RECORDS MANAGEMENT COMMITTEE
MEETING NOVEMBER 1, 1999
AGENDA
DISCUSSION
Arizona Conference on Electronic Records
General
The conference centered on retention rather than disposition. There were discussions of the legal aspects of retaining records—privacy requirements, ownership of records, and access to records. Records management requires collaboration between records specialists, archivists, and auditors.
Electronic Records
There is a critical need to become knowledgeable about electronic records: detecting alteration of electronic records, consequences of storing metadata (descriptive data on electronic records), the availability of deleted records and earlier versions of records for the legal discovery process.
The Committee should obtain legal and technical advice on electronic records to determine what UC is doing and what it should do. The RMP series should include warnings, if not policy statements, concerning the dangers unique to electronic records: unintentional retention of draft and deleted data, as well as problems in preserving electronic records in light of changing electronic formats.
Available Guidelines
Anne Gilliland Swetland, Assistant Professor at UCLA, was one of the Arizona conference speakers. She is Co-director of the U.S. InterPARES project, a research project examining issues related to the short- and long-term durability, accessibility and usability of electronic records systems. See: http://is.gseis.ucla.edu/us-interpares/
Some federal departments have drafted guidelines on electronic records: Health and Human Services (HHS), Department of Defense (DOD), and the U.S. Archivist. The Managing Electronic Records (MER) conference at http://www.cohasset.com
provides online information on this topic.
Investigation of the Functional (or General) Retention Schedule Method
An action item from our last meeting was to produce a sample functional schedule, using a small subset of University records, so that the Committee might assess whether this method will work at UC. Although the planned experiment utilizing the Retention Manager software was not successful, a real life example of a large university system using this method was located and evaluated.
The Oregon University System
Oregon University System (OUS) is a diverse multi-campus system similar to UC in that it has a system headquarters that functions much like UCOP, and includes research universities; Oregon State University (OSU) and University of Oregon are part of the system. At most locations the records function is understaffed and many functions have been decentralized. OUS differs from UC in that it has no health sciences, and has less autonomy from state government.
The OUS Schedules
The OUS Records Manager, with a great deal of assistance from the Archivist at OSU, took the seven existing retention schedules (some more than 400 pages in length), identified common series of records, and created one functional (or "general") schedule for use by all locations. The individual campuses may modify the general schedule to some degree, or use it as is.
The schedules do not itemize records but have one-paragraph descriptions of categories of records. The schedules have 21 major categories and approximately 400 record groupings ("series" or "types"). By comparison, the current UC schedule has 9 chapters, 61 major categories, and approximately 1,300 individual "generic" records.
The original OUS schedules were developed in 1991-1992 and they expire every five years. The schedules became part of the State of Oregon Administrative Rules. The system uses the "keep forever if not listed" rule. The OUS schedules can be found online at: http://www.ous.edu/archives/schdmain.html
Other Systems' Schedules
Another example of a university utilizing the functional schedule approach can be found on the University of Missouri system Web site. Look online at:
http://www.system.missouri.edu/records/RecRetGd8.html
The University of Michigan's procedures will be investigated, as U-M is a similar institution to UC in terms of structure and relationship to state government. California State University schedules may not be useful because CSU is a state agency and likely follows generic California State guidelines.
Evaluation of "Retention Manager" software
The attempt to map a small section of our current schedule into Skupsky's software was instructive, if not very successful. The Retention Manager categories and jargon are skewed toward a business setting. As we expected, many categories of records we have at UC are absent: student, medical, and police are examples. The exercise pointed out that even within the different University operational areas, vocabularies are specialized; internal specialists from the operational areas will be a key component to any revision strategy we develop.
Legal Research
There may still be value in Retention Manager when we get to the point of needing legal research. By one estimate, it may handle 50% of the legal research, which would save General Counsel and others lots of time. Again, functional area specialists will need to be involved.
Recommendations
There was concurrence to move ahead with a plan to convert the existing, out-of-date detailed schedule to a functional schedule, utilizing the OUS experience as a model. There was acknowledgement that this may result in some records being kept longer than strictly necessary to conform to a broader category, however the trade-off seems worthwhile given the benefits the University will derive from moving to a process that can be kept current in our decentralized environment.
Proposed next steps are:
Questions
As we strive to create a more user-friendly document, some of the questions that come to mind are:
RMP-1 and RMP-2
Merger of RMP Bulletins
There were good arguments for and against (1) having the records policies all remain separate, (2) merging RMP-1 and RMP-2 and having the remaining policies remain separate, or (3) merging all the records policies into one overall policy. The Committee agreed to revise the RMP bulletins separately and merge them later if there is too much repetition among them.
Definitions
There was consensus that one set of definitions in should apply to all the RMP bulletins and the definitions should be repeated (i.e. have the same wording) in each bulletin. The Committee also agreed that definitions should be placed at the front instead of the end of each bulletin.
The old term "office of record" could apply to either the "record proprietor" or the "record custodian." "Office of record" also makes clear which are the official rather than "other copies" of records. Use of the word "delegated" in the definitions is not clear in some campus situations; members of the Committee prefer that the definitions refer to heads of operational units rather than functional area managers.
University record, administrative record
In deciding whether "University record" or "administrative record" should be used, the Committee noted that all administrative records are University records, while academic records may be either University or non-University records. The applicability of the RMP bulletins to UC medical centers was not clear, and student health and counseling records are not distinguished from other records. The bulletins should also clarify the inclusion or exclusion of electronic records as needed.
Accountability and Responsibility
The sections on accountability and responsibilities should be merged. The focus should be on outcomes rather than positions.
Annual Reporting
Annual reporting in the old RMP-2 implied control of disposal. However, when campuses are not staffed for disposal it seems foolish to require activity that implies monitoring records. On the other hand there are dangers both in keeping records too long and in disposing of them too quickly—so the policy must require retention and disposal, as well as include a requirement to refer questionable items to management.
ACTION ITEMS
Policy
Martha Winnacker, Meta Clow, Penny White, Linda Arquieta, Meredith O'Connor (federal regulations)
Topical Areas
Connie Williams, Penny White, Linda Maczko, Dayoan Rivera, Mike O'Neill (stage 2)
NEXT MEETING
The next meeting will be scheduled for the beginning of February 2000.
The group prefers meeting in Oakland. Future meetings will held from 9:30 to 2:30 instead of 10 to 3 o'clock.