Ref. Ares(2016)5416325 - 16/09/2016
Ref. Ares(2015)182108 - 16/01/2015
Guidelines on document management and access to documents
1) Document registration
In accordance with the Commission Decision on document management1, a document drawn
up or received by the Commission must be registered if it contains important information
which is not short-lived and/or may involve action or follow-up by the Commission or one of
its departments.
Not registering such a document could prevent the institution from retrieving it at a later date.
Keeping documents in a working space such as shared drives or electronic mailbox folders
does not ensure their integrity, preservation and retrieval. It is therefore
essential that all
documents that meet the registration criteria defined in the eDomec rules2 are actually
registered.
It should be noted that registering a document does not mean that it will automatically be
released in case of a request for access as an exception3 may well apply.
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Practical registration criteria are provided in annex.
2) Filing and retrieval
Registering a document ensures its integrity and preservation. Filing it will facilitate its
retrieval, both by enabling a thematic search and by making it accessible to a larger number of
colleagues.
An unfiled document is only accessible to a few colleagues (the sender, the recipient(s), and
the colleagues who received an attribution task). Filing it makes it accessible to the members
of the group which has been granted access to the file. This is usually a unit or a DG, but it is
possible to give Commission-wide access to files which are both of general interest and not
sensitive.
While the new release of Ares features improvements to the full-text search functionality,
retrieval of registered documents will still depend critically on their proper filing.
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All registered documents should be filed.
1 Decision 2002/47, art 4
2 Annex IV.3 of SEC (2009) 1643. See also the practical registration criteria in annex
3 In the sense of Regulation 1049/2001 (OJ L 145/2001), art 4
Commission européenne, B-1049 Bruxelles / Europese Commissie, B-1049 Brussel - Belgium. Telephone: (32-2) 299 11 11.
Ref. Ares(2015)182108 - 16/01/2015
Practical registration criteria
It is impossible to draw up a definitive list or typology of documents with clear and unambiguous rules for what must be
registered and what not. The question of whether or not to register a given document can only be answered by
analysing it in
context.
This analysis must be applied to all documents,
whatever their medium.
However, analysing a document does not necessarily entail detailed scrutiny of its content.. On the contrary, in most cases a
brief study, or even a cursory glance, is sufficient to arrive at a conclusion. This is particularly true as experience of registration,
and of the types of documents usually dealt with, is built up within the Commission's services.
In order to help to build up such experience, and for use in less clear-cut cases, the following questions aim to provide a step-by-
step guide to analysing documents.
If the answers to all of the following questions is "yes", the document needs to be
registered in the relevant corporate document management system.
1
. Has the document been "drawn up or received" by the institution?
A document is considered as "drawn up" if it is
approved as ready for transmission by the author, i.e the person who signs it
or takes responsibility for its content.
A document is considered as "received" if it has been
intentionally delivered to the Commission by the (external) sender.
2.
Is the document related to the policies, activities and decisions falling within the institution's sphere of responsibility?
Documents related to one's personal situation should not be registered.
3.
Is the information contained in the document important and not short-lived?
Information is unimportant and short-lived if losing it would have no negative administrative or legal effect for the
Commission. A document which requires action or follow-up or involves the responsibility of the institution is important.
Examples (non exhaustive):
Yes No
- formal notes/communications, both received and - drafts (i.e documents not yet validated by the
sent
person who will sign them or take responsibility
- financial documents (as per BUDG guidelines)
for them)
- minutes of meetings, especially with other - e-mails and other texts circulated within an
institutions or external stakeholders, and, for
informal exchange of views between colleagues.
important meetings, briefings/speaking/defensive
- exchanges on short lived matters (such as
etc.
invitations)
-
information received/sent from/to other - information on one's personal situation
institutions or external stakeholders
- contributions to interservice consultations or pre-
consultations
- documents, even informal (e-mails or notes to the
file) that attest situations or events, justify
decisions made or otherwise explain the
development of official actions
- instructions notes, guidelines
3) E-mails
The abovementioned registration criteria defined in the eDomec rules apply to E-mails4.
An e-mail that contains important information, involves action or follow-up, or may later be
needed as proof, should therefore be registered in Ares5. Storing an important and not short-
lived e-mail in an electronic mailbox or on a shared drive is not sufficient because this does
not ensure its integrity and preservation.
In case of a request for access, important e-mails should be retrievable in Ares, just as other
types of documents.
The most practical way to register e-mails is to use "Areslook".
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Areslook,
which thus far has been installed only on request, should be installed
on a systematic basis on all staff personal computers6, at the latest on 1 March
2015. Document Management Officers (DMOs) should inform and provide training to
staff at all levels on the use of Areslook.
Conversely, e-mails which do not qualify for registration in Ares should not be permanently
stored. These e-mails should be deleted by the sender and the recipient(s) when they become
obsolete and/or are superseded by events.
Technical tools allowing an
automatic deletion or any other form of instant mass-deletion of
the e-mails still present in Inbox and Sent Items segments of the electronic mailbox
after a
period of 6 months following their reception or creation date will be put in place by DIGIT
on
1 July 2015. Staff will be able to transfer e-mails to personal folders for purely personal use
outside service activity, with the consequence that the Commission considers such transferred
items to be strictly personal items, not Commission documents, so such transfer must not be
practiced as an alternative to proper registration in Ares. A similar system is already applied
by the European Parliament and the Ombudsman (after 3 months), and is envisaged by the
European Central Bank.
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E-mails which do not qualify for registration in Ares should be deleted in due
time.
¾
Unregistered e-mails will be automatically deleted after 6 months from the
electronic mailbox (Inbox and Sent Items segments).
4 The same also holds true for other media such as SMS, although in practice the criteria are less frequently met
than for e-mails. However, should it be the case, the content of such other media should be transferred or
copied to an e-mail account and then registered as an e-mail or, if this is technically not possible, scanned
and then registered by some other means, such as a note to the file.
5 See the practical registration criteria in annex. On aspects specific to e-mails, see also SEC (2006) 353.
6 This should be done by the Information Resource Managers (IRMs) in close coordination with the DMOs
2
4) Importance of correct registration and filing for access to documents
Regulation 1049/2001 on public access to documents applies to documents drawn up or
received by the institution and in its possession, in all areas of activity of the European Union,
concerning a matter relating to the policies, activities and decisions falling within the
institution's sphere of responsibility7.
Documents which fall under this definition should be registered according to the registration
criteria mentioned above.
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When processing a request for access, documents should therefore be only
searched for in Ares or in another Commission document management system8.
5) Need for a change in administrative practices
As noted by the "peer review", the proper and full implementation of document management
rules still constitutes a challenge, in particular at the level of middle managers and desk
officers.
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Document management should be included in job descriptions and objectives and
discussed during appraisals, so as to make staff at all levels aware of its
responsibilities in this field.
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Participation in "e-Domec" courses should be encouraged. These courses are
regularly organised for staff at all levels (managers and desk officers / secretaries /
DMOs and DMO correspondents)9.
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Implementation of Internal Control Standard n°1110, which relates to Document
Management,
should be regularly monitored by internal auditors and taken into
account in Annual Management Plans and Annual Activity Reports.
Annex: practical registration criteria
7 Regulation 1049/2001, art 2.3 and 3a)
8 Such as Decide, ABAC, etc. These systems will be integrated with Hermes/Ares/Nomcom ("IT
Rationalisation" project)
9 There are also trainings on the use of ARES and NOMCOM, organised by DIGIT, and comprehensive
guidance on the intranet, both on the policy side (on the eDomec website) and on the IT side (on ARES
website).
10 Standard: Appropriate processes and procedures are in place to ensure that the DG's document management is
secure, efficient (in particular as regards retrieving appropriate information) and complies with applicable
legislation. Requirements: Document management procedures and related systems comply with compulsory
security measures, provisions on document management and rules on protection of personal data. Every
document that fulfils the conditions laid down in the implementing rules needs to be registered, filed in at
least one official file and preserved during the period established by document management rules. To do so,
the DG uses systems which respect the above rules, mainly HERMES-ARES-NOMCOM.
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