3.3 Contractor Responsibilities
The contractor shall:
3.3.1 Plan for the full life cycle
(from capture or creation, during retention, to their approved destruction)
of Government records regardless of media.
3.3.2 Prevent
the unlawful or accidental removal, defacing, alteration, or destruction
of records. Records must not be destroyed except under the provisions
of the DHA RDS. The penalties for the unlawful removal, defacing,
alteration, or destruction of federal records or the attempt to
do so, include a fine, imprisonment, or both.
3.3.3 Ensure that appointed contractor’s
Records Liaisons (RLs) attend the DHA RM annual training.
3.3.4 Maintain all government records
in their custody pursuant to the DHA RDS and federal law.
3.3.5 Provide RMO with RLs appointment
letters for those individuals working with the DHA RMO.
3.3.6 Apply current laws, regulations,
standards, procedures, and techniques to ensure creation, retrieval, maintenance,
preservation, and disposition of Government records, regardless
of media.
3.3.7 Maintain file plans of Government
records and annually provide to the DHA RMO for review and approval.
3.3.8 Provide file plans to the Government,
if requested.
3.3.9 Maintain
documentation on any Federal records that have been transferred
to the Federal Records Centers (FRC) or destroyed pursuant to the
DHA RDS.
3.3.10 Participate in biennial RM
Program evaluations to monitor compliance with RM laws and regulations.
3.3.11 Evaluate current and potential
electronic information systems to identify record information being created
or received during the conduct of business and ensure the preservation
of federal records as specified in the DHA RDS.
3.3.12 Incorporate recordkeeping functionality
into electronic information systems or transfer records to a compliant
electronic recordkeeping repository.
3.3.13 Demonstrate recordkeeping functionality
compliance within electronic information systems which store Government-owned
records.
3.3.14 Notify the DHA RMO of any unscheduled
records.
3.3.15 Train all employees on their
legal responsibility to report to the RL any actual, impending,
or threatened unlawful removal, alteration, or destruction of federal
records. Policies and regulations are referenced in
paragraph 1.1.
3.3.16 Report any incidents to DHA
RMO within five business days.
3.3.17 Establish a RM Program covering
all media formats.
3.3.18 Use the filing system outlined
in the DHA RDS. This allows for the maximum uniformity and ease
in maintaining and using Government records and facilitating the
locating, charge-out, re-filing, and disposing of records.
3.3.19 Submit a Notice of Destruction
(NOD) form to the DHA RMO for approval before destroying any DHA records.
3.3.20 Develop and implement a vital
records program in accordance with 36 CFR Chapter XII Subchapter
B, Part 1223, “Managing Vital Records.” Vital records are also called
essential records.
3.3.21 Retrieve and deliver requested
records, or other records management related activities within five business
days of receiving the US Government’s request for them.
3.3.22 Routinely transfer inactive
paper records to the FRC designated by DHA RMO in accordance with
Section 4. The deadline for paper records
transfer is December 31, 2022.
3.3.23 Manage email that complements
Government records by applying the laws, regulations, and instructions
which are identified in
paragraph 1.0 and include the following administrative
actions:
3.3.23.1 Publish and implement an internal
email policy to include requirements and risk prevention guidance
addressing unauthorized additions, deletions, and alterations to
message content, all of which impair record integrity.
3.3.23.2 The contractor’s policy shall
include, but not be limited to:
• Defining what is a record versus
what identifies a non-record.
• Adding records to recordkeeping
systems.
• Preserving data; to include
preserving names on distribution lists and directories.
• When to request receipts and
how to preserve them.
• Circulating drafts securely.
• Using external email systems
for Government email as records.
3.3.24 Assign an individual to be
responsible for the maintenance of the email recordkeeping system.
This individual is also required to annually monitor the use of
the email system to assure recordkeeping instructions are being
followed.
3.3.25 Provide basic records management
training annually to each employee who receives, creates, maintains,
uses, and dispositions Government records that covers employee responsibilities
throughout the lifecycle of records.
3.3.26 Use
Addendum B for
guidance on transferring electronic records to DHA.