B-226375 O/M, MAR 10, 1987

B-226375 O/M, MAR 10, 1987

MISCELLANEOUS TOPICS - FEDERAL ADMINISTRATIVE/LEGISLATIVE MATTERS - ADMINISTRATIVE POLICIES - RECORDS DESTRUCTION - TIME RESTRICTIONS DIGEST: 1. WE RECOMMEND THAT PROPOSAL SUBMITTED BY NATIONAL ARCHIVE AND RECORDS ADMINISTRATION TO REVISE GENERAL RECORDS SCHEDULE 12, ITEM 4, TO DESTROY INVESTIGATIVE REPORTS INCLUDING REPORTS RELATING TO EMPLOYEES UNAUTHORIZED USE OF LONG DISTANCE TELEPHONE SERVICE FOR TWO YEARS AFTER THE INVESTIGATION, BE MODIFIED TO EXCLUDE REPORTS RELATED TO ANY PENDING CLAIMS COLLECTION ACTIONS BY THE GOVERNMENT. 2. WE RECOMMEND THAT PROPOSAL SUBMITTED BY NATIONAL ARCHIVE AND RECORDS ADMINISTRATION TO REVISE GENERAL RECORDS SCHEDULE 12, ITEM 4, TO REQUIRE THAT RECORDS RELATING TO DETERMINATIONS OF UNAUTHORIZED USE OF LONG DISTANCE TELEPHONE SERVICE BY EMPLOYEES BE RETAINED FOR MORE THAN TWO YEARS (SUGGEST FIVE) IN ORDER TO DETERMINE WHETHER THIS IS AN ISOLATED OCCURRENCE OR PATTERN OF ABUSE WARRANTING DISCIPLINARY ACTION.

REQUEST FOR RECORDS DISPOSITION AUTHORITY; OFFICE OF RECORDS ADMINISTRATION, NATIONAL ARCHIVES AND RECORDS ADMINISTRATION. PROPOSED REVISION TO GENERAL RECORDS SCHEDULE 12, ITEM 4. RM-87-06. B-226375 O.M.:

THIS IS IN RESPONSE TO A MEMORANDUM FROM THE CHIEF, RECORDS ANALYSIS AND MICROGRAPHICS MANAGEMENT SECTION, DATED JANUARY 30, 1987, FORWARDING FOR OUR REVIEW A REQUEST FOR RECORDS DISPOSITION AUTHORITY (SF-115) SUBMITTED BY THE OFFICE OF RECORDS ADMINISTRATION, NATIONAL ARCHIVES AND RECORDS ADMINISTRATION, PROPOSING TO REVISE GENERAL RECORDS SCHEDULE (GRS) 12, ITEM 4, REQUIRING THAT SUMMARIES OF LONG DISTANCE TELEPHONE REPORTS USED TO INDICATE AUTHORIZED USE OF TELEPHONE SERVICE AS WELL AS TO AUDIT EXPENSE VOUCHERS BE RETAINED UNTIL THE CLOSE OF THE FISCAL YEAR IN WHICH AUDITED. PROPOSED ITEM 4B WOULD PROVIDE AS FOLLOWS:

B. INVESTIGATIVE RECORDS-- RECORDS WHICH ARE GENERATED FROM CALL DETAIL REPORTS THROUGH ADMINISTRATIVE, TECHNICAL OR INVESTIGATIVE FOLLOW UP. THESE MAY INCLUDE SPECIAL REPORTS OF UNOFFICIAL LONG DISTANCE TELEPHONE USE, THE DOCUMENTATION OF UNOFFICIAL AND UNIDENTIFIED LONG-DISTANCE TELEPHONE CALLS, AND RECEIPT OF PAYMENT OF UNOFFICIAL CALLS.

"AUTHORIZED DISPOSITION

"DESTROY TWO YEARS AFTER INVESTIGATION OR REPORT IS COMPLETED"

WE NOTE THAT COLLECTION ACTIONS MAY BE INSTITUTED AGAINST INDIVIDUALS FOUND TO HAVE MADE UNAUTHORIZED LONG DISTANCE TELEPHONE CALLS AND IT IS POSSIBLE THAT SOME OF THESE ACTIVITIES MAY NOT BE COMPLETED WITHIN THE TIME PROPOSED FOR THE DESTRUCTION OF THE INVESTIGATIVE RECORDS. THEREFORE, WE SUGGEST AMENDING THE AUTHORIZED DISPOSITION TO READ:

"DESTROY TWO YEARS AFTER INVESTIGATION OR REPORT IS COMPLETED UNLESS THEY RELATE TO ANY PENDING CLAIMS COLLECTION ACTION BY THE GOVERNMENT."

WE ALSO NOTE THAT RECORDS RELATING TO DETERMINATIONS THAT AN EMPLOYEE HAS MADE UNOFFICIAL USE OF THE TELEPHONE FOR LONG-DISTANCE CALLS MIGHT BE RETAINED FOR A LONGER PERIOD OF TIME THAN TWO YEARS IN ORDER TO PERMIT A DETERMINATION WHETHER THIS IS AN ISOLATED OCCURRENCE OR A PATTERN OF BEHAVIOR NECESSITATING SOME FORM OF DISCIPLINARY ACTION BY THE GOVERNMENT. THUS FOR THESE CASES IT MAY BE APPROPRIATE TO REQUIRE A LONGER RETENTION PERIOD, SAY FIVE YEARS IN ORDER TO PERMIT THIS DETERMINATION TO BE MADE.

OTHERWISE, WE HAVE REVIEWED THE PROPOSED REVISION TO GRS 12, ITEM 4, AND FROM A LEGAL STANDPOINT WE HAVE NO OBJECTION TO ITS ISSUANCE.