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Best Practice and Required Procedures

The VCU Records Management policy stipulates that departments must have written procedures for records management. What should these procedures entail?

Specific records procedures are necessary if your area has limited written processes in place about your documentation or has several record types that are not already covered in some kind of procedure. The records management procedure template for departments can be found here.

Otherwise, if your department/unit/functional area already has written processes in place about the documentation you create and store, then adding the following statement to those policies is sufficient:

"Documents referenced within this procedure that are deemed public records must be retained and destroyed in accordance with the VCU Records Management policy and time periods listed in the Library of Virginia’s record retention and disposition schedules."

I have always filed a group of similar records together for storage and retrieval, but the file as a whole is made up of documents belonging to different record series with different retention periods. What should I do?

The Virginia Public Records Act is clear that retention periods must be followed regardless of individual effort or cost to the agency. Going forward, please consider separating out or tagging individual documents so that it is easier to locate the ones that are expired. In the meantime, it is recommended that you wait until the longest of the retention periods has passed, then reporting all of the record series that exist within the file as a whole for destruction at that time.

What is the best way to set up a shared network drive?

By record type as well as by year. Subfolders assigned to certain individuals can still be set up within the larger structure, as long as all users are able to retrieve a specific kind of record created at a specific point in time quickly and easily.

How do I go about getting rid of a large amount of paper files?

VCU uses a document shredding service provided by Shred-it. You may request shredding or temporary shred bins by placing a work order in QuikFM. Select "Document Shredding" in the Problem Type drop down menu when creating the new order. Please keep in mind that before destroying public records, a Certificate of Records Destruction (RM-3) form must be completed and approved by the University Records Officer.

The record disposition says "Permanent, Archives" or "Permanent, In Agency" and we're running out of storage space for paper files.  What should we do?

Records that are deemed permanent by the Library of Virginia must be retained, but there are options:

  1. Transfer to University Archives - The VCU Libraries maintains archives containing University permanent records and historically significant artifacts.  Record transfers (ad hoc or regularly scheduled) can be coordinated by contacting Jodi Koste at (804) 828-9898 or jlkoste@vcu.edu. University Archives are located on the Monroe Park and MCV campuses for ease of records access.
  2. Reformatting - In many cases, it is acceptable to convert paper records to electronic format for long-term storage.  See Library of Congress's 2017-18 Recommended Formats Statements for acceptable formats and Technology Services' Where Can I Store My Data? page for approved systems.  After reformatting, the paper version is considered a convenience copy and does not need to be retained permanently in most cases.  
    Exceptions:
    1. Legal/Contractual Requirements - In rare cases, legal retention requirements or contractual agreements forbid reformatting.  If you are uncertain, consult with leadership in your department or university counsel.
    2. Record Holds - Do not destroy copies if there is an active or pending audit, investigation, legal hold, FERPA or FOIA request.
    3. Historical Significance - For VCU, anything that dates to the RPI or MCV years (prior to 1968), and also materials from the formative years of the University (1968-1974), should be reviewed for historical significance. In addition, photographs, significant events or programs, events or programs that are unique or other similar situations as well as records from prominent faculty, students and alumni should be considered for historical value. If you are still in doubt, the University Archivist is available to help make a historical determination for permanent retention.

 

Certificate of Records Destruction (Form RM-3)

Where can I get instructions on filling out the Certificate of Records Destruction (RM-3) form?

Watch the how-to video, "Filling out the Certificate of Records Destruction" (Library of Virginia, 2013), or visit this link for line item instructions.

What is the turnaround time for submitted forms to be approved and sent back to the department?

The Records Management Office will verify the information on the form is correct, sign and send the form back to the department as soon as possible, usually within 1-3 business days. If there are any errors on the form, the Records Management Office will notify the person completing the form (box 3 on the form) within this same time period. If there are any errors, the department would typically have to re-submit the form.

Who should sign line 7 on the form?

The department Records Coordinator or any employee who can verify that the records represented on the form are eligible for destruction.

Who should sign line 9 on the form?

The department Records Coordinator or any employee who can verify that the records represented on the form were destroyed. An individual representing the vendor who performed the destruction may also sign line 9.

Disaster Recovery and Business Continuity

What should I do in case of fire or flood?

Seek safety and contact emergency personnel referenced on the VCU Alert site. once the emergency has been resolved and access to your area and records are allowed, contact the University Records Officer at (804) 828-1414 or recman@vcu.edu for advice on how to handle damaged records. 

What help do you give in case of an emergency?

We can point you to Facilities Management (FMD) and their QuikFM system. If you have an emergency facility problem such as fire, flood/uncontrolled water, chemical/biological spill, power outage or smoke, then call FMD Customer Service at (804) 828-9444.

Where can I get more information?

The VCU Libraries has excellent information on Emergency Preparedness. The Virginia Department of Emergency Management offers a Continuity Plan template.  If you would like to request assistance in drafting your unit's continuity plan, please contact Adam Crowe, Director of Emergency Preparedness, at (804) 827-2238 or ascrowe@vcu.edu.

Requests for Records

What should I do if I receive a request for documents from an external party?

For external requests, regardless of whether the requester specifies the Freedom of Information Act (FOIA) in the request or not, please follow the guidelines in the VCU News Center FOIA requests page as soon as possible.

When should I not destroy records that are out of retention?

If there is a hold in place for an upcoming or ongoing audit, investigation, litigation, FERPA or FOIA request, records cannot be destroyed until the hold has been lifted.

How do I know if I am under a litigation/legal hold?

Department heads are notified of upcoming and ongoing holds. If you are uncertain of record hold status, discuss the matter with your department head.

What if an unexpected request for records occurs after the respective records have expired, been reported for destruction and destroyed?

As long as record owners are compliant with the Library of Virginia retention schedules at the time the records were reported for destruction and ultimately destroyed, then the university should not be expected to produce them. Conversely, expired records and their copies that still exist are still subject to discovery, so if you have it, you must produce it.

Electronic Records & Imaging

Are files on my desktop computer or laptop "public records"?

Yes, the Virginia Public Records Act states:

“Regardless of physical form or characteristics, the recorded information is a public record if it is produced, collected, received or retained in pursuance of law or in connection with the transaction of public business. The medium upon which such information is recorded has no bearing on the determination of whether the recording is a public record.”

Do I have to keep the electronic version of a record along with a paper version?

If there is an active or pending hold, you must keep all formats until the hold is lifted.  As long as there is no legal requirement stating otherwise and the document does not carry a permanent retention, you may destroy one format of the records (either paper or electronic) if you plan to retain the other as the official record for the retention periods listed in the schedule. If your office chooses to keep both electronic and paper formats and they are exact duplicates, both should be destroyed once they have met the retention period in the Records Retention and Disposition Schedules approved by the Library of Virginia.  Exact duplicates are considered non-records and their destruction is not to be reported on a certificate of record destruction (RM-3) form.  Exact duplicates may be destroyed at anytime prior to the destruction of their official record and must not exceed retention of their official record.

 

 

 

Electronic storage is cheap. I’ll just keep my computer records?     

The best practice is to destroy all records that have met their retention requirements at the same time, regardless of format. Records in paper and electronic formats that have met their retention period but continue to be kept are still subject to public inspection, audit, and litigation/legal holds. Maintaining electronic records beyond their approved retention periods can be used to show a lack of compliance with state laws and regulations in a legal or an audit proceeding.

Records must be destroyed in a “timely manner,” which the Library of Virginia construes to be one calendar year from the end of the retention period. Records containing privacy-protected information must be destroyed within six months of the end of the retention period.

We have an imaging system. Do we have to keep the paper? 

After records are reformatted, inspected and approved according to established standards, the originals may be destroyed, unless specifically prohibited by law, because they are then considered copies.

The Records Management Office or University Archivist should be contacted before destroying any paper records with a permanent retention after imaging. Similarly, if records are from 1974 or earlier, there is a strong possibility of historical significance, in which case the University Archivist or Records Management Office should be contacted.

Where can I store confidential electronic records?

Please visit the Where Can I Store My Data? page on the VCU Information Security site.

How do I get information about ImageNow?    

ImageNow by Lexmark is a secure, user-friendly document imaging and workflow management tool that allows you to easily capture, organize and manage documents. ImageNow allows you to scan paper, import digital-born records, index, annotate, retrieve, print, export, email, share and run custom reports on electronic documents.  

More information can be found at go.vcu.edu/imagenow

Email Management

When can I delete my email?

Electronic mail is just as much a record as any traditional paper record and must be treated in the same way. It is the content of each message that is important. If a particular message would have been filed as a paper memo, it should still be filed (either in your email database or in your regular folder structure), and it should be retained the same length of time as its paper counterpart. It is inappropriate to destroy email simply because storage limits have been reached. Review the Records Retention and Disposition Schedules for the records series of the email and follow the retention instructions.

Can I use my email system to store records?

Best practice in records management dictates that email systems should only be used for routine correspondence. They should not serve as a repository for long-term retention. If you send or receive non-correspondence records via email, it is recommended you move those records out of email to a more suitable storage location for retention.

Do I have to print my email to file it?

No, email can be retained in electronic format for the entire length of its retention, however, you must be able to access the email during that entire retention period.

I use my personal email account for work. No one can see my personal email. Right?

The best practice is to avoid using personal resources, including private email accounts, for public business. The Virginia Public Records Act states that records are public records "if it is produced, collected, received or retained in pursuance of law or in connection with the transaction of public business." The fact that public records reside in a personal email account is irrelevant. Likewise, you should limit the use of a public (VCU) email for personal email.

Record Ownership

Who owns records that I use for my work and then pass along to another department (HR, Procurement, etc.)?

The final record owner is typically wherever the record ends up for storage to finish out its retention, or the last responsible party in the record’s “chain of custody”. If a copy of the record is kept for your files and is no longer used in the transaction of business, that would be a non-record (unless the copy is modified, in which case the version you keep becomes a new, unique record).

Please visit go.vcu.edu/records-ownership for more information (if you are staff/faculty and do not have a VCU Google account, please email recman@vcu.edu for an updated version).

Are copies of requisitions, orders, etc. taken from the eVA purchasing system considered records or non-record “convenience copies”?

Because eVA is not a VCU system of record, then any copies made of eVA documentation, whether paper or electronic, are considered unique to VCU, and they are official records with respective retention periods as a result.

Are reconciliation files records or non-record “convenience copies”?

The Library of Virginia has deemed that “multiple copies of the same document are each considered to be a record only in the instance that each serves a separate administrative purpose and if they are kept in separate filing or recordkeeping systems.” (A Guide to the Virginia Public Records Act, 2016).  Given this assertion, reconciliation files are in fact records owned by the department performing the reconciliation. The appropriate record series for them is 200109: Cash and Bank Reports from retention schedule GS-102 Fiscal Records.

I am a VCU Health employee who has no academic affiliation with the university. Does all of this records stuff apply to me as well?

Yes, records management for VCU Health System is led by the Health Information Management division. Certificate of Records Destruction (RM-3) forms should be submitted to that office, not to the VCU Records Officer identified on this site.

Retention Periods

How long do I have after records expire to report them for destruction and then destroy?

Records must be destroyed in a “timely manner,” which the Library of Virginia construes to be one calendar year from the end of the retention period. Records containing privacy-protected information must be destroyed within six months of the end of the retention period.

What should I do if I believe I have records with a disposition of “Permanent, Archives” or “Permanent, In Agency” according to the state retention schedules?

VCU Libraries is the designated repository for archival records and the administrative unit that operates the university archives program as stated in the University Archives policy. If you determine that you have records with a permanent retention, please contact the University Archivist for guidance on appraising, acquiring, arranging, describing, preserving, and providing access to any records of enduring value.

How do I know if a record has historical value?

There is no specific definition for historical value, as it is deliberately vague to allow state bodies such as VCU to make their own judgment. For VCU, anything that dates to the RPI or MCV years (prior to 1968), and also materials from the formative years of the University (1968-1974), should be reviewed for historical significance. In addition, photographs, significant events or programs, events or programs that are unique or other similar situations as well as records from prominent faculty, students and alumni should be considered for historical value. If you are still in doubt, the University Archivist is available to help make a historical determination for permanent retention.

In the Library of Virginia record retention and disposition schedules, some of the triggering events that are used to describe retention periods are unclear. What do these mean?

Ambiguous-sounding triggering events found in retention periods such as “last action”, “obsolete” or “no longer administratively useful” are meant to be subjective. It is up to the record owner to make the determination as to when the noted point in time is supposed to occur. Whatever point in time is chosen, being consistent with its application when reporting records for destruction is extremely important and will minimize confusion.

When should I not destroy records that are out of retention?

If there is a hold in place for an upcoming or ongoing audit, investigation, litigation, FERPA or FOIA request, records cannot be destroyed until the hold has been lifted.

 

Social Media

Are social media posts public records?

Yes, including posts made by the general public.

Where can I go for more information?

Please visit the university’s Social Media Guidelines page and the Library of Virginia’s social media tips sheet.