How to inventory a document collection

A count is an inventory result, not a legal conclusion

There is no universal document count, age cutoff, or download threshold that determines a public entity’s Title II obligations. Scope and exceptions require the actual facts. Read DOJ’s rule and exception guidance.

Discover the collection safely

Suggested workflow: combine approved website crawling, content-management exports, owner interviews, and known service inventories. Record the crawl boundary and inaccessible or authenticated areas. Public crawling alone does not establish that every document or system was found. Do not bypass access controls or gather private submission data.

Record useful fields

• Document URL, title, format, version, and owner.
• Evidence of when it was made available.
• Current program use and affected user tasks.
• Known barriers and the checks actually completed.
• Candidate exception, supporting facts, reviewer, and unresolved questions.
• Duplicate or superseded versions and authorized retention decisions.

These are suggested operational fields, not a legally prescribed form.

Keep samples distinct from totals

A sample can help understand complexity and plan further review. Do not multiply an informal sample’s percentage across the entire collection and present the result as a verified compliance count. Record sampling method, exclusions, uncertainty, and whether the sample supports any proposed inference.

Use the inventory to plan work

Separate discovered files, reviewed files, confirmed barriers, unresolved scope questions, and approved decisions. Apply the actual conditions for preexisting documents and archived content; “old” or “rarely downloaded” is not enough. Prioritize work using user impact and current use.