Policy No: 2109 Responsible Office: University Libraries Administration Last Review Date: 05/04/2023 Next Required Review: 05/04/2028
Records Disposition Authority
This policy covers the creation, maintenance, and disposition of records (records management) at the University of South Alabama (USA) as specified in the Code of Alabama 1975, Sections 36-12-1, et seq., and outlined in the Public Universities of Alabama Functional Analysis & Records Disposition Authority (RDA) issued by the State Records Commission and administered by the Alabama Department of Archives & History (ADAH).
This policy applies to all USA students, and to faculty, staff and contractors of the University General Division.
Permanent Records: permanent means to retain forever. See sections on Permanent Records and the Permanent Records List in the RDA.
RDA: Public Universities of Alabama Functional Analysis & Records Disposition Authority (RDA) issued by the State Records Commission and administered by the Alabama Department of Archives & History outlines the types of university records considered permanent or temporary, and outlines retention periods for temporary records.
Record: the official copy of any paper or electronic document, e-mail message, file, video, audio tape, microfilm, microfiche, computer disk, website, social media sites, or other communication created or acquired by an employee of USA in the course of conducting his or her job. Under state law, such records belong to the government, not the employee.
Record Custodians: employees designated by administrators across campus to maintain office records in accordance with the RDA and this policy.
Records Destruction Notice: form to be completed by a Record Custodian and submitted to the Records Officer for approval to destroy temporary records in accordance with the retention schedules found in the RDA.
Records Management: policies and procedures with respect to organizing, filing, maintaining, transferring, preserving, deleting, or destroying any document, publication, report, file, video or audio tape, electronic media, microfiche or film, or other communication in any format.
Records Officer: designated individual responsible for ensuring the development of quality record keeping systems that meet the business and legal needs of the university; coordinating the transfer and destruction of records; ensuring that permanent records held on alternative storage media (such as microforms and digital imaging systems) are maintained in compliance with national and state standards; and ensuring the regular implementation of the RDA.
Retention Schedules: time periods for the retention of various types of records as found in Public Universities of Alabama Functional Analysis & Records Disposition Authority (RDA).
Temporary Records: records retained for only their active life that should be disposed of once all fiscal, legal, and administrative requirements have been met. A non-exhaustive list of Temporary Records and their retention periods can be found in the RDA.
4. Policy Guidelines
4.1 Introduction / State Requirements
Alabama law requires public officials to create and maintain records that document the business of their offices. These records must be protected from “mutilation, loss, or destruction,” so that they may be transferred to an official’s successor in office and made available to members of the public. Records must also be kept in accordance with auditing standards approved by the Examiners of Public Accounts (Code of Alabama 1975 § 36-12-2, § 36-12-4, and § 41-5A-21). The Public Universities of Alabama Functional Analysis & Records Disposition Authority (RDA) is issued by the State Records Commission under the authority granted by the Code of Alabama 1975 § 41-13-5 and § 41-13-20 through 21. The RDA lists records created and maintained by the Agency in carrying out their mandated functions and activities. It establishes minimum retention periods and disposition instructions for those records and provides the legal authority for the Agency to implement records destruction.
USA complies with records retention schedules outlined for public universities as established by the State of Alabama. The Public Universities of Alabama Functional Analysis & Records Disposition Authority (RDA) is the primary document used on campus to identify how long certain records should be kept. The retention schedules have been created to protect universities from litigation and other instances where documentary evidence may be necessary.
Public colleges and universities document their compliance with their respective RDAs by submitting an Annual Records Disposition Authority (RDA) Implementation Report to the ADAH each year. USA’s Records Officer submits the annual Implementation Report on behalf of the university.
USA is committed to maintaining its records in an efficient and accessible manner as a vital source of information for its employees, as well as the state’s citizens. Each USA employee is required by law to create, maintain, and protect the records that document the operations of his/her office. USA employees should be aware of the provisions of the RDA because it is used to make decisions regarding the retention and disposition of records, regardless of format.
Records covered by the RDA are to be retained and protected by the custodian of those records until the retention period has expired. When the retention period has been satisfied, the records should be disposed of in the appropriate manner. It is the responsibility of every state employee to follow RDA retention schedules for the records in their custody, as well as to ensure that any personal copies of official records are destroyed or transferred as outlined in the RDA. All employees are also responsible for reporting any actual or threatened loss or removal of records to the USA Records Officer.
USA’s operational records are open to public inspection by law unless otherwise restricted. (See Code of Alabama 1975, Section 36-12-40, et seq.). Record requests may be made during normal business hours (Monday through Friday, 8:00 a.m. through 5:00 p.m.) or as posted by individual offices at USA. However, access to some document types can be restricted, including, but not limited to:
- medical patient records;
- employee records;
- student records;
- library circulation records;
- fragile or brittle records.
The RDA retention schedules for various types of records can be found in Public Universities of Alabama Functional Analysis & Records Disposition Authority on the Alabama Department of Archives & History web site. A copy of the RDA is also maintained on USA’s Records Management site.
4.2 Records Management
Each office will normally store all of its own Temporary and Permanent Records. To free up storage space within the office, Record Custodians should establish cutoff/closing periods for files after which they are boxed up and moved to storage, removed and transferred from employee hard-drives to alternative long-term electronic storage, or transferred to USA Archives. If an office elects to transfer records to an electronic storage medium, it should abide by the recommendations contained in the RDA for storing Temporary and Permanent Records on electronic media, which include, among other things, the creation of a back-up for all Permanent Records and the storage of a back-up copy off-site. The RDA includes the following statement concerning maintaining electronic records:
The agency should maintain full documentation of any computerized record-keeping system it employs. It should develop procedures for: (1) backing up all permanent records held in electronic format; (2) storing a back-up copy off-site; and (3) migrating all permanent records when the system is upgraded or replaced. If the agency chooses to maintain permanent records solely in electronic format, it is committed to funding any system upgrades and migration strategies necessary to ensure the records’ permanent preservation and accessibility. (RDA p. 43)
4.3 Disposition and Retention of Electronic Records
Data or reports, regardless of source, licensing, or ownership, generated by USA employees may or may not constitute a record that must be retained according to this policy. To keep from becoming inundated in a sea of computer output, it is important to establish whether a computer-generated output or report is a record as defined by this policy. When any computer-generated output becomes an integral part of, or attachment to, a record covered by this policy, it must be retained as part of that record for the designated retention period. If the computer-generated output may be needed for audit, legal, risk management, tax, or similar purposes, the chief administrator of the unit or department or the USA Records Officer may need to be consulted.
Electronic documents, communications, files, and databases that serve as university records must be retained for the same time period as their paper equivalents. Data should be stored on University Network Attached Storage (NAS) and backed up or stored in approved cloud storage for the required retention period. Methods of disposing electronic records differ from disposition of paper records because of the way they are stored in cloud storage, computer memory, magnetic tape, and other modes of storage.
Retention of FRS Banner or similar computer system reports is normally the responsibility of the requesting department or administrator. The Computer Services Center (CSC) generally only processes reports requested by departments by pulling certain data from a massive system database. The CSC sends the report to the requestor but does not retain such reports. Records Custodians, therefore, must normally retain all system reports requested by their departments from the CSC for the required RDA retention period. The retention requirements may be satisfied if the ability to create the report from the database exists for the duration of the retention period. For example, data entered into the Banner database pertaining to records of funds deposited outside the state treasury must be retrievable in a legible format for at least three years after the end of the fiscal year in which the data were created. If it is not possible to use the database to satisfy this requirement, it is the responsibility of the department or administrator originating the database entries to satisfy the retention requirements by other means.
4.4 Destruction of Temporary (Non-Permanent) Records
Once the retention period for Temporary Records has expired, the Records Custodian or employee should:
- complete a Records Destruction Notice;
- forward it to the USA Records Officer. Permission to destroy records covered by this Policy must be obtained prior to actual destruction;
- USA’s Records Officer will confirm that the records are eligible for destruction by signing and returning the Records Destruction Notice form to the Records Custodian. Only then can the Records Custodian or employee destroy those particular records;
- USA employees may destroy records using the following methods:
- Discard records in the trash or place in a recycle box when such records do not contain financial, personnel, or other sensitive personal information that should be shredded;
- Shred (required for financial data, personnel records, and sensitive information). There is no centralized office for shredding documents in most administrative or academic offices at USA; most departments are responsible for their own costs for shredding.
4.5 Destruction of Copies & Transitory or Duplicate Records
There are a variety of records that any state employee may discard or destroy without the permission of USA’s Records Officer. No forms need to be completed to discard or destroy convenience or duplicate copies of memoranda, notices, correspondence, reports, publications, or temporary records such as drafts of such material kept solely for easy reference, short-term use, and internal office purposes (so long as the original record is maintained for the required retention period).
Permanent records are those records of enduring value that are kept because of their historical importance, or because they are considered to be records that are vital to the ongoing mission of the University. University Records with a designation of Permanent are not to be destroyed and normally are retained by the department, office, or division that originated them. For Permanent Records originating in academic or administrative units with potential public interest or research value, the University Archives (McCall Rare Book and Manuscript Library) should be consulted. Medical and hospital records are not included here for reasons of health information privacy. Procedures for transfer of records to USA Archives are as follows:
- Fill out the Permanent Records Transmittal Request and an accompanying Box Inventory;
- Submit the request to email@example.com. A request must be submitted to the McCall Library and approved prior to physical transfer. The University Archives will deny or approve transfer of records based on the information provided in the request;
- If approved, McCall Library will schedule a time for physical transfer. Records that have not been approved by the McCall Library, or that have been denied transfer on the basis of status or condition, will not be accepted by the McCall Library;
- Place records into acid-free boxes. The McCall Library will not transfer boxes that do not meet stated specifications. Failure to use boxes specified by the McCall Library may result in a charge to the transferring department:
- Remove records from hanging file folders and place in standard folders. University Archives will not accept boxes that contain hanging file folders;
- Ensure that the records are in a logical order (alphabetical, chronological, numerical, etc.);
- DO NOT put two different record series in the same box;
- Leave a 2 inch working space in each box to permit future reference to records;
- Label the box as follows:
- Write on the front end of the box only;
- Write in pencil only;
- Include the name of the office;
- Include the name and inclusive dates of the record series in the box;
- Number the boxes consecutively, beginning with 1;
- Internal numbering or labeling schemes can be included in the Box Inventory, or written on the box in addition to the consecutive box numbers. Please contact University Archives at firstname.lastname@example.org if you have questions.
Administrators or Records Custodians who are not sure about the confidentiality or privacy of records are encouraged to consult the USA Records Officer, Human Resources, or the General Counsel as appropriate.
No records are to be destroyed that are necessary for agency compliance with requirements of the Alabama Sunset Law of 1981, an agency audit, any legal notice, or a subpoena.
In rare situations, permanent records may be transferred to the Alabama Department of Archives & History when USA no longer has an administrative need or space for the records. However, this storage option can be expensive, and, as a result, requires permission from the USA Records Officer. Information on the transfer process is available on the web site of the Alabama Department of Archives & History at Manage Records—For State Agencies--Transfer Permanent Records.
USA’s Records Officer should be notified if any permanent records have been destroyed, lost, or stolen.
Individuals found to be in violation of this policy may be subject to disciplinary action by the University, up to and including termination or separation from the University.
7. Related Documents
7.1 The web site of the Alabama Department of Archives & History provides details and advice concerning managing public records, including information on suggested file naming conventions, file formats, disaster preparedness, and recovery; a FAQ; and its For the Record blog.