Records Management
Date of Current Version: July 2007
Responsible Office: JMU Records Manager
- PURPOSE
THE purpose of this policy is to: (1) authorize a university records management program in accordance with State law and the university's need for proper records management, (2) designate a University Records Manager and establish the scope of the manager's authority, (3) indicate the responsibilities of individual departments and offices to achieve compliance with the program, (4) establish specific procedures to be followed to carry out the program, and (5) clarify proper methods for records storage and destruction.
Some major considerations in records retention and disposition are:
- Legal requirements must be met.
- Audit requirements must be met. This includes the university's ongoing internal audit program as well as the requirements of the Auditor of Public Accounts and other external agencies.
- Limitations of space. The university has very limited storage space. Departments are restricted as to both the volume of records that can be maintained, and the duration for which records may be stored.
- Historical and research information about the university must be preserved. In addition, records with historic value should be kept in a manner that makes them readily accessible to researchers.
- AUTHORITY
The Code of Virginia, Sections 42.1-76 through 42.1-91, otherwise referred to as the Virginia Public Records Act, requires that state agencies with public records maintain an active and continuing program for the economic and efficient management of the records of the agency. - DEFINITIONS
Public Records:
All original copies of written papers, letters, documents, photographs, magnetic tapes, microfiche, microfilm, sound recordings, maps, other documentary materials, or information in any recording medium regardless of physical form or characteristics, including computer generated and electronically recorded materials and information, made or received in connection with the transaction of public business by any agency or employee of state government or its political subdivisions. State law prohibits individuals and departments from destroying or otherwise disposing of public records without proper authorization.
Original Copy:
The top copy or document having the actual typed, handwritten, or computer generated print or signature on it. In cases where the original copy has been sent outside of the university, the institutional copy that resides in the originating office is to be treated as the original copy. The requirement for records retention and disposition schedules relates specifically to original/institutional copies.
Records Series:
A group of records with similar physical characteristics that document a particular function or activity of a department. Examples include correspondence files, purchase requisitions, budget preparation materials, and invoice vouchers.
Administrative Value:
Records or documents that have utility in the operation of a state agency.
Legal Value:
Records that document actions taken in the protection and proving of legal or civil rights and/or the obligations of individuals and agencies. This includes records relating to pending or proposed litigation.
Fiscal Value:
Records that are needed to document and verify financial authorizations, obligations, and transactions. After a specified period of time and audit by the Auditor of Public Accounts such records can normally be disposed of without risk, provided that the necessary retention and disposition schedules have been approved.
Historical Value:
Records that provide an understanding of some aspect of state government, its agencies, and its political subdivisions. Such records typically contain evidence or information on the agency that created them or on the subject the records deal with. Historical value persists long after the agency has any regular need for the records.
Current Records:
Records needed to conduct the daily business of the university. Current records must be maintained in appropriate filing or retrieval equipment for immediate access in a working office.
Semi current Records:
Records not required for immediate access, but retained for information, audit, or legal purposes. When possible, semi current records should be retired from storage in working office space and moved to a designated storage area. Some semi current records, such as certain student and personnel records, are permanent in nature.
Noncurrent Records:
Records not needed to conduct current business and have no further use to the originating office. If noncurrent records have historic value, they should be transferred to the special collections of the Carrier Library or to the university records manager, who will arrange for their storage. If disposable, they should be destroyed or disposed of in accordance with an approved records retention and disposition schedule. - APPLICABILITY
This policy applies to all university employees and students with the responsibility to maintain or manage university records or data. All such information is covered under this policy unless specifically excluded. - POLICY
JMU records are subject to the provisions of the Virginia Public Records Act (Code of Virginia, Sections 42.1-76 through 42.1-91). In accordance with the Freedom of Information Act, Code of Virginia, Sections 2.2-3700 through 2.23-3714, public records are to be made available for public inspection, except those records that are specifically excluded from public disclosure by the Act. The public's right of access is also restricted by the Government Data Collection and Dissemination Practices Act, Code of Virginia, Sections 2.2-3800 through2.2-3809, when records show personal information on individuals. The Family Educational Rights and Privacy Act (FERPA) is a federal law that requires the establishment of a written institutional policy regarding the confidentiality of and access to student educational records. Policy No. 2112 establishes university requirements for releasing educational records.
The Library of Virginia publishes standard forms to be used in administering agency records management programs. - PROCEDURES
6.1 Records Retention and Disposition Schedules. Different types of records must be retained for varying amounts of time before they can be destroyed. General Records Retention and Disposition Schedules have been prepared for use by all state agencies by the Library of Virginia. Departments should refer to those General Schedules to determine how long a particular record must be retained before it can be destroyed. Copies of General Schedules are available from the university records manager, from the JMU Web Site www.jmu.edu/recordsmgmt or the Library of Virginia Records Management Services Web Site http://www.lva.lib.va.us/whatwedo/records/sched_state/index.htm .
6.2 Destruction and Disposal of Records. No public records may be destroyed without an approved retention and disposition schedule. State Form RM-3, Certificate of Records Disposal, is used to obtain permission to destroy records previously described in a records retention and disposition schedule. Instructions on filling out Form RM-3 may be obtained from the JMU Web Site www.jmu.edu/recordsmgmt or the Library of Virginia Records Management Services Web Site http://www.lva.lib.va.us/whatwedo/records/sched_state/index.htm . All departments and offices must contact the university records manager before destroying any original or institutional files, series of records, or correspondence files. To meet this requirement, the department or office should submit State Form RM-3 to the university records manager for review. The records manager will review the completed RM-3 for adherence to approved records retention and disposition schedules. After approving the form, the records manager will notify the department to proceed with the destruction of the records. At the discretion of the university records manager, records not scheduled for transfer to the Carrier Library but thought to be of possible historical value will be made available to the records manager for review prior to being destroyed. Most records can be destroyed simply by throwing the records away. In some cases, however, the records must be destroyed by burning or shredding under the supervision of a university employee. The General Schedules state which records must be destroyed in this manner. Regardless of the method, the department that owns the records must assure that they are destroyed in a proper and economical manner, and that all destructions are reported to the university records manager who in turn notifies the Library of Virginia.
6.3 Records Storage. Departments and offices are responsible for the storage of public records that they generate and receive. Current records must be maintained in appropriate filing or retrieval equipment for immediate access in the office. Records should be filed and arranged by an accepted standard method that allows for determination of when a records series passes from a current status to a semi current or noncurrent status. When possible, semi current records should be retired from working office space and moved to a designated storage area.
6.4 Microfilming. It is much less expensive to store records for many years than to microfilm them. The State will not allow the microfilming of records merely for convenience. Only records of sufficient administrative, legal, fiscal, and historical value to warrant their permanent preservation will be approved for microfilming. Any department or office which intends to microfilm records must budget for its own filming. The Library of Virginia’s Records Management Services Office maintains a large microfilming operation and will submit bids, if asked. Microfilming of records must be approved by the university records manager and the Library of Virginia. - RESPONSIBILITIES
The University Records Manager is responsible for managing the Records Management Program in accordance with state law and university policy. The University Records Manager ensures that records appraisals and records retention and disposition schedules are systematically updated, maintained, and enforced. In addition, the University Records Manager evaluates and reports the program's progress and achievements to management.
All departments and offices that generate public records as defined above are responsible for preparing the certificates of records disposal for those records. They are further responsible for compliance with procedures regarding records storage and destruction as established by this policy. - SANCTIONS
Sanctions will be commensurate with the severity and/or frequency of the offense and may include termination of employment. - EXCLUSIONS
Reference books, exhibit materials, and extra copies kept solely for convenience or reference are not considered to be public records for purposes of this policy.
- INTERPRETATION
The authority to interpret this policy rests with the President, and is generally delegated to the JMU Records Manager.
Approved by the President: March 1999
Index of Terms
Records
Record retention
Files
Public Records
Destroying Public Records