Federal use of social media could create federal records in need of the full archival treatment, even if the records are hosted on third party websites, says the National Archives and Records Administration in a new bulletin.

The bulletin, released Oct. 20, says that if third-party hosted social media content is a mere duplication of records found elsewhere, then agencies may determine that the duplicate content is non-record. Should an agency host a social media platform on its own website, the records require a schedule, regardless. A "schedule" in a NARA context means a policy regarding records retention and disposal.

Before brushing off third-party hosted social media content as a non-record, agencies should consider whether the platform adds value, such as better indexing and public comment or other collaboration opportunities. If they do, then the content in question requires a records schedule, the bulletin states.

The bulletin's appendix includes a flowchart to help agency staff determine if third party social media requires a new records schedule, which we've reproduced here.

The bulletin also warns agencies to be careful about using private sector social media platforms, since the service provider could stop providing the service or delete information from an agency's account. Agencies should include a standard records management clause within any contract it signs with a social media provider, the bulletin states.

If a third party platform doesn't allow for access to the data for records schedule purposes, agencies can resort to strategies such as taking snapshots or other capture methods. But, agencies "should consider" whether they'll have direct access to content before using a third party service, the bulletin adds.

For more:
- go to the bulletin, NARA 2011-02
- see a NARA flowchart for determining whether social media records require a new a schedule

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