ML19294A283
| ML19294A283 | |
| Person / Time | |
|---|---|
| Issue date: | 10/31/2019 |
| From: | Khadijah West NRC/EDO |
| To: | Baker B NRC/OIG/AIGA |
| Margaret Janney, 301-415-7245 | |
| Shared Package | |
| ML19270F025 | List: |
| References | |
| OEDO-19-00460, OIG-19-A-20 | |
| Download: ML19294A283 (3) | |
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AUDIT OF NRCS PROCESS FOR PLACING OFFICIAL AGENCY RECORDS IN ADAMS (OIG-19-A-20)
Status of Recommendations Recommendation 1: Require NRCs refresher records management training be completed annually by all staff and contractors with email accounts or network access.
Agency Response Dated October 11, 2019: Agree. The U.S. Nuclear Regulatory Commissions (NRCs)
Office of the Chief Information Officer (OCIO) submitted a formal request on October 8, 2019, to the Office of the Chief Human Capital Officer (OCHCO)/Human Resources and Training Development (HRTD) that all staff and contractors be required to complete the mandatory records management training annually.
When OCHCO/HRTD and the Human Capital Council approves the request, the training requirement will be assigned in February 2020, consistent with OCHCOs assignment of all agencywide mandatory training.
Target Completion Date: Second Quarter (Q2) Fiscal Year (FY) 2020 Point of
Contact:
Marianne Narick, OCIO/GEMSD/IMSB (301) 415-2175 Recommendation 2 : Assess and update NRCs records management training to address NARA requirements.
Agency Response Dated October 11, 2019: Agree. OCIO reached out to the OCHCO/HRTD Learning and Talent Development Branch, requesting an update to the mandatory records management training to include those items identified as deficient by the Office of the Inspector General (OIG).
OIG noted deficiencies in the following content areas: (1) how records schedules or file plans are implemented and updated; (2) how legal holds and the discovery phases of litigation affect records handling, retention, and disposition; and (3) how agency information technology systems are used for records management. With OCHCO/HRTDs agreement, the OCIO Governance and Enterprise Management Services Division, Information Management Services Branch, is adding a set of Microsoft PowerPoint slides to the current training to cover the content areas noted.
Target Completion Date: First Quarter (Q1) FY 2020 Point of
Contact:
Marianne Narick, OCIO/GEMSD/IMSB (301) 415-2175 Enclosure
AUDIT OF NRCS PROCESS FOR PLACING OFFICIAL AGENCY RECORDS IN ADAMS (OIG-19-A-20)
Status of Recommendations Recommendation 3 : Conduct an initial review of ADAMS to identify and remove personal papers, and implement a policy to conduct such reviews on a periodic basis.
Agency Response Dated October 11, 2019: Agree. OCIO will perform a review of Agencywide Documents Access and Management (ADAMS) using key words such as birthday, anniversary, son, daughter, and vacation. OCIO will confirm with the owners of identified documents that such documents are personal papers, and then remove them from ADAMS. OCIO will establish a policy to conduct reviews on a biannual basis thereafter.
Target Completion Date: Q1 FY 2020 Point of
Contact:
Kenny Nguyen, OCIO/GEMSD/IMSB (301) 415-1938 Recommendation 4: Strengthen internal controls to prevent individuals from entering personal papers in ADAMS.
Agency Response Dated October 11, 2019: Agree. OCIO will take three approaches:
(1) Issue a reminder announcement to staff reiterating the policy that personal papers must not be entered into ADAMS.
(2) Phase I - Modify NRC Form 665, ADAMS Document Submission, to include a warning box. The warning box will advise submitters that personal papers must not be placed into ADAMS, and it will include a reference to Guidance for Determining the Public Availability of NRC Records for additional information. Document Processing Center staff use this form when entering documents into ADAMS.
(3) Phase II - Establish a popup window in ADAMS that is automatically triggered when a staff member attempts to add a document that requires staff confirmation that the document is NOT of a personal nature. The pop up window will include a reference to Guidance for Determining the Public Availability of NRC Records for additional information. In the absence of that confirmation, the system will automatically block the documents entry into ADAMS.
Target Completion Date: Q2 FY 2020 Point of
Contact:
Kenny Nguyen, OCIO/GEMSD/IMSB (301) 415-1938 AUDIT OF NRCS PROCESS FOR PLACING OFFICIAL AGENCY RECORDS IN ADAMS (OIG-19-A-20)
Status of Recommendations Recommendation 5: Strengthen internal controls to ensure use of the Capstone tool and compliance with NARA requirements.
Agency Response Dated October 11, 2019: Agree. OCIO will explore options in collaboration with the Commission and Office of the Executive Director for Operations (OEDO). Possible options include the following:
(1) Establish procedure for the Agency Records Officer (ARO) to periodically review Capstone Official e-mail capture compliance based on the quantity of e-mails captured by individual Capstone Officials. The ARO will then provide this information to the Capstone officials, OCIO, or the OEDO, or all three, for further review and appropriate action.
(2) Modify Capstone Official e-mail capture from the current Opt In approach to an Opt Out approach. The Opt Out approach would allow Capstone Officials to remove emails from capture, such as emails from a professional association or spouse. All other emails would automatically be captured without regard to whether the e-mail is confirmed to constitute a Federal record.
Target Completion Date: Q2 FY 2020 Point of
Contact:
Marianne Narick, OCIO/GEMSD/IMSB (301) 415-2175