ARMS Bulletin #1: Fall 1997, revised Summer 2001

425 Steenbock Library
550 Babcock Drive
Madison, WI 53706-1201
Phone: (608) 262-5629
FAX: (608) 262-8899
Email: Records Management 

© 1996-2007 by the Regents of the University of Wisconsin.

Last updated:
August 21, 2001

Originally published:
prior to 2001

A CALL TO ARMS

Information technology has effectively made all of us records managers. The Campus Records Review Group and ARMS are concerned that all University employees recognize and understand the obligation they have to create, maintain, dispose of, and preserve records. This ARMS bulletin outlines records management responsibilities for University employees.

Introduction-Your Work Responsibilities and Records
Wisconsin Public Records Law and University Policies
Records Management Policy and Program Responsibility
Strategy for Approaching Your Department's or Unit's Records
On Leaving Your University Position
Appendices

Introduction-Your Work Responsibilities and Records

The creation, management, and distribution of information are at the heart of what the University is all about. Knowledge and the transmission of it is basic to the University mission:

The primary purpose of the University of Wisconsin-Madison is to provide a learning environment in which faculty, staff and students can discover, examine critically, preserve and transmit the knowledge, wisdom and values that will help ensure the survival of this and future generations and improve the quality of life for all.

A very important part of your job is the management of records and information that is related to your job responsibilities. As part of your University employment, you are provided a number of workplace tools and institutional resources. A number of them relate to the production and management of University records and information.

Records provide:

• Evidence of transactions


• Support for the decision making process


• Documentation of University programs and activities, and


• Resources for future historical research.

We all have a stake in making sure records are efficiently and effectively managed so that University administrative, legal, audit, research and historical interests are served. Furthermore, there are significant legal liabilities and costs associated with poor or inadequate records management practices.

Information technology has had significant impact on the record keeping process. The consolidated subject file or case file stored in the department office file cabinets is no longer the mainstay of record keeping. Technology makes it more challenging to ensure a complete, accurate and reliable record is maintained. "Records" are frequently the compilation of a number of different data elements from databases and can be from varying locations and media. Record keeping is not easy and provides many challenges.

Technology has effectively made all of us records managers. As part of your University employment, you will likely have your own desktop computer or access to one. Standard desktop configurations provide the capability to manage and access databases, email, word processing documents, and spreadsheets. Using these capabilities often results in the creation of University records. While we have all experiences inadvertently deleting something or electronically misplacing a document or part of one, it is our responsibility to abide by University policies and procedures relating to records and information. This brochure outlines basic responsibilities for the management of records and information regardless of media. It also identifies where to go for more information or assistance.

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Wisconsin Public Records Law and University Policies

Records you create while a University employee generally do NOT become your personal property. Official department records belong to the University and must be managed in accordance with established University and State policy. Some incidental personal records are expected and those should be maintained separately. It is recognized that the mission of the University demands the free exchange of ideas and information. For example, communications with colleagues, research activities, etc. generate personal records and communications that would be considered private.

Wisconsin Statues. Section 16.61, Wisconsin's Public Records law and Section 19.32, Open Records Law of the Wisconsin Statutes define public records. These definitions are purposefully broad. Wisconsin government has a long tradition of a strong public access to records policy. Public records represent a key resource in open, representative government, and the presumption is that these records belong to the citizens of the State and are accessible with certain exceptions. (Medical records, student records, law enforcement, and certain other records are exceptions by Statute or administrative rule. Within the University community intellectual property rights protect certain types of research records.)

Administrative Rule 12, effective May 1, 2001, provides instruction and guidance for the management of electronic records.

University Policies. University policies also address the management of records. Faculty Policies and Procedures 6.07 B requires that the University Archivist be contacted prior to the disposition/destruction of any University records.

Faculty Policies and Procedures II-500 describes the mission of the University Archives and Records Management Services (ARMS). ARMS fulfills statutory responsibilities for the University, but it is also a valuable resource for University researchers and for offices that have concerns and questions about the management of records and information.

Other University policies such as Misconduct in Scientific Research and the 1991 Report of the UW-Madison Ad Hoc Electronic Data Advisory Committee Policy include Procedures Governing Access to Electronic Files at the University of Wisconsin-Madison.

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Records Management and Program Responsibilities

Chancellor

Wisconsin Statutes 15.04(I) requires department heads (for the UW System this would be the Chancellor at each institution) to establish records and forms management programs. S 15.04(J) requires the department head to appoint a records officer.

Below is a description of the responsibilities of the campus records management program.

Department Chair

Faculty Policies and Procedures 5.31 C and D state that the department chair has charge of all official correspondence and of all departmental announcements and publications. Also, the department chair determines that all necessary records of teaching, research and public service are properly kept and accessible.

Committee Chair

Faculty Policies and Procedures 6.07 B provides that all faculty committee meeting records and reports are official University records, and that they may not be destroyed without the consent of the University Archivist. This section also outlines chair responsibilities with respect to transferring records to the Archives and transferring active files to his/her successor.

University Archives and Records Management Services

Faculty Policies and Procedures II-500 outlines the role and mission of the University Archives and Records Management Services. ARMS serves not only as an official state records repository for University records of permanent or historical value, but it also provides policy direction and technical assistance to campus departments in meeting their records and information responsibilities. These records guidelines along with several other educational and informational pieces on archives and records management are available through ARMS.

Employee Responsibilities

While no State Statute or University policy that specifically addresses employee responsibilities toward records and information, it is clear that employees engage in activities that directly impact the management of University information. The following is designed as a guideline for use in approaching your records responsibilities.

· The records and information that you create and maintain as part of your job responsibilities belong to the University and the State of Wisconsin. While certain categories of information constitute personal records, they should be maintained separately from records that are clearly part of the University official records.

· Just because your records and information may have been converted to another storage medium, provisions of State law and University policy still apply. For example, a record may be created and stored electronically and no paper copy created; however, it is still a record. The particular storage medium does not affect its status as a record.

· Know your records; what they are and where they are. Can you quickly locate electronic records that may relate to items in your paper files? If something happens to you or someone on your staff that results in unexpected absences and his/her computer contains information critical to a project or major issue, knowing how to access those records can become very important.

· Records regardless of storage media can be subject to subpoena and discovery processes. Effective filing systems for your electronic records can be of great assistance in responding to a subpoena. If you do not have a way of segregating your electronic records, opposing parties can and have taken entire disk drives.

· You need to manage your records and information in accordance with State and Federal regulations. All University records, for example, are subject to provisions of the Statutes relating to records retention scheduling. (See http://www.library.wisc.edu/libraries/Archives/rm/rechome.htm for further information and assistance on records scheduling.)

• For those administering research projects, you need to be mindful of any special records and documentation requirements of your funding agency as well as State and University policies.
• Attention to storage media, maintenance and retention practices, security, and access issues will mean that your data will be available to you and others to use in the future. The time period between major technology platform shifts continues to decrease. Be prepared to migrate, or move forward, any records and /or information that has long term value to you or your department when platform shifts occur.
• It is strongly advised that you establish consistent filing practices. Make sure that you separately identify and segregate private or personal information in both paper and electronic files.
• Destroy/delete information routinely in accordance with established retention policies. Check the University Archives and Records Management homepage for retention information or call the campus records officer if you are uncertain whether your records are covered by a retention policy.
  

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Strategy for Approaching Your Department's or Unit's Records

This strategy can be applied regardless of record format or storage media used.

1. Is it a record?

The first in appraising information is to determine if it is a record. State Statutes identify certain categories of non-record materials; see Appendix B for listing. Such categories of non-records may be destroyed without seeking authorization from the University Archives or Public Records Board. University policies on the appropriate use of information technologies address categories of messages that can be treated as non-records. Identifying non-records narrows the focus of records appraisal and facilitates disposal/deletion of a vast quantity of records and information. However, University departments need to be cognizant of State and Federal laws that establish records definitions and access and retrieval requirements that may impinge on the determination of non-records.

2. Identify the office of record.

Electronic information systems have encouraged the proliferation of copies. For example, e-mail is frequently used by offices to circulate copies of documents. Organizations need to identify which office is the holder of the record copy which will be retained for the full approved retention period. If on a LAN, who will be responsible for shared directories and the identification of which directories will hold the record copy? Identification of the official copy holder enables all other staff members to destroy/delete their copies freeing up valuable disk and file cabinet space.

3. Understand the capabilities of your PC's office product software. Most PCs come equipped with at least word processing, spreadsheet packages, and e-mail. Familiarize yourself with storage technologies used by your office.

Generally, word processing software includes some type of directory/foldering capability. It is advisable that you develop consistent filing structures and practices using that built in capability. Talk with others in your department, and develop consistent practices department wide. This can aid in access and retrieval and be a valuable time saver.

Similarly, use the capabilities of your e-mail system to establish folders, directories, and sub-directories for the daily management of your e-mail. Establish folders and directories that correspond to established filing structures within your office and that correspond with approved retention schedules. Ideally, e-mail messages that pertain to a particular topic or subject should be transferred to the particular filing systems containing that topic or subject. See Item 5 below.

If retention schedules do not exist, establishing a filing system for your e-mail will greatly facilitate the development and implementation of a retention schedule.

Use filtering and other capabilities to automatically file certain categories of messages. For example, listserv information can be automatically filed into one folder or directory. Listerv messages are non-records and can be disposed routinely without further authorization.

If your PC is connected to a LAN, there should be routine backup and storage arrangements available. Become familiar with them, so that you know how your information is being managed on and off line.

There are many opportunities for training on various information technologies. DoIT, the Division of Information Technology, produces a catalog of courses each semester. Some units, such as the General Library System (GLS) offer training programs for their employees.

4. Implement existing retention policies.

For many categories of University records, retention policies already exist. Apply those retention schedules not only to records in file cabinets but to the folders and directories that you have established within your PC directory and e-mail systems.

To learn more about campus retention policies, contact ARMS at 2-3284, or visit the ARMS homepage at http://archives.library.wisc.edu/

5. Linking e-mail messages to other files on similar topics or issues.

At the present time e-mail systems generally are not considered record keeping systems because they do not provide records management functionality, however; offices can establish procedures so that e-mail messages that support or relate to other office files on the same topic can be identified. E-mail messages can be moved to other directories in which related correspondence or information exists.

E-mail records may be copied to an electronic record keeping system if the system:

i. provides for the grouping of related records into classifications according to the
nature of the business purposes the records serve
ii. permits easy and timely retrieval of both individual records and files or other groupings of related records
iii. retains the records in a usable format for their required retention period
iv. allows access to the records by individuals who have a business need for information in the system
v. preserves the transmission and receipt data specified in organizational policies
vi. permits transfer of permanent records for archival preservation as specified in the organization's policies and procedures.

The record keeping copy of e-mail messages may be stored on the electronic mail system or in an off-line electronic format (such as optical disk or magnetic tape) only if the requirements of items (i) through (vi) above can be met. Backup tapes should not be used for records retrieval or retention purposes.

6. Records Disposition versus Records Destruction

Both records disposition and records destruction require an approved records retention schedule. Records disposition includes transferring to the University Archives for preservation as well as transfer to another State or Federal agency. Destruction refers to the physical destruction of the record. Records disposition may also include physical destruction.

Destruction of non-confidential records can be accomplished by merely placing them in recycling containers after the approved retention time has been satisfied. Care should be taken for confidential records. The State Records Center has a contract for the destruction of confidential records.

Destruction/deletion of electronic records must occur within the same framework as with paper records, i.e. an approved records retention schedule must be obtained. An addition, important consideration with regard to electronic records is that deletion must be applied to all backup copies as well. If the backup copies are not destroyed, they remain subject to legal and audit actions.

7. Should I retain my records past the approved retention period just in case I need them?

No, it is strongly suggested that you destroy records promptly at the time the retention period governing them has been completed. There are several reasons for this:

• Retaining records longer than necessary fills up hard copy and electronic storage space making it difficult to access and retrieve those record items that are needed.
• Disposing of records in the normal course of business in accordance with approved retention schedules and procedures demonstrates consistency in records and information management practices. Courts are understanding of records destruction in instances in which the organization can demonstrate that a comprehensive records management program exists and the disposition is carried out on a systematic and routine basis.
• It can be costly for the University in audit or legal action. If records that should have been destroyed remain available and an audit or court action is commenced, they are subject to subpoena and discovery. In the case of audits, if an exception is discovered, penalties can be assessed as far back as records are available.

8. What responsibilities, if any, do I have in the preservation of historical materials from my department?

All records created and maintained by your employing department should be covered by approved retention schedules that designate which records have long term or historical value and should be transferred to the Archives for preservation. The Archives has identified certain items as having permanent value.

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Upon Leaving Your University Position

· Check with your department chair regarding any official University records you may have in your possession and the proper disposition of them.

· Identify active records with directory locations for your successor.

· Seek guidance from the University Archives on the disposition of faculty/academic staff personal papers. The Archives is particularly interested in tracking major research developments which have occurred here, programmatic and instructional developments, and other significant developments relating to the history of the University.

· Clean your desktop computer once you are sure that you have met other responsibilities outlined in this document. This means deleting all records from the directories. Depending upon the intended use for the PC, you may or may not want to re-format the hard drive (re-formatting the hard drive will eliminate all software programs on the hard drive as well). This may or may not be desirable depending upon the anticipated use or user of the PC. At least make sure that all personal items are deleted from your PC.

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Conclusion

ARMS encourages you to take a few minutes to become familiar with University policies relating to records and the resources available to you through ARMS. Becoming acquainted now with your records and information responsibilities can be beneficial to you throughout your University working career. Understanding your records responsibilities will result in improved day-to-day management of your office's records and information, insure that you will be able to respond in a timely fashion to information requests both internally and externally, and insures the systematic retention and disposition of valuable University information resources.

Ann Balough, editor-in-chief of Records & Retrieval Report, has developed five brief guiding principles for the management of records and information. They provide some common sense to records management while recognizing the importance behind it:

• If you don't need it, don't keep it
• If you do need it, keep it in a way you can find it
• The more you keep, the harder it is to find
• When it has outlived its purpose, get rid of it
• If it is worth more, spend more to protect it.

These of course must be applied within the context of State and University records policy, but on the whole the above five basic ideas provide sound advice for the management of records and information.

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Appendix A: Statutory Definition of Records

"'Public records' means all books, papers, maps, photographs, films, recordings, optical disks, electronically formatted documents or other documentary materials, regardless of physical form or characteristics, made, or received by any state agency or its officers or employes in connection with the transaction of public business, and documents of any insurer that is liquidated or in the process of liquidation under ch. 645.
--Wisconsin Statute 16.61(b)

Appendix B: Statutory Definition of Non-Records

1. Records and correspondence of any member of the legislature.

1m. Any state document received by a state document depository library.

2. Duplicate copies of materials the original copies of which are in the custody of the same state agency and which are maintained only for convenience or reference and for no other substantial purpose.

3. Materials in the possession of a library or museum made or acquired solely for reference or exhibition purposes.

4. Notices or invitations received by a state agency that were not solicited by the agency and that are not related to any official action taken, proposed or considered by the agency.

5. Drafts, notes, preliminary computations and like materials prepared for the originator's personal use or prepared by the originator in the name of a person for whom the originator is working.

6. Routing slips and envelopes.

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