GovKM

GovKM Proposed Standards and Guidance

Govern Records Through Retention, Holds and Disposition

Preserve required records, enforce holds and support authorized lifecycle decisions across active, historical and offline holdings.

GovKM-proposed public draft. Published for public review. Not externally accredited or endorsed.

View the EICARS framework resource

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EICARS implementation guidance — proposed public draft. Checklist coverage: R06.1, R06.2, R06.3, R06.4. Prepared November 9, 2026. These suggested approaches support the published GovKM-proposed EICARS v0.1 draft; they do not add requirements or grant external accreditation.

Purpose and use

Preserve required records, enforce holds and support authorized lifecycle decisions across active, historical and offline holdings.

Use this guide within a declared organizational scope, with existing repositories and suitable organizational processes. AI is optional. Examples and suggested evidence are implementation aids; the published standard governs a conformance assessment. The Riverton case below is fictional, not an observed deployment or test result.

Responsible roles

Accountable records officials and custodians, with business owners, counsel and security or privacy staff as applicable.

Assign responsibilities through the organization’s actual instruments. A suggested role in this guide does not itself confer decision authority.

R06.1 Determine record status and schedules

Suggested approach: Have accountable records officials and business owners determine record status, classification and applicable schedules under law and agency policy. Identify the actual schedule item and triggering event. Distinguish an employee’s useful label from an authorized determination. Sensitive content and records status are different questions and may require different controls.

Riverton example: The Riverton coordinator calls a file a “record,” but the records official determines the applicable schedule and the role of the official project file, copies and working material.

Evidence and completion check: Keep the classification rationale, schedule reference and responsible determination. Inspect several different information types rather than assuming one retention rule covers the entire project.

R06.2 Implement lifecycle and hold controls

Suggested approach: Implement approved retention, preservation, hold, transfer and disposition arrangements using suitable existing records capabilities. Include necessary metadata, attachments and dependencies. Coordinate conflicting preservation and deletion duties with records officials and counsel. Retaining all material forever is not a substitute for lawful lifecycle governance.

Riverton example: A hold affects part of the Riverton procurement file. The applicable records and supporting attachments remain protected while unrelated material follows its own approved lifecycle.

Evidence and completion check: Inspect the applicable schedule and hold instructions. Demonstrate the required lifecycle behavior using safe test material and retain authorization, scope and results.

R06.3 Prevent unauthorized destruction

Suggested approach: Prevent destruction without valid authority and check for applicable holds or other restrictions before disposition. Use controlled workflows, permissions or equivalent safeguards suited to the environment. Retain evidence of authorized transfer or disposal as required, while avoiding unnecessary retention of protected content. Respond to suspected unauthorized loss through the applicable reporting process.

Riverton example: The active-information cutover does not authorize staff to delete old Riverton approvals. The records official verifies disposition authority and holds before any permitted action.

Evidence and completion check: Show that a safe test hold prevents scheduled disposition. For a permitted lifecycle action, inspect the authority, approvals and completion evidence; do not test destruction on required production records.

R06.4 Govern historical and offline holdings

Suggested approach: Keep inactive, archived, physical and offline holdings assigned to accountable custodians. Document preservation conditions, location, access arrangements and known dependencies. Prioritize historical assessment according to risk and business need. Where preservation and mandatory deletion obligations appear to conflict, seek a qualified determination rather than choosing one automatically.

Riverton example: Riverton’s older paper inspection files remain in approved custody after the active cutover. Staff know how to request them and which unresolved questions they may help answer.

Evidence and completion check: Inspect an offline or historical holding and its custody record. Demonstrate an authorized retrieval or documented limitation without claiming the unassessed archive is fully verified.

Evidence and completion checks

Agree the population, expected results and acceptance conditions before assessing. Record the date, assessor, evidence reference, observed result and limitation. Use approved safe examples for access, malicious-content or lifecycle tests. Documented policy and observed operating behavior are both relevant; one does not automatically prove the other.

On smaller screens, scroll the table horizontally to view every column.

ItemSuggested evidence and demonstration
R06.1Keep the classification rationale, schedule reference and responsible determination. Inspect several different information types rather than assuming one retention rule covers the entire project.
R06.2Inspect the applicable schedule and hold instructions. Demonstrate the required lifecycle behavior using safe test material and retain authorization, scope and results.
R06.3Show that a safe test hold prevents scheduled disposition. For a permitted lifecycle action, inspect the authority, approvals and completion evidence; do not test destruction on required production records.
R06.4Inspect an offline or historical holding and its custody record. Demonstrate an authorized retrieval or documented limitation without claiming the unassessed archive is fully verified.

Record a gap where the required outcome is not demonstrated. Assign an owner and review date, then verify any correction. Completion of this page alone does not demonstrate conformance with all ten domains, certify legal compliance, approve an AI deployment or authorize autonomous actions.

Common mistakes

Deleting inactive information at cutover; treating all copies alike; retaining everything indefinitely without authority.

Continue the checklist

Use this page with the EICARS standard, the identity guide and the full Riverton scenario. No particular product, model or repository migration is required.

Implementation overview

Suggested operating approach: assign the responsible roles, confirm applicability, implement suitable controls in the existing environment, examine operating evidence and track unresolved gaps. Tailor the methods to scale and risk. Maintain current services during preparation and preserve records, access and legal obligations throughout.

Standards traceability and references

Government Authority and References

U.S. federal reference review: November 9, 2026. These are GovKM mappings of relevance, not government endorsement or a legal compliance determination. Statutes and regulations are mandatory only within their scope; federal policy applies to covered agencies and uses; technical guidance and voluntary resources require the stated selection, adoption or contractual basis. Private and nonfederal organizations must identify their own governing requirements.

The eCFR is authoritative but unofficial. Retrieved Title 36 pages displayed currency through November 5, 2026. Source retrieval does not establish exhaustive legal currency or clause-level implementation compliance. Check current agency supplements, deviations, court orders, schedules, contracts and later amendments. Add the organization’s actual instruments and the qualified official’s applicability determination.

R06.1 — Determine record status and schedules

  • 44 U.S.C. 3301 — Federal record definition

    Issuing body: U.S. Congress; Office of the Law Revision Counsel. Pinpoint: 3301. Relevance: Record definition.

    Classification: Statute — mandatory when applicable. Applicability: Federal agency records within the source’s statutory and regulatory scope. Not a general obligation on private organizations.

  • 36 CFR 1220.32 and 1220.34 — Records program responsibilities

    Issuing body: National Archives and Records Administration. Pinpoint: 1220.34(g). Relevance: Records schedules.

    Classification: Regulation — mandatory when applicable. Applicability: Federal agency records within the source’s statutory and regulatory scope. Not a general obligation on private organizations.

  • NARA General Records Schedules

    Issuing body: National Archives and Records Administration. Pinpoint: applicable GRS item. Relevance: Disposition authority.

    Classification: Approved disposition authorities — apply only to covered series. Applicability: Covered common Federal administrative records; agency-specific authorities and deviations may apply.

  • NARA inventory, scheduling and disposition guide

    Issuing body: National Archives and Records Administration. Pinpoint: Scheduling Records. Relevance: Scheduling guidance.

    Classification: Official guidance. Applicability: Federal records inventory and scheduling work.

GovKM recommendation boundary: The cited sources support the underlying governance outcome. This checklist’s packaging, evidence register and assessment format are GovKM recommendations unless separately adopted.

R06.2 — Implement lifecycle and hold controls

  • 36 CFR 1226.10–1226.20 — Applying disposition authorities

    Issuing body: National Archives and Records Administration. Pinpoint: 1226.10–1226.20. Relevance: Disposition conditions.

    Classification: Regulation — mandatory when applicable. Applicability: Federal agency records within the source’s statutory and regulatory scope. Not a general obligation on private organizations.

  • 36 CFR 1236.20 — Electronic records controls

    Issuing body: National Archives and Records Administration. Pinpoint: 1236.20(b)(3), (6)–(7). Relevance: Lifecycle functions.

    Classification: Regulation — mandatory when applicable. Applicability: Federal agency records within the source’s statutory and regulatory scope. Not a general obligation on private organizations.

  • 36 CFR 1235.48 and 1235.50 — Permanent electronic records transfers

    Issuing body: National Archives and Records Administration. Pinpoint: 1235.48, 1235.50. Relevance: Permanent transfers.

    Classification: Regulation — mandatory when applicable. Applicability: Federal permanent electronic records transferred to NARA.

  • 5 U.S.C. 552a — Privacy Act

    Issuing body: U.S. Congress; Office of the Law Revision Counsel. Pinpoint: (e)(1), (e)(10). Relevance: Relevant information and protection.

    Classification: Statute — mandatory when applicable. Applicability: Covered agency systems of records and individuals, subject to definitions, exceptions and exemptions; section (m) can cover contractors.

GovKM recommendation boundary: Specific holds, court orders and approved schedules must be added locally. This is not a substitute for the actual preservation instrument.

R06.3 — Prevent unauthorized destruction

  • 44 U.S.C. 3105 — Safeguards

    Issuing body: U.S. Congress; Office of the Law Revision Counsel. Pinpoint: 3105. Relevance: Safeguards.

    Classification: Statute — mandatory when applicable. Applicability: Federal agency records within the source’s statutory and regulatory scope. Not a general obligation on private organizations.

  • 44 U.S.C. 3314 — Exclusive disposal procedures

    Issuing body: U.S. Congress; Office of the Law Revision Counsel. Pinpoint: 3314. Relevance: Exclusive disposal procedures.

    Classification: Statute — mandatory when applicable. Applicability: Federal agency records within the source’s statutory and regulatory scope. Not a general obligation on private organizations.

  • 36 CFR 1226.10–1226.20 — Applying disposition authorities

    Issuing body: National Archives and Records Administration. Pinpoint: 1226.16, 1226.18. Relevance: Retention exceptions.

    Classification: Regulation — mandatory when applicable. Applicability: Federal agency records within the source’s statutory and regulatory scope. Not a general obligation on private organizations.

  • 36 CFR Part 1230 — Unlawful or accidental records loss

    Issuing body: National Archives and Records Administration. Pinpoint: 1230.10–1230.16. Relevance: Unauthorized disposition response.

    Classification: Regulation — mandatory when applicable. Applicability: Federal agency records within the source’s statutory and regulatory scope. Not a general obligation on private organizations.

GovKM recommendation boundary: The cited sources support the underlying governance outcome. This checklist’s packaging, evidence register and assessment format are GovKM recommendations unless separately adopted.

R06.4 — Govern historical and offline holdings

  • 36 CFR 1236.14 — Electronic records controls

    Issuing body: National Archives and Records Administration. Pinpoint: 1236.14(c). Relevance: Offline records.

    Classification: Regulation — mandatory when applicable. Applicability: Federal agency records within the source’s statutory and regulatory scope. Not a general obligation on private organizations.

  • 36 CFR 1226.10–1226.20 — Applying disposition authorities

    Issuing body: National Archives and Records Administration. Pinpoint: 1226.14(e), 1226.18. Relevance: Orders and retention limits.

    Classification: Regulation — mandatory when applicable. Applicability: Federal agency records within the source’s statutory and regulatory scope. Not a general obligation on private organizations.

  • 5 U.S.C. 552a — Privacy Act

    Issuing body: U.S. Congress; Office of the Law Revision Counsel. Pinpoint: (e)(1). Relevance: Relevant personal information.

    Classification: Statute — mandatory when applicable. Applicability: Covered agency systems of records and individuals, subject to definitions, exceptions and exemptions; section (m) can cover contractors.

GovKM recommendation boundary: Inactivity is not disposal authority. Preservation conflicts require the actual statutes, orders and schedules, with records and legal review.

This section gives relevant official references for each covered checklist item and is not an exhaustive list of every possible obligation. The actual agency, program, records, data, system and contract determine additional duties. The EICARS organization of these tasks, suggested registers and completion checks remain GovKM recommendations unless independently required or adopted.

Version history

November 9, 2026 — Publication authorized by GovKM. Guidance based on checklist and government authority reference package checked November 5, 2026. References must be periodically revalidated.

November 9, 2026 — Expanded implementation guidance, version 0.1. Replaced the shorter implementation text with the reviewed Riverton examples, task-specific approaches, evidence checks and official authority mappings, with Robert Noyes’s approval. Existing URLs and checklist anchors are preserved. No EICARS requirement or GovKM doctrine is amended.