Off Site Storage Policy

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:
June 11, 2003

Originally published:
June 11, 2003

University of Wisconsin-Madison
May 2003

Purpose: This policy defines the framework for the selection of off site records storage facilities that will be used to store and maintain official University records. It recognizes that records and data are University resources and must be maintained in facilities and under conditions that will ensure their protection and accessibility throughout their retention life. It further recognizes that campus departments and offices have choices in the area of records storage, but in exercising those options they need to be mindful of the need to meet basic records responsibilities.

Policy:

1. Prior to sending records and data to off site storage facilities, departments will ensure that University records are appropriately identified, appraised, and scheduled.
2. Departments will assign a permanent staff member the responsibility of maintaining documentation about the records maintained off site and coordinating with the Archives and Records Management Service, ARMS.
3. Departments shall notify ARMS of records that have been appraised as having permanent or archival value that are located in off site storage facilities.
4. It is recommended that departments and offices consult with the ARMS prior to contracting with an off site storage vendor, so that appropriate criteria are used in the selection of a vendor. (Departments planning to use the State Records Center for off site storage must contact ARMS to establish contact information and to verify status of records retention schedules.) See ARMS Bulletin # 8.
5. If storage vendors will carry out destruction of confidential, personally identifiable data, or PHI (protected health information) departments need to make sure that all proper notification has taken place and that destruction is in accordance with State, Federal, and or University policy guidelines.(For HIPAA see Health Information Privacy Manual, Section 8.7 http://www.wisc.edu/hipaa)
6. Departments storing data or records meeting HIPAA (PHI) records definitions with a commercial vendor shall make certain that those records/data are appropriately stored, meet HIPAA security standards, and that all notifications have been met prior to final disposal. The vendor must have a Business Associate agreement with the University as requirement for storing PHI data. (See Health Information Privacy Manual, Section 6.1)
7. The storage of electronic records requires attention to specific considerations. If departments are storing electronically formatted data some or all of the following may be appropriate:
   

Storage of Electronic Records

• Electronic records are often housed on impermanent physical media and are subject to constant technological change.
• Access to information is limited when machines necessary to read these records fail and cannot be replaced. To ensure access to information, copy older formats onto a stable technology while playback machines remain available.
• Computer disks and diskettes should be stored vertically within paper boxes. Neither the boxes nor disks should lean or slant, which causes deterioration.
• Plastic cartridges should never be removed; nor should the cartridge shutter be opened to expose the digital optical disk's recording surface. To protect disks from warping, they should not be subject to pressure.
• A sample of stored electronic records should be checked annually to ensure continued accessibility and readability.
  Imaging system data that are maintained on electronic media must be recopied onto new media at least once every ten years. A comprehensive migration strategy should factor in vendor stability, system obsolescence and media longevity.
• Security copies should be marked with appropriate external labels that identify the University department/office, system and software used, any access restrictions, and date. The department/office should maintain specific, detailed documentation of the contents and the system specifications needed to access each security tape or disk. Labeling is critical when the data and its index are stored on different media. Labeling should include:
  • Data Description / Date
  • Format of the data
  • Software used to generate/process the data and version and operating system required
  • Date the data were last read /checked
• Security copies must be stored off-site.
• Electronic records must not be subjected to magnetic fields.
• The manufacturer's specifications of environmental conditions for the storage of optical disks must be followed.
• Annual department budget calculations should include an amount between 15-20 percent of the original system acquisition cost for upgrades, training, and maintenance. Unless these costs are factored into the continuing support of system maintenance and improvement, the system is in danger of becoming obsolete and requiring a far greater cost outlay to restore its effectiveness. Continued planning and budgeting for the migration of long-term and archival records is essential for the success of any digital imaging project.

* This policy was endorsed by the Campus Records Review Group, May 22, 2003.