This policy establishes the general responsibilities for management, retention, and disposition of Virginia Commonwealth University records as mandated by the Virginia Public Records Act (VPRA), Code of Virginia § 42.1-76–§ 42.1-91.
This policy supports the following objectives:
All records, regardless of format, must be retained and destroyed according to the state-mandated record retention schedule unless subject to a longer retention period by other superseding authority; a record hold; or deemed a permanent record. University records may not be destroyed because of lack of space or funding for storage.
Noncompliance with this policy may result in disciplinary action up to and including termination. VCU supports an environment free from retaliation. Retaliation against any employee who brings forth a good faith concern, asks a clarifying question, or participates in an investigation is prohibited.
All employees are responsible for knowing this policy and familiarizing themselves with its contents and provisions.
"Archival record" means a public record of continuing and enduring value useful to the citizens of the Commonwealth and necessary to the administrative functions of public agencies in the conduct of services and activities mandated by law that is identified on a Library of Virginia approved records retention and disposition schedule as having sufficient informational value to be permanently maintained by the Commonwealth. (Code of Virginia § 42.1-77)
Public records that are restricted from disclosure by statute, court order, or legally adopted rules and regulations are considered confidential. University records that are deemed confidential by the Library of Virginia are still considered to be public records even though they are not publicly available.
The “official record” shall be construed to mean the “official” copy of a particular public record, with no regard as to whether it is an original, copy, or reformatted version.
Department Records Coordinator
Employee who serves as a liaison between the department and the designated records officer.
Designated Records Officer
The designated records officer(s) serves on behalf of VCU as a liaison(s) to the Library of Virginia implementing and overseeing the records management program.
As set forth in the Code of Virginia § 42.1-77, “nonrecord materials,” means materials made or acquired and preserved solely for reference use or exhibition purposes, extra copies of documents preserved only for convenience or reference, and stocks of publications.
A university record that has not been deemed permanent. The records retention and disposition schedules identify when a set of records has reached the end of its usefulness
A public record is considered permanent when it has been determined to have “continuing and enduring value useful to the citizens of the Commonwealth and necessary to the administrative functions of public agencies in the conduct of services and activities mandated by law.” (Code of Virginia § 42.1-77)
A public record is any recorded information that documents a transaction or activity by or with any public officer, agency or employee of an agency. Regardless of physical form or characteristic, 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, whether electronic or otherwise, has no bearing on the determination of whether the recording is a public record.
"Personal information" means all information that (i) describes, locates or indexes anything about an individual including, but not limited to, his social security number, driver's license number, agency-issued identification number, student identification number, real or personal property holdings derived from tax returns, and his education, financial transactions, medical history, ancestry, religion, political ideology, criminal or employment record, or (ii) affords a basis for inferring personal characteristics, such as finger and voice prints, photographs, or things done by or to such individual; and the record of his presence, registration, or membership in an organization or activity, or admission to an institution. "Personal information" shall not include routine information maintained for the purpose of internal office administration whose use could not be such as to affect adversely any data subject nor does the term include real estate assessment information.(Code of Virginia §2.2-3800)
A temporary suspension of destroying records in accordance with the record retention schedule when the records are subject to a pending or active audit, litigation, investigation or request for records.
Record Retention Schedule
The documents that authorize the period of time that records are kept before they are destroyed or kept permanently. The Library of Virginia sets the record retention schedule referred to as General Schedules for State Agencies.
Governing body with recordkeeping requirements that conflict with the record retention schedule. Records governed by a superseding authority must be retained to the most lengthy retention period.
Technology Services officially interprets this policy. Technology Services is responsible for obtaining approval for any revisions as required by the policy Creating and Maintaining Policies and Procedures through the appropriate governance structures. Please direct policy questions to Technology Services and the designated records officer.
The following procedures describe the required actions and processes to comply with this policy and applicable laws and regulations.
Roles and Responsibilities
Designated Records Officer
1. Coordinate Records Management Program: The designated records officer develops and coordinates the university’s records management program. This includes:
1. Maintain Departmental Procedures: Each department head is responsible for the department’s compliance with the records management program and procedures developed by the designated records officer in accordance with the record retention schedule:
2. Train Employees: All employees must adhere to the records management requirements:
3. Honor Record Holds: Any record that is subject to a record hold must be retained until final resolution of the matter. In this circumstance, the department(s) involved must:
4. Designate Department Records Coordinator: Each major budget unit must have at least one records coordinator:
Department Record Coordinator
1. Advocate Records Management Program: Each major budget unit must have at least one records coordinator designated to assist with records management compliance.
1. Know Your Department Records Coordinator: Leverage the designated department records coordinator for assistance complying with department procedures and the records management program.
2. Manage Records Appropriately: Manage records with care throughout their lifecycle:
3. Timely Record Destruction: A Certificate of Records Destruction (RM-3 Form), signed by the designated records officer, is required for official records prior to destruction:
4. Disposition Methods: Acceptable methods of record destruction. Confidentiality is deemed by the Library of Virginia and denoted in the record retention schedule:
The following forms are associated with this policy and procedures:
This policy supersedes the following archived policies:
|Initial Approval: 07/31/2009||Records Standards|
|Revised and Approved: 03/10/2010||Standard for Records Management|
|Revised and Approved: 12/03/2015||Records Management|
1. What are reasons to enact a record hold?
There are several reasons to enact a record hold. Some examples are pending or active:
2. Where should I store my data?
The Information Security Office in Technology Services provides guidance on the secure handling, transmission and storage of data and information; IT resources and services offered by the University that can assist; and specific precautions one should take. For more information, contact Technology Services at (804) 828-2227 or visit the Data Management System webpage: https://ts.vcu.edu/askit/essential-computing/information-security/data-management-system/
3. Who owns the record?
Records created, collected or required by law while doing university business belong to the university. Formal approval must be granted to retain a copy of records. To see exceptions or to make formal request, please visit:
4. Whom should I contact about recycling or document destruction?
VCU Facilities Management (FMD) provides guidance on recycling and destruction services for documents and other types of media storage. For more information about available services, contact the FMD Customer Service Center at (804) 828-9444 or submit a service request at fmd.vcu.edu.