Records Management Basic Training University of Texas at Austin Records Management Services

Our Agenda What is a record? Why do we have to manage them? Who is responsible for managing them? What do I keep and what do I throw away? How do I dispose of records? How often do I need to review and purge records?

What Is a Record? A record captures or documents the relationships and transactions between the university and our students, faculty, staff, donors, and sponsors as well as with the general public and governmental entities. Records contain information with business, legal, compliance, operational, or historic value. 13 Texas Administrative Code, Title 13, Part 1, Chapter 6, Subchapter A: Definition of a State Record State record--Any written, photographic, machine-readable, or other recorded information created or received by or on behalf of a state agency or an elected state official that documents activities in the conduct of state business or use of public resources. The term does not include library or museum material made or acquired and preserved solely for reference or exhibition purposes; an extra copy of recorded information preserved only for reference; a stock of publications or blank forms; or any records, correspondence, notes, memoranda, or other documents, other than a final written agreement described by §2009.054(c), associated with a matter conducted under an alternative dispute resolution procedure in which personnel of a state department or institution, local government, special district, or other political subdivision of the state participated as a party, facilitated as an impartial third party, or facilitated as the administrator of a dispute resolution system or organization.

What Is a Record: Life cycle of a record Created through interaction between the university and its constituents Active—the record is used in business processes Stored to meet regulatory requirements or to support decisions or actions throughout audit and dispute cycles Disposed Destroyed Archived

What Is a Record: It’s not the medium…it’s the message! Retention requirements apply to: PDFs and imaged records. Electronically Stored Information (ESI). correspondence in any medium that is declared as a record based on its content. good old paper documents. Requirements apply to master records in all media and all formats. Review the content to determine the retention category.

Why Do We Do This? State Law sets records management authority and responsibilities for the Texas State Library and requires the establishment of a Records Management Officer for each state agency. It also sets forth requirements for each state agency to develop a records management program and a records retention schedule and establishes standards for retention of electronic records and the destruction of records containing confidential information. Federal Law sets retention requirements for documentation of federally regulated activities or funded programs.

Why Do We Do This? Texas Government Code 441.183 et seq Texas Administrative Code Title 13 Part 1 Chapter 6 Subchapter A Code of Federal Regulations

Why Do We Do This: To minimize risk and lower liability In the event of a lawsuit, audit, or request for public information, will we have the required documentation? Records must be retained and available throughout the life-cycle. Record retention requirement calculations are based on statute of limitation requirements, state and federal regulatory requirements, cycles of dispute, and business practices. Records must be kept as long as required and destroyed soon after retention requirements are met. Consistent and routine management of records demonstrates a good faith effort to comply with legal requirements. Available has an important meaning in records management. For electronic records this means to be individually retrievable. Backup tapes are not considered an acceptable method for records storage. Record retention requirements are developed in response to the different reasons the record might be needed. The calculation is intended to identify the point at which the record is no longer required and keeping it longer would represent a liability. Keeping records longer than required means keeping MORE records, the more records we keep the more formidable finding one record may become.

Why Do We Do This: To provide efficient and transparent business processes Good records management practice supports the goal of getting the right information to the right people at the right time. Knowing which documents and information should be retained, why they are retained, and how long to retain them reduces clutter and streamlines workflow. Well organized and managed information is quickly and easily retrieved when required. Awareness of the requirement to retain records to support actions and decisions enhances transparency in governance. You don’t have to keep everything! Even if, at first these practices seem burdensome and like one more thing you have to do… eventually I think most of you will see the liberating benefit of being able to dispose of things that you don’t need to keep.

Why Do We Do This: To preserve our institutional story University archives are kept at the Center for American History. The archival value of a record series is determined at the time the record series is added to the UTRRS. Staff judgment of the historical value of records not listed as requiring archival review is valuable. You are often the experts on the significance of some records. Again, it would be much harder for future historians to sort through the sheer volume of information we produce and proliferate if we were to try to keep everything. So we can’t do that, but we surely do want to keep the information that will tell the story of who we are and what happened in our time at this great institution we serve. The office of the state archivist reviews the UTRRS to ensure that all the appropriate records series are identified as requiring archival review or transfer. The acting UT archivist reviews any records that require archival review and oversees the transfer of historically significant records into the UT archives.

Who Is Responsible? Everyone! Everyone is responsible and accountable for keeping accurate and complete records of the business activities they conduct. Who here is a Department Records Management Contact? Who knows who their DRMC is? Know your Department records management contact Know where to store records Maintain files on a regular basis Get authorization before destroying records Do not keep convenience copies after the master copy has been destroyed Dispose of confidential information appropriately.

Who Is Responsible: University roles and responsibilities Texas State Library and Archives Commission—mandates records management rules and requirements for all state agencies; it develops the state records retention schedule. Records Management Officer—develops university records management policy, administers university records management program, manages University of Texas at Austin Records Retention schedule, maintains the records disposition log, and provides training and support for department records management contacts and university staff.

Who Is Responsible: University roles and responsibilities Department or Unit Heads—designate Department Records Management contact in the university department system; they review and approve Requests for Internal Authorization to Dispose of Official State Records. Department Records Management Contacts—develop and maintain departmental procedures and retention plans; they prepare the Request for Internal Authorization to Dispose of Official State Records form; they oversee disposal of documents.

What Do I Keep. . . . . . and what do I throw away? Meet the UTRRS: University of Texas at Austin Records Retention Schedule is a list all of the records created in the course of university business and the retention requirement for each one. The UTRRS contains all the information you need to determine which records to keep and which may safely be disposed. The UTRRS is meant to describe and support our business practices. It should make it possible to dispose of information and records that are no longer required.

What Do I Keep: Master records vs. convenience copies The UTRRS sets retention requirements for master records. State law requires documentation of disposition for master records. Convenience copies can be disposed when they are no longer needed and do not require RMS authorization to do so. Caution: Do not retain convenience copies past the retention requirements of the master record. When we talk about managing records we must first distinguish between Master records and convenience copies. The “Master record” is sometimes called the “copy of record” or original. It is the recording or documentation of a transaction or interaction that we are required to retain. “Convenience copy” refers to any copy made of the original for reference or convenience of multiple users. All copies were once inconvenient and a lot of them still are. First they were hand copied, later there was carbon paper… but now it is easy to reproduce multiple copies of the original record. Sometimes we create copies, in the form of electronic images which we intend to replace the original record, and this is fine, we can declare the image to be the Master record and that renders all other copies including the original hard copy to be convenience copies. Even though retention rules apply to master records, it is important to manage or have plans for disposing of convenience copies as well. Consider investing in a convenience copy rubber stamp. When you make a copy before sending off the original, stamp your copy, along with a destruction date, when possible. Do not retain convenience copies past the retention requirement of the master record, because the convenience copy becomes the master record if it exists after the master record has been destroyed. The non-existent UT records management police will not come knocking at your door if you do keep them longer, but you are creating an unnecessary risk. If you feel you have a legitimate reason to keep copies past the required retention period of the master record, please consult with RMS to verify. Know where master records are stored: The Image Retrieval System HR- Web guidelines http://www.utexas.edu/hr/hrpro/appt/files.html Student Records

What Do I Keep: Transitory information Some examples of transitory information, which can be in any medium (voice mail, fax, e-mail, etc.) are routine messages, internal meeting notices, routing slips, and similar routine information used for communication but not for the documentation of a specific university transaction. Records of temporary usefulness that are not an integral part of a UTRRS records series, and that are required only for a limited period of time for the completion of an action or in the preparation of an ongoing records series. Transitory records are not essential to the fulfillment of statutory obligations or to the documentation of agency functions. It is very important to dispose of transitory information in a timely and consistent manner.

What Do I Keep: Retention requirements State Codes The State records retention schedule (RRS) sets minimum requirements for records managed by all state agencies. The UTRRS contains reference links to corresponding State RRS codes. State minimums must be observed for any university record that serves the same purpose as the record listed in the state RRS. The State RRS does not set requirements for “program records”. That is the programs that are specific and unique to each agency. We have considerable latitude in setting requirements for records that do not correspond to state records.

What Do I Keep: Retention requirements University Codes AALL codes are developed for general use by all departments. Department codes are developed for specialized department records. University codes must be used for all requests to dispose of records. There should be a UT code for each record created in the course of university business and activity. If, in the course of your operations, you create records that are not listed in the retention schedule, contact RMS.

What Do I Keep: Retention requirements Archival Review Requirements Archival review requirements for entire record series are set at the time the record series is added to the UTRRS. UTRRS archival review codes I = Transfer to the university archives O = Review by archivist UTRRS codes requiring archival review are printed in red in the UTTRS

What Do I Keep: Retention requirements Vital Records Vital records are records necessary to the: resumption or continuation of university operations in an emergency or disaster. re-creation of the legal and financial status of the university. protection and fulfillment of obligations to the people of the state. UTRRS is guided in designating record series as vital by the State RRS. UT vital records in electronically stored formats are generally managed by IT policies and procedures Department record management contacts need to be aware if their office manages hard copy vital records

What Do I Keep: Retention requirements Retention Codes AC = After close AV = As long as administratively valuable CE = Calendar year-end FE = Fiscal year-end LA = Life of asset PM = Permanent US = Until superseded Some retention requirements are simply expressed as years. General correspondence is retained for 1 year. This means that a record dated 1 year plus 1 month ago may be destroyed. A record dated November 6, 2007 may be destroyed on December 1 of 2008. Say you have two VP7 records , one is dated July19, 2000 and the other is dated September 3, 2000. The retention requirement is FE + 8. The fiscal year end date for the July 19 document is August 31, 2000. So we add 8 years to the fiscal year end date and we can destroy the July 19 document on September 1, 2008. The fiscal year end date for the September 3 document is August 31, 2001. Add 8 years to that date and the September 3 document may be destroyed on September 1, 2009. Calendar year end works the same way as fiscal year end. If a record with CE + 1 retention is dated December 12, 2007 the calendar year end date is December 31, 2007, so it may be destroyed on January 1, 2008. If the record is dated January 3, 2008 its calendar year end date is December 31, 2008 and it can be destroyed as of January 1, 2009. AV records retention requirement is determined by the user. Any regulations or requirements to retain the record still hold. And for the sake of consistent treatment it is important to have internal guidelines for records with an AV retention requirement.

Now it’s time for a visit to the UTRRS online! Describe the anatomy of a record series entry: State code - when there would or would not be a corresponding state code UT code -this is what is used to request authorization to dispose Record Series title -general name for a broad category of records-you may use more specific title in your department, but enter this title on the request to dispose form Archival requirement -red entry and archive codes Vital record designation Retention requirement Comments Show the interactive features of the PDF Look up and interpret three codes for records commonly managed in departments: Payment Vouchers Recruiting Records Tests and course materials

How Do I Dispose of Records? The end of the life cycle of a record: Destruction Archival Transfer

How Do I Dispose of Records? Request for Authorization to Dispose of Official State Records A request must be submitted and approved prior to destroying any Master Record. The request form provides the essential information to complete the records disposition log that is required by state law. Failure to maintain complete and accurate disposition logs exposes the university to serious risk in the case of lawsuits, public information requests, audits, and other claims and disputes.

How Do I Dispose of Records? Request for Authorization to Dispose of Official State Records Incomplete logs and inconsistent application of retention requirements strips away the protections that good faith records management programs provide. Request to Dispose: www.utexas.edu/business/accounting/retention/ disposeforms.html

How Do I Dispose of Records: Disposition requirements Master Records Prepare and submit a request to dispose form Wait for authorizing letter Dispose per authorizing letter instructions Notify RMS after the disposition of the records Convenience copies—may be disposed without authorization when no longer needed Transitory Information—should be routinely disposed as soon as it has served its purpose Even if a record met retention requirements 50 years ago, a request to dispose form must be submitted and destruction must be authorized before disposing of the record. Even thought transitory information is listed in the retention schedule and has a UT code, AALL083, it should not be listed on request to dispose forms.

How Do I Dispose of Records: Confidential information Any record (master record, convenience copy, or transitory information) that contains confidential information must be destroyed in a manner that preserves confidentiality. Do not place records containing confidential information in a blue recycle bin! Austin Task is the authorized vendor for disposing of records containing confidential information. Do not use facilities services to dispose of records containing confidential information. You may shred records within the department. Resulting shred may be placed in recycle bin. You may contract with other venders, but check with RMS before proceeding.

Caution! Even if a record meets retention requirements it may not be destroyed if any litigation, claim, negotiation, audit, public information request, administrative review, or other action involving the record is initiated, impending, or imminent until the completion of the action and the resolution of all issues that arise from it.

How Often Do I Need To Review and Purge Records? At least once per year. Document departmental records management procedures: www.utexas.edu/business/accounting/retention/ checklist.html Be routine and consistent in management and disposition of records in accordance with the UTRRS, university records management policy, and written department procedures. You can inventory and dispose of records at any time throughout the year. As we will discuss, the departmental records management procedures will include expected times for document destruction. You may want to include two or more times per year on an as needed basis. But you should plan to dispose of records at least one of the designated times every year. One suggestion is to do this in the month of October which is close to fiscal year end, and a bit after the fall semester has begun. Such a policy statement might read: A review and purge of records that have met retention requirements will be conducted every October. Further reviews may be conducted in March and July of each year if needed. On the other hand some departments have a need to dispose of records on a monthly basis because they are managing a record series that requires immediate disposition of a master record once its purpose has been served. This should be noted in the review and purge process as well. Scheduling disposition establishes and supports a claim of routine disposition. Consistency is established by uniform treatment of records series within a department and across departments. If you request to dispose of a record series for a date range, you are expected to destroy every record

How Often Do I Dispose of Records: Departmental procedures List the department Records Management Contact and other records management roles and responsibilities. Inventory records to be managed. List retention practices for records with AV retention requirements. List retention practices for any records that you routinely retain longer than UTRRS requirements The records management contact is responsible to receive information and training from RMS and communicate records management policy and procedure to department administration and staff. Other staff records management duties and requirements should also be listed. You may wish to include departmental records management orientation materials, as well as ensuring there is a records management component in the separation process. Staff tasked with managing or disposing of records, but are not the designated records management contact, may want to subscribe to the UT-RETENTION mailing list to receive news and updates on records management policy. The records inventory is the process of identifying the records, convenience copies, and transitory information that you are responsible for managing. Then correlating them to records series in the UTRRS. This can be much more difficult than it sounds, and you are encouraged to seek support, either through writing to records management services, or call 232-5647. I am happy to help--from talking through how to categorize a single record to making an office visit to discuss a range of questions that arise prior to or during a records inventory.

How Often Do I Dispose of Records: Departmental procedures Document review and purge procedures and schedule. Document automated disposition protocols for ESI. Document any activity that results in the destruction of records. The records management contact is responsible to receive information and training from RMS and communicate records management policy and procedure to department administration and staff. Other staff records management duties and requirements should also be listed. You may wish to include departmental records management orientation materials, as well as ensuring there is a records management component in the separation process. Staff tasked with managing or disposing of records, but are not the designated records management contact, may want to subscribe to the UT-RETENTION mailing list to receive news and updates on records management policy. The records inventory is the process of identifying the records, convenience copies, and transitory information that you are responsible for managing. Then correlating them to records series in the UTRRS. This can be much more difficult than it sounds, and you are encouraged to seek support, either through writing to records management services, or call 232-5647. I am happy to help--from talking through how to categorize a single record to making an office visit to discuss a range of questions that arise prior to or during a records inventory.

Questions?