About the CRRG
The Campus Records Review Group (CRRG) is a broadly representative body tasked by the Provost's Office to provide direction and support for the Unversity Records Management program. The CRRG is comprised of UW-Madison employees from different divisions on campus, including Legal, Records Management, Archives, Graduate School, Enrollment Management, School of Medicine & Public Health (SMPH)l, Information Technology, and the Provost's Office.
In 2007, Provost Farrell approved the restructuring of the CRRG to include a diverse membership and expanded the mission to ensure a more collaborative and systematic approach to records management on campus. In 2010 Provost DeLuca reaffirmed the charge and mission to the CRRG.
In addition to offering policy and guidance on records management issues for the UW-Madison campus, the CRRG is also the campus authority for approval of records retention schedules.
The CRRG recognizes that records and record keeping have undergone dramatic changes in recent years and many of our administrative, teaching, and research processes are now totally digitally based or soon will be. Personal computing, digital imaging, document duplication, and the growing use of information technology have expanded both the types of information resources and the volume of records that need to be managed. All of these factors combine to increase vulnerability and associated risks to the University in the management of its institutional information resources.
The CRRG have identified the following as major records and information management issues for the campus:
- Email management. Email is used in innumerable ways across campus. It also represents one of the areas of greatest legal liability as it is most frequently the focus of open records requests and discovery actions. Email messages can be records, and as such are subject to public records laws.
- Digital preservation. Many of our fundamental institutional records are now produced in digital format only. These include course catalogs, enrollment reports, timetables and other traditional documents that have policy and archival value to the University.
- Electronic records management modules. These modules should be a requirement for new recordkeeping applications which will assist University offices and employees manage their electronic records.
- Digital storage. A trustworthy repository that will support the retention and preservation of authentic records is necessary for an effective electronic records program.
- Education and training. The CRRG recognizes the need for awareness, education and training on electronic records management.
Strategic partnerships with information technology and other campus stakeholders will be needed to meet these challenges. The survivability of University archival records depends upon a collaborative infrastructure that supports electronic records management. By working together we can ensure the University's valuable information resources are organized, protected, retained, and remain accessible over time.
Policy & Guidance
The CRRG administers policy and guidance to the campus community on a variety of records management issues. The following are records management policies that apply to UW-Madison.
The University of Wisconsin-Madison recognizes the impact of changing information technology upon its informational resources. These changes have a profound effect upon its corporate memory, and the continued success of its mission. The University Archives and Records Management Service (ARMS) strives to maintain and preserve the University's cultural heritage and meet the institution's records obligations. The University needs to provide increased support to ARMS for the continuing accomplishment of those objectives. ARMS has worked with the University community to meet those objectives in the past and will work to ensure the successful completion of them in the future.
Many of the traditional items in an academic archive are available only in electronic or digital formats. The maintenance and preservation of electronic archives is a shared responsibility requiring the commitment of the information creator, information technology staffs, campus administration, and the archives. This statement of policy principles addresses the continued mission of the University Archives and Records Management Service, the new resources that will be needed, and changed campus responsibilities. It provides the basis for the development of an electronic archives and records management program for the University.
1. The basic mission of the University Archives and Records Management Service is reaffirmed. To ignore the mission is to abandon the preservation of the UW's collective memory and presents legal, audit, and administrative risks to the institution.
2. Information is a valuable institutional resource. It must be managed with the same care and level of detail as are applied to other key resources in and organization. The ultimate goal is to preserve access to the information contained in the electronic systems.
3. University records and information, regardless of form and format, are subject to state and federal records laws as well as University policies.
4. The retention of electronic records is based upon appraisal and analysis of the informational content and context of the records. ARMS conducts records appraisal and works with University departments to determine the retention value of their records and information.
5. The determination of 'record status' is based NOT upon the storage media used, but upon the records-keeping requirements of the office creating and maintaining the information, to the intent to create a record, and the need to provide evidence to support and document University transactions and decision making.
6. The management of records and information in varying forms and formats requires a team approach. Without the active cooperation of the records creator, information technology staffs, legal and audit services, ARMS, and others, sound records practices will not be implemented and the University's corporate memory will not be protected.
7. The management of electronic information resources is complex. There is not likely to be a single solution to the problem of information retention and disposition that is suitable in all situations. Strategies will need to be developed that address a wide variety of technology situations and capabilities; from the individual employee who creates University records in a personal computer environment, to the complexity of hybrid information systems.
8. Each University department must be responsible for migrating or refreshing electronic resources that are scheduled to meet University records-keeping needs or for long term or permanent preservation. University departments must also be responsible for documenting how their information systems work. Without adequate documentation, continued access to the information will be in jeopardy.
9. Although preservation of electronic records may be distributed over the campus rather than physically in the Archives, there will be increased need to provide intellectual control and access to a rich and complicated body of electronic University records. While distributed maintenance and preservation is likely to be the model, ARMS will doubtless be called upon to maintain certain records of institution-wide importance as well as orphaned records. ARMS will need additional resources to administer these institutional assets.
10. Long-term access to and preservation of University records stored in varying electronic media will require the commitment of University staff and resources. Deans, directors, and department chairs will need to provide sufficient support so that it will be seen as a priority, and sufficient work time will be committed to it. The benefits of implementing sound records and information management practices are significant and substantial. They include: reduction of storage costs, reduction in staff time needed for the retrieval of records, ensures legal acceptability of their electronic records, and ensures economies in the migration of records to successive generations of technology and services.
11. The University Archives and Records Management Services must be given sufficient administrative and financial support to carry out its mission in this complex electronic environment. ARMS will need to expand its consulting, partnering, and training roles to meet the demands of new systems, while continuing to do its traditional work.
12. ARMS will need to develop partnering efforts with the General Library System, the Division of Information Technology, Administrative Legal Services, Internal Audit, and other offices to develop and maintain new policies and procedures that will insure the long-term viability of institutional informational resources. For example, such standard items as catalogs and timetables, long determined to be permanent institutional resources, must be maintained to meet the academic needs of past and present students, and to serve the needs of future generations.
These basic principles need to be communicated to the University community, most especially to those groups charged with information systems development and long-term information technology planning. The University Archives and Records Management Services will serve as a resource for those groups and will develop appropriate policy statements, guidelines, and procedures on various aspects of electronic records management.
Administrative Rule 12 requires state agencies who keep official records in digital formats only to ensure that their electronic records are retrievable, accessible, reproducible throughout their stated retention.
At the present time there is not a campus-wide tool suite infrastructure to support digital preservation of institutional records. Departments are responsible for managing and preserving their records throughout the records' lifecycle.
The University of Wisconsin-Madison recognizes the need for appropriate management of its records and information resources from their creation through disposition/destruction. It also recognizes that many institutional records and information resources contain confidential or sensitive information that must be safeguarded and appropriately disposed of in order to protect individual privacy. These guidelines describe the authority and requirements for records disposal within the University of Wisconsin-Madison.
1. The authority for the retention and disposition, including physical destruction/deletion, of University records and information is the records retention schedule. For a listing of approved campus-wide retention schedules, or General Records Schedules, visit the "What General Records Schedules are available?" section of this website. If you need to prepare a records schedule, contact the Campus Records Officer.
2. University employees have a responsibility for the management, including appropriate disposition, of records they create and maintain as part of their job duties. It is further recognized that University employees handle and must have access to client (student, staff, and other) information in order to fulfill their job responsibilities.
3. Generally, paper records that do not contain personal or sensitive information can be recycled. Most routine administrative and financial paper records can be recycled. Recycling containers are available throughout campus.
For the purposes of this guideline, personal information generally includes medical information, account credit information, tax information, and any individual information that may be accessed by the association of one or more personal identifiers.
4. Paper records containing private or confidential information (e.g., personal identifiers, credit card numbers, social security numbers, student academic information, personal financial information) must be confidentially destroyed. The State Records center provides a confidential disposal service. Some private commercial vendors also provide this service, but it is up to the University department to ensure that the vendor meets the requirements of this guideline and also the ARMS publication on off-site storage.
5. It is advisable to render undiscoverable certain types of personal information prior to disposal. This can be accomplished by:
- Shredding. Cross-cut shredding or shredding that results in materials being less than 1/8 of an inch wide.
- Erasing the personal information in the records.
- Modifying or otherwise making the personal information unreadable.
- Taking actions that will reasonably result in no unauthorized individual access to the personal information contained in the records.
6. Encryption can be used to secure confidential or sensitive data; however, it is not a disposal mechanism. University employees are reminded that if encryption is used for official institutional records, care must be taken to ensure the readability of these records throughout their retention life.
7. The Health Information and Portability and Accountability Act (HIPAA) contains specific requirements regarding the disposal of protected health information (PHI). See Chapter 8 of the University Health Information Privacy Manual at: http://www.provost.wisc.edu/hipaa/privacymanual/index.html.
8. The requirement to destroy records also applies to records and information in electronic formats. The sale, donation, scrapping, or internal transfer of University computer equipment requires that all information on the device be deleted in accordance with accepted procedures prior to such sale, donation, or transfer. University records and information contained on storage media (such as floppy disks, CDs, DVDs, videotapes, audiotapes, etc.) must also be appropriately deleted and/or the media destroyed. These forms of storage media cannot be simply put in the trash or sent to Surplus With A Purpose (SWAP) without first being appropriately erased or otherwise evaluated for the deletion or rendering of the information undiscoverable.
9. University employees must have appropriate guidance and training about the appropriate management of records disposition/destruction.
Please read the ARMS Bulletin "Records Disposition & Destruction" for more information.
The CRRG has also developed common language to be used when creating RDAs to facilitate consistency and the proper application of policy. A complete listing of the common language can be found in the "Is there common language used in RDAs?" section of this website.
Laws, Regulations & Policy:
Additionally, there are laws, regulations and policies developed by other campus departments, the UW System, and state and federal agencies that have records management implications. The following are links to laws and policies affecting the management of University records:
- Legal Requirements for Public Records:Reference document describing the various state, federal, and university-wide laws and polices that must be followed when managing University records.
- Public Records Management Guidelines (UW System): List of voluntary guidelines derived from internationally-accepted best business practices for records management. The Board of Regents provides these guidelines as a business resource for University institutions, and also recognizes that these guidelines will be utilized as best suits the business needs of each institution, within the controlling limits of University of Wisconsin system-wide policies.
- Employee Ethics and Public Records Management (UW System): Every University of Wisconsin employee is obliged to abide by legal requirements for ethical conduct and proper management of public records, as set forth in multiple Wisconsin statutes. In order to assist UW employees in understanding and abiding by these requirements, the Office of General Counsel has published guidance, entitled: “Employee Ethics/Public Records Management."
- Faculty Policies and Procedures, specifically chapter 5.31 C & D and 6.09 B: These chapters address records management responsibilites and duties for department chairs and faculty and ad hoc committees.
- Faculty Legislation, II-500: Legislation governing the authority and responsibilities of the University Archives.
- Information Technology Policies: Provides links to IT policies that apply to UW-Madison. Please note that not all of the policies listed on this website have records management implications.
Additional policy information for the campus on a wide range of issues can be found in the policy section of the UW-Madison website.