Audit Report 09-23: Survey of Electronic Records Management

On September 15, 2009, the OIG issued Audit Report 9-23, Survey of Electronic Records Management.  After completing a survey, the Auditing Division decided not to perform an audit of SBA’s electronic records management (ERM) program at this time. The OIG had considered an audit because (1) the agency has become increasingly dependent on electronic records, and (2) magnetic tapes containing records needed for a prior audit were inappropriately erased.   The OIG, however, decided not to conduct the audit because SBA’s ERM program is in the early stages of development. This memorandum, therefore, contains the OIG’s findings and recommendation based on the survey.

The OIG found areas of concern when conducting the initial survey.  Specifically, (1) the SBA had not developed complete inventories and disposition schedules for its electronic records, (2) some program offices were not aware of ERM requirements, and (3) some offices requested additional training in records determinations and requirements.  The OIG recommended that the SBA implement an Electronic Records Management program that meets the requirements of 36 CFR 1222, 36 CFR 1228, and 36 CFR 1234,such as:

1. Ongoing training for all agency personnel on policies, responsibilities, and techniques for the implementation of recordkeeping requirements and the distinction between record and non-record materials, regardless of media, including those materials created by individuals using computers to send or receive electronic mail.
2. Preparation of an inventory of electronic records that includes description of medium, location, volume, inclusive dates, informational content and use.
3. Development and implementation of disposition schedules for all electronic records created and received by the agency.
4. Procedures for the participation of records management officials in developing new or revised agency programs, processes, systems, and procedures in order to ensure that adequate recordkeeping requirements are established and implemented.