93.002:  Records Management and Archiving

I.  Authority and History

II.  Definitions and Legal Requirements

III.  Records Retention Manual

I.  University Records Committee

II.  Records Retention

III.  Inventories and Schedules for University Records

IV.  Removal and Storage of University Records

1. Records for which retention dates have been officially scheduled shall be retained until such time as their retention dates have been reached. The University Records Manager may provide space on a limited basis at a safe, secure records storage facility where units may store records that have not yet reached their scheduled expiration dates. Records maintenance personnel from each unit that is granted permission to transfer records from their unit to the records storage facility must generate and maintain a complete inventory of the records that they are transferring to the storage facility, and they must provide a copy of the inventory to the University Records Manager. The Records Manager will provide records storage boxes to the units transferring records, and the records generating unit will be responsible for packing the boxes and labeling those boxes so that the contents of each box may be easily identified for retrieval or destruction.

2. Some records, which have longer or permanent retention periods, also may be stored on a limited basis at the records storage facility with the approval of the University Records Manager, who may first require the unit to make arrangements to have those records more appropriately preserved (see subsection V, "Preservation of University Records," below).

3. Records that have been transferred to the records storage facility are still considered to be the property of the offices from which they have been transferred, and requests to the University Records Manager for retrievals of copies of those records or for retrievals of the original records in full or in part may be made by the offices from which the records were sent for storage. No record(s) shall be retrieved or reproduced from the storage facility at the request of anyone other than the records maintaining personnel or administrators of the offices from which those records were originally transferred unless permission is otherwise granted by the office from which the record(s) were transferred, except in cases of official University investigation, responding to requests from the Office of Legal Affairs, or for Audit purposes.

V.  Preservation of University Records

1. Records that have been identified in the schedule as "Archival" for their enduring historical value may be transferred to the University Archives upon the approval of the University Archivist. The University Archivist may supply standard size records boxes for units that are preparing to send records to the Archives. University records and the boxes in which they are transferred to the Archives shall be clearly identified and labeled before transfer, and units transferring records to the Archives shall supply the Archives with a complete inventory of the records being transferred.

2. Records that are transferred to University Archives (located in Alden Library) become the administrative responsibility of the Archives, and, unless otherwise stipulated by agreement, such records shall reside permanently in the Archives. Most university records housed in the Archives are subject to unrestricted public access. The relatively few series of archived university records to which access is legally restricted may be examined by staff from the office of origin of those records upon the request of the administrator of that office and in agreement with the University Archivist.

3. In order to help guarantee the preservation, integrity, and security of records that have been turned over to the Archives, access to records housed in the Archives -- whether by the general public or by university staff -- shall be on-premise only. Archive staff may agree to photocopy or scan records for a fee if the condition and integrity of the original records will not be in any way damaged or otherwise altered during the process of placing them on scanners or photocopiers.

4. Section 9.01 of the ORC authorizes microfilming the records of public offices for the purpose of preserving them or for the purpose of conserving space. The Office of the University Archivist and Records Manager therefore urges units that generate large amounts of paper records that have been determined to be of enduring administrative, legal, or historical value to make arrangements to have such records microfilmed. Although digitizing (scanning) has become a convenient way by which to maintain and access records that are retained over shorter periods, microfilming is still the safest, most secure, and most durable means of preserving records that must be retained more permanently. The University Records Manager shall, upon request, supply units with information concerning microfilming.

VI.  Disposal of University Records

1. When a unit head or his or her designee has determined by the retention schedule that records within their unit have reached or have exceeded the legal retention period, and that the records have no further administrative, legal, or historical value, the administrative head of the unit shall arrange for the disposal of those records.

2. Upon the disposal of records, the head of the unit shall sign and maintain appropriate records documenting such information as title, contents, and purpose of the disposed records, legal retention period, as well as date and method of disposal.

3. When the University Records Manager is to oversee the removal and destruction of records that have reached their retention period from the off-site storage facility, as identified in Section IV, the University Records Manager shall first inform the responsible unit, in writing, of his or her intent to destroy those records, preserving a copy of that notice and of the subsequent reply from the unit acknowledging and consenting to the destruction of the records.

4. Records that contain materials that are of a confidential nature -- especially but not exclusively those records that are included under FERPA or HIPAA stipulations -- shall be destroyed in a manner consistent with best practices to reasonably ensure that the data is not recoverable.

5. Some less-formal records that have shorter-lived administrative or legal value are categorized as "transitory." Retention periods for transitory records are usually event-driven, rather than being a fixed period of time. Examples of transitory records include preliminary drafts and notes, used in the production of university records, which are proper to dispose of when those drafts or notes have been superseded or updated by other records; policies and procedures documents that have been superseded or withdrawn (University Archives shall, and other offices may, retain copies of superseded and withdrawn policies); voice mail; and records relating to scheduling meetings and other non-public events. Such records should be retained until they are no longer of administrative or legal value and may then be destroyed, deleted, or purged at any time without acknowledgement or approval of the University Records Manager. For further advice as to whether a record should be classified as transitory or not, please contact the University Records Manager.

VII.  Retention and Disposal Guidelines for Electronic Records

1. Electronic records, including electronic mail (e-mail) messages and personal computer disk files, that document the organization, functions, policies, decisions, procedures, operations, or other activities of a university office shall be considered records in accordance with the Ohio Revised Code definition of records. (For examples of electronic records that are not considered to be university records see the next paragraph, immediately below.) Therefore, all such electronic records that are generated or received by university offices shall fall under all of the regulations established by the federal and state law, and shall be subject to the university policies and procedures for records retention and disposal as outlined previously in this document. For example, the retention period for requisitions that are created or received electronically by a university office shall be the same as the retention period for those requisitions that are generated or received on paper or in any other fixed medium.

   Examples of electronic records that would not fit the criteria for public records as defined by ORC would be e-mail messages of a personal nature that do not pertain in any way to the conducting of university business, even though they were received on university e-mail systems, and messages received from interest-group listservs. These types of records, generally categorized as transitory, may be deleted or purged at any time.

2. The Office of Information Technology will maintain guidelines for the appropriate management of electronic mail online in the "Guidelines for Electronic Mail Retention, Back-Up, and Archiving," at http://www.ohio.edu/technology/security/electronicrecords.cfm.