provide optimal protection for all types of vital records.  If vital records, including electronic media, are damaged by an incident, stabilizing the environment and removing records will prevent further damage.  A contract service provider under the direction and supervision of the Program Support Center (PSC), if required, will complete vital record restoration (dry cleaning and deodorizing).

Following a COOP activation, the Vital Records Officer will contact the off-site storage locations within the National Archives and Records Administration (NARA) for delivery of off-site, vital records to the AOF.  In the event that electronic records are unavailable, ensuring access to hard copy records is critical towards implementing the essential functions.

17.3     Vital Records Inventory

ACF must conduct an inventory of records needed to support emergency operations.  The ACF Vital Records Officer is responsible for conducting this inventory.  In addition, individual ACF components must ensure that all vital records and systems in their charge are routinely backed up and maintained at a secured off-site facility.  ACF vital records, as identified by representatives for each essential function, include the following:

 Table 17.3 – Vital Records Inventory

Vital File, Record, or DatabaseForm of Record (e.g., hardcopy, electronicStorage LocationMaintenance Frequency
ACF COOP Plan

Electronic/Hardcopy

Carried to AOF

Annually

ACF Occupant Emergency Plan (OEP)

Electronic/Hardcopy

Carried to AOF

Annually

All approved grant applications in the Office of Community Service are scanned and stored offsite

Electronic/Hardcopy

Hotsite/NARA

Annually

Contracts for security services

Electronic/Hardcopy

Hotsite

Annually

Contracts with states

Electronic/Hardcopy

Hotsite/NARA

Annually

COOP Plans for GATES, AFCARS, CCBIS TANF and the WEB Server

Electronic/Hardcopy

Hotsite/NARA

Annually

Counsel “getaway bag”

Electronic/Hardcopy

Carried to AOF

Annually

Current grant files

Electronic/Hardcopy

Hotsite/NARA

Annually

Delegations of Authority

Electronic

Hotsite

Annually

Federal register notices

Electronic/Hardcopy

Hotsite/NARA

As necessary/ Annually

Form 3971-SF71 (perhaps ITAAS backup)

Electronic/Hardcopy

Hotsite/NARA

Annually

Hard copies of information in PATS

Hardcopy

NARA

Annually

Legal documents (MOUs, transmittals)

Electronic/Hardcopy

Hotsite/NARA

Annually

MOU for Natcher

Electronic/Hardcopy

Hotsite/NARA

Annually

MOU for Payment Management System

Electronic/Hardcopy

Carried to AOF;

Hotsite/NARA

Annually

OA/key contacts phone list

Electronic

Carried to AOF

As necessary/ Annually

Older offline grants system (might be useable backup)

Hardcopy

NARA

Annually

OPA fly-away kit (critical contacts on CD)

Electronic

Carried to AOF

As necessary/ Annually

ORR Client files

Electronic/Hardcopy

Hotsite/NARA

Annually

ORR COOP Plan

Electronic/Hardcopy

Hotsite/NARA

Annually

Performance records

Electronic/Hardcopy

Hotsite/NARA

Annually

Physical security plans/procedures

Electronic/Hardcopy

Hotsite

Annually

Previous Congressional correspondence,  GAO reports, OIG and White House documents

Electronic (access to HHS system) or Hardcopy

NARA

Annually

Red Book/Social Security Act

Electronic/Hardcopy

Hotsite/NARA

Annually

State plans (sent in for ACF review)

Electronic/Hardcopy

Hotsite/NARA

Annually

Telephone trees

Electronic/Hardcopy

Hotsite/NARA

As necessary/ Annually

Template for reporters

Electronic/Hardcopy

Hotsite

Annually

Unsolicited grants log

Electronic/Hardcopy

Hotsite/NARA

Annually

Volume 45 CFR (4 paperback volumes)

Hardcopy

Hotsite/NARA

Annually

 

Additional vital records are stored at off-site NARA facilities; the current inventory is maintained by the Vital Records Officer.


Content last reviewed on June 30, 2014