Information Management Information Management

Summary

Army Regulation 25–98
Information Management
Information
Management
Control
Requirements
Program
Headquarters
Department of the Army
Washington, DC
8 February 2019
UNCLASSIFIED
SUMMARY of CHANGE
AR 25–98
Information Management Control Requirements Program
This administrative revision, dated 13 February 2020—
o Corrects guidance for the Army internal survey exemptions (para 6–5j)

This new publication, dated 8 February 2019—
o Changes publication title and series from AR 335–15 (Management Information Control System) to AR 25 –98
(Information Management Control Requirements Program) (cover)

o Updates guidance for the Information Management Control Requirements Program (throughout)

o Changes the proponency of the program from Chief Information Officer/G–6 to the Office of the Administrative
Assistant to the Secretary (throughout)

Headquarters *Army Regulation 25–98
Department of the Army
Washington, DC
8 February 2019 Effective 8 March 2019
Information Management
Information Management Control Requirements Program
United States, and the U.S. Army Re- and identifies key internal controls that
serve, unless otherwise stated including must be evaluated (see appendix B)

Department of the Army Civilians. This
Supplementation. Supplementation
regulation applies regardless of mobiliza-
of this regulation and establishment of
tion status

command and local forms are prohibited
Proponent and exception authority. without prior approval from the Adminis-
The proponent of this regulation is the trative Assistant to the Secretary of the
Administrative Assistant to the Secretary Army (AAHS– PA), 9301 Chapek Road,
of the Army. The proponent has the au- Building 1458, Fort Belvoir, VA
thority to approve exceptions or waivers 22060–5527

to this regulation that are consistent with
Suggested improvements. Users
controlling law and regulations. The pro-
are invited to send comments and sug-
ponent may delegate this approval author-
gested improvements on DA Form 2028
ity, in writing, to the Records Manage-
(Recommended Changes to Publications
ment and Declassification Agency/Rec-
History. This publication is an adminis- and Blank Forms) to the Administrative
ords Management Division, Army Rec-
trative revision. The portions affected by Assistant to the Secretary of the Army
ords Officer. Activities may request a
this administrative revision are listed on (AAHS– RDR), 9301 Chapek Road,
waiver to this regulation by providing jus-
the summary of change. Building 1458, Fort Belvoir, VA 22060–
tification that includes a full analysis of
5527 or usarmy.belvoir.hqda.mbx.rmda-
Summary. This regulation prescribes the expected benefits and must include
[email protected]

policy for the preparation, review, and ap- formal review by the activity's senior le-
proval of information requirements and gal officer. All waiver requests will be en- Distribution. This regulation is availa-
the documentation and information prod- dorsed by the commander or senior leader ble in electronic media only and is in-
ucts prepared in response to these require- of the requesting activity and forwarded tended for the Regular Army, the Army
ments. through higher headquarters to the policy National Guard/Army National Guard of
proponent. the United States, and the U.S. Army Re-
Applicability. This regulation applies serve

to the Regular Army, the Army National Army internal control process

Guard/Army National Guard of the This regulation contains internal control
provisions in accordance with AR 11–2
Contents (Listed by paragraph and page number)
Chapter 1
Introduction, page 1
Purpose • 1–1, page 1
References and forms • 1–2, page 1
Explanation of abbreviations and terms • 1–3, page 1
Responsibilities • 1–4, page 1
Records management (recordkeeping) requirements • 1–5, page 1
Statutory authority • 1–6, page 1
Objectives • 1–7, page 1
Policy • 1–8, page 1
Secretary of the Army • 1–9, page 2
Chief Information Officer/G–6 • 1–10, page 3
Headquarters Department of the Army principal officials and Commanders of Army commands, Army service com-
ponent commands, and direct reporting units • 1–11, page 3
*This publication supersedes AR 335-15, dated 28 October 1986

AR 25–98 • 8 February 2019 i
UNCLASSIFIED
Contents—Continued
Chapter 2
Information Collections, page 4
General • 2–1, page 4
Types of information collections • 2–2, page 4
Information collection requirements • 2–3, page 4
Information collection budget • 2–4, page 4
Chapter 3
Army Internal Information Collections, page 5
Purpose • 3–1, page 5
General • 3–2, page 5
Army internal exemptions • 3–3, page 5
Unauthorized requests • 3–4, page 5
Required documents and approval process • 3–5, page 5
Canceling a report control symbol reporting requirement • 3–6, page 6
Chapter 4
Multi-Service Information Collection Requirements, page 6
Purpose • 4–1, page 6
General information • 4–2, page 6
Multi-Service exemptions • 4–3, page 6
Approval periods and types of requests • 4–4, page 6
Elements of a multi-Service collections package • 4–5, page 7
Multi-Service approval process • 4–6, page 7
Responding to a multi-Service collection requirement • 4–7, page 9
Chapter 5
Public Information Collection Requirements, page 9
Purpose • 5–1, page 9
Identifying members of the public • 5–2, page 9
Public exemptions • 5–3, page 9
Consideration of utility and burden • 5–4, page 10
Elements of a public collections package • 5–5, page 10
Collection Instrument • 5–6, page 10
Coordination supporting documentation • 5–7, page 11
Approval process for public information collections • 5–8, page 11
Public generic surveys • 5–9, page 12
Evidence of approval • 5–10, page 12
Termination of approval and use • 5–11, page 13
Failure to comply • 5–12, page 13
Chapter 6
Army Internal Surveys, page 13
Purpose • 6–1, page 13
Policy • 6–2, page 13
Applicability • 6–3, page 13
Army internal survey requirements • 6–4, page 13
Army internal survey exemptions • 6–5, page 14
Required documents and approval process • 6–6, page 14
Sponsoring an Army internal survey • 6–7, page 15
Appendixes
A. References, page 16
B. Internal Control Evaluation, page 19
AR 25–98 • 8 February 2019 ii
Contents—Continued
Table List
Table 4–1: Mandatory coordinators for multi-Service collections, page 8
Glossary
AR 25–98 • 8 February 2019 iii
Chapter 1
Introduction
1 –1. Purpose
The purpose of this guidance is to update the Information Management Control Requirements Program that reduces
costly, ineffective, and redundant information collections (such as forms and surveys) and reporting requirements

Additionally, it establishes procedures for information collecting and reporting of Army internal, multi-Service, and
public requirements

1 –2. References and forms
See appendix A

1 –3. Explanation of abbreviations and terms
See the glossary

1 –4. Responsibilities
Responsibilities are listed in section II of chapter 1

1 –5. Records management (recordkeeping) requirements
The records management requirement for all record numbers, associated forms, and reports required by this regulation
are addressed in the Records Retention Schedule-Army (RRS–A). Detailed information for all related record numbers,
forms, and reports are located in Army Records Information Management System (ARIMS)/RRS–A at
https://www.arims.army.mil. If any record numbers, forms, and reports are not current, addressed, and/or published
correctly in ARIMS/RRS–A, see DA Pam 25–403 for guidance

1 –6. Statutory authority
Implements portions of Chapter 35 of Public Law 104–13 (PL 104–13, Chapter 35) to—
a. Minimize the Federal paperwork burden on the public, small businesses, and state and local governments

b. Minimize the Federal Government's costs for collecting, maintaining, using, and disseminating information

c. Maximize the usefulness of information collected, maintained, and disseminated by the Federal Government

d. Coordinate, integrate, and where practical, create uniform Federal information policies and practices

e. Make sufficient information available to all commanders and management personnel to achieve mission effec-
tive- ness

1 –7. Objectives
The objectives of this regulation are to—
a. Identify the information needs of Army organizations to reduce the burden of unnecessary collections of infor-
mation

b. Collect, transmit, process, and store information through the most economical use of personnel, funds, and
equipment

c. Comply with standard forms, terms, data elements, and source records

d. Provide simple, orderly, and flexible procedures and systems that can quickly respond to mobilization

e. Prevent or reduce the imposition of invalid, inefficient, or unnecessary information collections

f. Provide a means for measuring the value of information against the cost of collecting it

g. Improve the methods and techniques for collecting information by applying information processing technology
and reducing agency cost

1–8. Policy
a. Control and maintain Army collections of data. Requirements not specifically exempted, not approved, not as-
signed an Office of Management and Budget (OMB) control number, report control symbol (RCS), survey control
number (SCN), or other Army information control symbol, or in any other ways not in conformance with this regula-
tion, are unauthorized. The requests will be—
(1) Identified by standard numbering patterns

(2) Approved by a designated official

AR 25–98 • 8 February 2019 1
(3) Reviewed periodically by the initiating, monitoring, and preparing agencies. Periodic reviews will be made of
each management information requirement at least once every 3 years for public collections and once every 5 years
for Army internal collections

(4) Revised or rescinded, when needed

b. Cite the title and RCS in the table of contents and text for each directive that initiates an information management
requirement. Each subsequent action affecting the information requirement will also state the title and RCS

c. Conduct privacy impact assessments in accordance with Department of Defense instruction (DODI) 5400.16 for
collections of information that contain personal information on individuals, which require special handling under De-
partment of Defense (DOD) Regulation 5400.11–R. The assessments will ensure that personal information in elec-
tronic form is acquired and maintained only when necessary and that the supporting information technology being
developed and used protects and preserves the privacy of individuals. Such information included in the proposed
collection of information will be accessible to the public only as prescribed by DOD Manual 5400.07

d. Ensure that information needs are clearly identified and reports to be generated by the system represent a cost-
effective use of resources in the development and operational life cycle of an automated information system

e. Submit requests for forms used to collect information in accordance with AR 25–30

f. Evaluate and screen each item of data in the information collection against data in existing information collec-
tions to determine whether the existing information can satisfy the requirement

g. Refuse to honor information collections that have not been specifically exempted or properly approved and
symbolized

h. Approve and symbolize, on a case-by-case basis, special, one-time, high priority, or time-sensitive information
col- lections without subjecting the request to an in-depth review and analysis, provided a statement of urgency is
included with the request for approval

i. Commercial platforms, unless specifically approved by CIO/G–6, are not authorized for Army conducted sur-
veys. See chapter 6 for authorized and preferred online survey development sites

1 –9. Secretary of the Army
On behalf of SECARMY, the Administrative Assistant to the Secretary of the Army (AASA) is responsible for
Armywide control of information management collections and reporting requirements

a. The Administrative Assistant to the Secretary of the Army. The AASA will ensure the Director, U.S. Army
Records Management and Declassification Agency (RMDA) will—
(1) Establish and implement standards and procedures for initiating, identifying, reviewing, preparing, distributing,
and discontinuing information collections

(2) Establish an information requirement control activity and appoint a Department of the Army (DA) Information
Management Control Officer (IMCO)

(3) Appoint Department of the Army (DA/Army Headquarters Services (AHS)/RMDA) IMCO, in writing

b. Department of the Army Information Management Control Officer. DA IMCO have jurisdictional control over
Armywide and multi-command information management requirements. DA IMCO will—
(1) Provide guidance and technical advice for information control policy and operations

(2) Represent DA in all matters relating to control of information management requirements, including all other
DOD and Federal agencies

(3) Provide for periodic review of approved information collections for need, adequacy, design, economy of prep-
aration, and use

(4) Withhold approval of any information management requirement if the suitability, coordination, essentiality, or
costs have not or cannot be determined

(5) Ensure that ARs and DA Pamphlets containing information requirements are updated in accordance with AR
25–30

(6) Maintain an up-to-date Armywide index of approved recurring information collections requiring a RCS and all
Army submissions under the Paperwork Reduction Act of 1995 that OMB approved

(7) Assess ongoing public information collections every 3 years, unless OMB stipulates otherwise

(8) Submit the DA information collection budget to Washington Headquarters Services, Executive Services Direc-
torate and Office of Information Management (OIM)

(9) Serve as the DA clearance office and office of record for Army public information collection requirements

(10) Serve as the office of record and approval authority for Army-prescribed Army internal information collection
requirements, including for multi-Service collection requirements DA imposed. May delegate Army internal survey
ap- proval authority to other Army activities, as needed

AR 25–98 • 8 February 2019 2
(11) Evaluate and screen each data element in an information collection requirement against information in existing
information collection requirements to determine whether the existing information can satisfy the requirement

(12) Ensure that information collection requirements, including research involving human subjects, are reviewed
in accordance with the requirements of DODI 3216.02

(13) Ensure alignment of Army internal and multi-Service RCSs

c. Headquarters, Department of the Army Privacy Office. This office provides mandatory coordination for infor-
mation collections, when required

1–10. Chief Information Officer/G– 6
The CIO/G–6 will exercise oversight and policy and upon request, review packages when information is collected,
stored, or disseminated in an electronic form and ensure that privacy impact assessments (PIAs) are complete and
accurate in accordance with DODI 5400.16

1 –11. Headquarters Department of the Army principal officials and Commanders of Army
commands, Army service component commands, and direct reporting units
HQDA principal officials and Commanders of ACOMs, ASCCs, and DRUs will—
a. Manage and supervise the information management control requirements within their jurisdiction

b. Ensure that compliance and enforcement of department policies and procedures governing information manage-
ment requirements and data products within their organization are upheld, including at subordinate agencies and com-
mands

c. Designate an IMCO, in writing, and provide HQDA/AHS/RMDA with a copy of the designation memorandum

IMCOs, within their jurisdiction, will—
(1) Advise action officers (AOs) on the essentiality of proposed, revised, and amended information management
col- lections

(2) Promote secure electronic information collection methods and procedures

(3) Process documentation for submission to DA to assign, extend, reinstate, and cancel Army internal, inter-com-
ponent, and public information collections

(4) Reduce the data collection burden by decreasing the frequency and amount of data requested when possible

(5) Ensure statistical sampling techniques and the use of information technology are employed as approaches to
minimizing reporting workloads. Ensure that census data collections are conducted only when sampling is not meth-
odologically appropriate, such as when the population of interest is very small

(6) Ensure DA Form 7799 (Request for Approval of Information Management Requirement) is completed for each
nonexempt request initiated

(7) Minimize, account for, and control information collected from the public and State and local governments in
accordance with Title 5, Code of Federal Regulations, Part 1320 (5 CFR, Part 1320)

(8) Approve or disapprove the citation of exemptions listed in paragraph 3–2 and make sure the proper exemption
is cited if the information requirement is exempt

(9) Establish goals for the reduction in number or frequency of Army internal and multi-Service prescribed infor-
mation collections

(10) Ensure prompt responses to information management controls, paying particular attention to the timeliness,
accuracy, and completeness of the data submitted, to ensure full compliance with approved requirements

(11) Ensure that violations of this regulation are corrected and reported to the initiating organization. Notification
of violations will be sent to each IMCO in the chain of command

(12) Maintain a database or list of recurring information requirements

(13) Maintain the organization’s information management control requirements files in accordance with AR
25–400–2

(14) Make sure RCSs assigned by a higher level will not be assigned a different DOD component RCS by a lower
level organization

(15) Submit public and required information collection requests through HQDA, making sure users justify new
information collections before submission for approval

d. Designate AOs to coordinate information management controls with the IMCO within their jurisdiction. AOs
are the originators of a proposed information collection. Specifically, AOs will—
(1) Submit all documents concerning the information requirement to the organization’s IMCO within their juris-
diction for review and recommendation of approval before forwarding to HQDA

AR 25–98 • 8 February 2019 3
(2) Review published collections a minimum of 180 days before the expiration date. Extensions must be requested
a minimum 180 days before the expiration date. Information collections not approved for extension may be canceled
on the date of expiration

(3) Ensure the collection meets the requirements set by the CIO/G–6 and DODI 5400.16

e. Designate a privacy official in accordance with AR 25–22. To ensure compliance with privacy policies, the
organization privacy official will review all information collections that contain personally identifying information

f. Designate a records administrator in accordance with AR 25–400–2. All information collection requests must be
coordinated with the records administrator to ensure that the appropriate records disposition schedule has been iden-
tified

Chapter 2
Information Collections
2 –1. General
Information is any communication or representation of knowledge such as, facts, data, or opinions in any medium or
form. Information collections are written verbal reports, applications (forms), schedules, surveys (including focus
groups), questionnaires, reporting or recordkeeping requirements in any format and collected through any media. In-
formation collections must be essential to the mission of the requesting organization and the burden must be worth
the benefit of the results of the collection. The burden is the total time, effort, and financial resources used to generate,
maintain, retain, or provide information

2 –2. Types of information collections
Information collections may be Army internal (also known as component internal or internal), multi-Service (also
known as DOD internal or cross-services), or public. In some instances, an information collection may be a combina-
tion of public and Army internal or multi-Service

2 –3. Information collection requirements
Information collection items must be constructed to obtain all information needed concisely, economically, and effec-
tively. Prescribing directives containing information requirements should be sufficiently clear to avoid misinterpreta-
tion. Before collecting information, AOs must ensure that the information is not duplicative of information already
available. Army and DOD policies require that information collections comply with the following:
a. Non duplication. Individuals requesting an information collection must ensure that the information collected
does not duplicate information already available. When the information is not already available, requesters must
demonstrate that they are using methods (for example, a scientific sample and a short questionnaire) to minimize the
information col- lection burden on respondents

b. Licensure. All information collections must be approved and assigned a SCN, RCS, OMB control number or a
combination of two. All surveys administered by an Army organization will be submitted for a formal review and
deter- mination. Soldiers and DA Civilians will not respond to any type of information collection that has not been
properly approved and licensed with an information collection control symbol

c. Privacy impact assessment. When personal information about individuals is collected in an electronic form, a
DD Form 2930 (Privacy Impact Assessment (PIA)) must be completed in accordance with AR 25–1 to ensure the data
remains protected and private

2 –4. Information collection budget
a. In accordance with DODI 8910.01, HQDA will submit annual information collection budgets, which will project
DA’s information management needs from the public for the next fiscal year. The number of hours public respondents
require to prepare Army data collection requests will be limited by a ceiling OMB assigns

b. HQDA will inform AOs proposing a new or revised data collection from the public if their proposal is within
the current assigned ceiling

c. Data collection requests proposed after submission of the information collection budget that exceed the ceiling
will be disapproved unless the Secretary of Defense certifies an emergency need for the data

AR 25–98 • 8 February 2019 4
Chapter 3
Army Internal Information Collections
3 –1. Purpose
This chapter outlines the requirements and process for Army internal collections. If the Army internal information
collec- tion is a survey, see chapter 6 for the elements required for review and approval

3 –2. General
An Army internal information collection is when the Army needs to collect information from Army personnel only

Army internal information collections are approved by HQDA. If approved, the collection will be assigned a RCS and
expiration date

3 –3. Army internal exemptions
a. Nonsurvey Army internal collections may be exempt from a formal review. The exemptions align with the multi-
Service collections exemptions outlined in DODM 8910.01, Volume 1, Enclosure 3

b. In accordance with paragraph 2–3, all surveys administered by an Army organization will be submitted for a
formal review and determination

3 –4. Unauthorized requests
Requests for information will not be approved when—
a. The request is considered controllable and the directive does not cite a RCS

b. The request cites an exemption that does not apply

c. The request cites a RCS that has been rescinded

d. The request cites a questionable exemption or symbol

e. A request for an exempt or controlled information collection appears to duplicate or overlap another collection
re- quest, or to conflict with the objectives of the management information control system

f. Repeated requests are received for one-time data collections that appear to overlap each other or indicate a need
for a recurring data request

g. The request does not appear to comply with this regulation

3–5. Required documents and approval process
a. The action officer (AO) will discuss new or revised data requests with the IMCO within jurisdiction for coordi-
nation. The discussion will include possible duplication of data, potential availability of data, cost estimating tech-
niques to be used, effect on preparers, and management’s need for the information

b. If a need to request data is determined, the AO will complete the DA Form 7799. The DA Form 7799 and
instrument will be sent to the IMCO with jurisdiction for review and approval

c. The IMCO with jurisdiction will coordinate with the records administrator and privacy officer ensuring compli-
ance with records management and privacy policies. The appointed IMCO may also serve as the records administrator
and privacy officer. If that is the case, the IMCO with jurisdiction will complete and sign complete DA Form 7799,
block 11

d. The request for a RCS will be approved by a colonel and/or O–6 or DA Civilian equivalent within the office of
the IMCO with jurisdiction before submission to HQDA

e. Upon approval of the request, the IMCO with jurisdiction will submit the DA Form 7799 with all applicable
signatures and the instrument to HQDA for approval of the RCS

f. The assigned DA IMCO will review the information requirement and if approved assign a RCS number to all
DA Form 7799s for Armywide use

g. The RCS will be added on all DA Forms annotated on the approved DA Form 7799

h. RCSs will expire when the prescribing directive requiring the collection of information is no longer applicable

Pre- scribing directives with a requirement to collect information that are rescinded will also rescind the approved
RCS. If there is still a need to collect data Armywide then it must be outlined in a new prescribing directive and
resubmitted for approval of a RCS. If there is no prescribing directive that includes the need to collect data Armywide,
the AO may submit a request for an extension of the RCS

AR 25–98 • 8 February 2019 5
3 –6. Canceling a report control symbol reporting requirement
RCS reporting requirements that are no longer needed may be canceled before the expiration date. To cancel a RCS
reporting requirement, AOs must—
a. Send written notification to the reporting activities if they have superseded or discontinued a RCS report

b. Update the publication that prescribes the RCS report by issuing a revision or an interim change to reflect the
current status of the reporting requirement. Include this information in the “Summary of Change” once the publication
is rewritten

c. Submit a copy of the written notification, a draft of the revised publication or interim change, and the DA Form
7799 requesting to cancel the RCS requirement to the DA IMCO

d. Coordinate with servicing records administrator to effect disposition of any accumulated records and coordinate
on requirement to change any report specific records disposition

Chapter 4
Multi-Service Information Collection Requirements
4 –1. Purpose
This chapter provides the necessary information for the Army to develop, review, revise, and obtain approval for
multi- Service information collections. It specifies the responsibilities of the Army for responding to collections im-
posed on DOD

4 –2. General information
a. A multi-Service information collection is when information is collected from one or more DOD or Office of the
Secretary of Defense (OSD) components

b. Multi-Service information collections will be approved by the DOD Army internal Information Collections Of-
ficer in the Washington Headquarters Services/Executive Services Directorate Office of Information Management. If
approved, the collection will be assigned a RCS and expiration date

c. There are two groups that make up a multi-Service population, they are as follows:
(1) Active Duty Service and/or military members from two or more DOD components

(2) Federal employees from two or more DOD or OSD components

4 –3. Multi-Service exemptions
a. See DODM 8910.01, Volume 1 for categories of multi-Service collections that are exempt from formal review
and approval procedures

b. Army organizations will notify DA of nonsurvey collections exempt from formal review. If action is needed,
the implementing organization will request a RCS in accordance with this regulation

c. Surveys are not exempt from formal review. All surveys will be submitted to for determination and licensure

4 –4. Approval periods and types of requests
There are several types of multi-service information collection requests. Request types may be combined; however,
there will only be one expiration type and date assigned to the collection. Approval periods vary depending on the
type of collection

a. New and/or reinstatements

(1) Approval period: 5 years

(2) Reinstatements are completed when a RCS is close to expiring and there remains a need to collect the infor-
mation and when the RCS has expired and the component needs to resume the collection

(3) For reinstatements, copies of past results of the approved collection must be submitted to OIM

b. Revisions

(1) Revisions do not alter the expiration date

(2) A revision is a change to an active RCS

(a) Minor revisions require approval forms, cost summaries, or coordination

(b) Major revisions may require coordination of the DD Form 2936 (Request for Approval of DOD Army internal
Information Collections), an updated cost summary, and updated mandatory coordination of the collection instrument

(3) Revisions which increase the cost of the collection by more than $10,000 must go through the full approval
process

c. Extensions

AR 25–98 • 8 February 2019 6

The purpose of this guidance is to update the Information Management Control Requirements Program that reduces costly, ineffective, and redundant information collections (such as forms …

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