Over the years, the U.S. National Archives and Records Administration (NARA) has provided the federal government with a wide range of records management services. One of their most important and helpful services is running, in cooperation with other federal agencies, a collection of massive Federal Records Centers (FRCs) across the country. Originally opened in 1950, today there are 18 regional facilities that manage over 29 million cubic feet of records. But how do FRCs work, and what role do they play in the modern management of federal records?
What is a Federal Records Center?
According to 44 U.S.C. 2901(6) and 36CFR 1220.18, a Federal Records Center (FRC) is a facility that, for a fee, manages the storage, processing, and security of records that need to be kept for a certain period of time but don’t need to be retained at the site of creation. These types of facilities are usually operated by either the Archivist of the United States or another federal agency. “The records that we hold and manage are essential to the functioning of the federal government today and to the documentation of federal transactions for the future,” David Weinberg, director of the Federal Records Centers Program (FRCP), has said.
Do agencies have to use a FRC for off-site storage of records?
No. FRCs are government run, but agencies can also optionally use approved “Commercial Records Storage Facilities” run by third parties. These facilities must meet standards established by NARA, and approval for their use by federal agencies is required from NARA. These facilities are compliant with regulations designed to protect records from various threats, including fire, theft, and pests.
Who owns the records stored at an FRC?
The agencies that created the records own them, even when stored in an FRC. These agencies are only using the FRC to house the records, and generally speaking, only the agency can request them.
This also means that moving physical records to an FRC is not the same thing as accessioning them to NARA. Here, there’s some important vocabulary to understand. Agencies transfer records when moving them into the physical custody of a NARA FRC while retaining legal custody. They accession records when NARA takes both legal and (usually) physical custody of the records. In other words, once accessioned, those records legally become NARA’s possession. Until then, housing records in an FRC means transferring them only.
What about record requests made under the Freedom of Information Act (FOIA)?
Since the records in FRCs of NARA are fully in the agency’s legal custody, if the agency is responsible for processing the FOIA request, they are the ones responsible for responding to it. If it is deemed necessary to furnish the record, the agency may request its transfer back into their physical custody from the FRC. In emergency situations, they can request expedited service.
What implications does Memorandum M-23-07 have for FRCs?
At the end of 2022, the U.S. government issued updated guidelines related to M-19-21, which mandated a transition to electronic records for federal agencies. The pandemic slowed that transition, so M-23-07 revises the intended deadlines. Now, Federal agencies must manage all permanent records in an electronic format, excepting records transferred for storage into an FRC before June 30, 2024. Similarly, Federal agencies must manage all temporary records in an electronic format or store them in a commercial records storage facility, again excepting records transferred for storage into an FRC before June 30, 2024.
This means that FRCs (and other approved records storage options) will continue to offer a legitimate option for agencies trying to figure out how to adjust their records management programs to comply with M-19-21 and M-23-07.
Do FRCs offer services beyond storage?
Yes, FRCs can actually serve as a helpful partner in managing records overall. Beyond simple storage, FRCs can provide advisory services (e.g., helping Federal agencies to develop records retention schedules), disposition services, including the disposal of records at the end of their retention period, digital imaging services, and more.
For more information, please see https://www.archives.gov/frc
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