First, the “departing official or a staff member must prepare an inventory of personal papers and nonrecord materials proposed for removal.” The departing official must then “request a review of the materials proposed for removal.” Lest Mrs. Clinton claim she was not subject to this rule, the manual provides that this review process is specifically required for “Presidential appointees confirmed by the Senate.”

The purpose of this independent review by records officials (as opposed to simply accepting the say-so of the departing official) is “to certify that the documentary materials proposed for removal may be removed without diminishing the official records of the Department; violating national security, privacy or other restrictions on disclosure; or exceeding normal administrative economies.” The process “generally requires a hands-on examination of the materials to verify the accuracy of the inventory.” (5 FAH-4 H-217.2(b)).

Finally, there is a formal certification by the State Department records official authorizing the employee to remove the documents from State’s custody: “Once the reviewing official is satisfied that documentary materials proposed for removal comply with Federal law and regulations the reviewing official completes Form DS-1904, Authorization for the Removal of Personal Papers and Non-Record Materials, and forwards the form and the inventory to the Department of State records officer.”