4-4.27 Documentation and Preservation of Records

1. Administrative File. All records custodians must maintain an administrative file documenting how they responded to a FOIA request. The administrative file must contain the following:
1. A Completed PS Form 8170 (see 4-4.27.b);
2. A copy of any responsive records, including any responsive records that were withheld in full based on a FOIA exemption (see 4-4.23 and 4-4.24) and any records released in full to the requester;
3. If records were released to the requester with redactions, a copy of the redacted records and a copy of the unredacted records;
4. All correspondence pertaining to each request;
5. Clear documentation of the steps taken in conducting a records search; and
6. An accounting of search time and review time used in calculating fees.
2. Completing PS Form 8170. Records custodians must consult with their FOIA Coordinator when completing PS Form 8170. Use Exhibit 4-4.27 to locate the appropriate FOIA coordinator. A list of current FOIA coordinators for each location may be found on the Privacy and Records Blue site: http://blue.usps.gov/uspslaw/Privacy/records/foia_resources.htm.

Exhibit 4-4.27 

FOIA Coordinators

3. Forwarding Completed Documents. The Records Custodian must, upon consultation with the FOIA Coordinator, forward the completed PS Form 8170 and a copy of the response to the FOIA RSC.
4. Retention Period. The Records Custodian must retain the administrative file, including all of the items detailed in 4-4.27.a. for a period of 7 years from the end of the fiscal year in which the final response occurs.
5. Administrative Appeals and Litigation Holds. If the requester appeals a response (see 4-4.28), the FOIA RSC will request that the Records Custodian forward a copy of the administrative file to the FOIA RSC. If the request becomes the subject of litigation, the Records Custodian will receive a litigation hold notice from the Area Law Department handling the litigation. In the event of a litigation hold, the litigation hold controls the retention period for any documents within its scope, including but not limited to the administrative file.