The version of this rule that includes live links
to associated resources is online at
https://www.ohio.edu/policy/93-002.html
(A) Overview
This policy establishes general guidelines and
procedures by which to assure economy and efficiency in the identification,
retention, retrieval, preservation, and destruction of university records in
compliance with state and federal regulations.
(B) Authority and history
According to division (B) of section 149.33 of
the Revised Code, the boards of trustees of state-supported institutions of
higher education shall have full responsibility for establishing and
administering records programs for their respective institutions. The boards
shall apply efficient and economical management methods to the creation,
utilization, maintenance, retention, preservation, and disposition of the
records of their respective institutions.
Resolution 1992-1218 of the Ohio university board
of trustees empowers the president of the university to appoint a standing
university records committee "which shall be responsible for actions
regarding the university's records management policies and
procedures." The same resolution authorized a "university-wide
records management policy which shall oversee the creation, maintenance, and
disposition of all records in units and sub-units of the university."
In keeping with that resolution, the university
records committee has directed "provision for the equipping and
professional staffing of the records management office," which, it
charged, "shall monitor the creation, maintenance, and disposition of
university records throughout the system."
Each planning unit head, or his or her designee,
who oversees custody of university records is, therefore, responsible for
consulting the university archivist and records manager to establish and
maintain compliance with current records retention guidelines specific to
records that are created or received by their office.
The university records committee also recognized
the Ohio university archives "as the official repository for Ohio
university records of enduring and permanent value," and the committee
established a records storage facility "to hold records during their
inactive phase, prior to disposal or transfer to the archives."
(C) Definitions and legal requirements
University records and public access to them are
defined and explained under policy 40.007.
All questions about laws related to public
requests for access to university records should be directed to the
university's office of legal affairs.
(D) Records retention manual
The manual titled "Records Retention for
Public Colleges and Universities in Ohio," represents the work of a
special committee of the inter-university council of Ohio in consultation with
an international records specialist. This manual shall be used by the
university records manager as the basic guideline for determining the legal
retention periods for university records. If, in the future, the
inter-university council of Ohio updates the most recent records retention
manual or creates or adopts a different manual, such new manual shall be used
by the university records manager for determining legal retention periods for
university records.
(E) Process
The establishment of a centralized records
management office is necessary to ensure the university's consistent
compliance with state and federal records retention requirements and to
facilitate removal, storage, and destruction or preservation of university
records. Therefore, the person designated as the university records manager,
guided by the recommendations of the records retention manual, is authorized by
the Ohio university board of trustees to determine the disposition of
university records. Issues of the disposition of university records and
subsequent removal, storage, and destruction or preservation of those records
shall be determined in the manner established by parts (F) to (L) of this
policy.
(F) University records committee
The university records committee serves two
roles: it provides specific oversight for this policy and it is the policy area
committee ("PAC") for data handling, including university data
classification according to sensitivity. Other policies (in preparation) will
address the general role of information technology PACs and the other specific
roles of this committee.
The university records committee is a standing
committee, and so will be staffed through the committee on committees process.
The committee will be chaired by the chief information officer. It will include
the university records manager and the following people (or someone designated
by each of them):
(1) Vice president for advancement
(2) Vice president for research and creative activities
(3) General counsel (advisory)
(4) Chief human resource officer
(5) Information security manager
(6) Dean of the heritage college of osteopathic medicine
(7) University registrar
(8) Controller
(9) Chief audit executive (advisory)
(10) Chief marketing officer
(11) Director of government relations
(12) Executive dean of regional campuses
(13) Assistant vice president for safety and risk management
(14) Associate provost for institutional research and
effectiveness
The committee shall seek advice from and provide
advice to the university records manager; provide interpretation of this
policy, as needed; recommend changes to this policy, as needed; review and
provide feedback on the electronic records guidelines published by the office
of information technology (see part (L) of this policy); and identify other
opportunities to improve the handling of university records.
(G) Records retention
All staff of the university whose regular or
occasional performance of functions involves creating, receiving, or
maintaining files, records, or documents pertaining to the duties and functions
of their offices are required to observe the following:
(1) Records that document the organization, functions,
policies, decisions, procedures, operations, or other official activities of
university offices and personnel are the property of Ohio university and the
state of Ohio.
(2) Such property is not to be permanently removed or
destroyed except in accordance with the schedule for that unit as approved by:
(a) The administrator in
charge of the area in which the records are generated or received; and
(b) The university
records manager.
(3) The head of each planning unit or his or her designee
will determine in conjunction with the university records manager the
appropriate retention periods for the records series that are created,
received, or maintained by their respective units.
(H) Inventories and schedules for university records
It shall be the responsibility of each planning
unit head or his or her designee, with guidance and approval of the university
records manager, to conduct records inventories and analyses and to establish
the official records retention schedules for their respective units. This shall
be done in the following manner:
(1) Each planning unit that generates, receives, or
maintains university records shall complete and maintain up to date an
inventory of their various series of records including such information as the
names of the records series, descriptions of the purposes for each series, and
the date(s) of each series.
(2) Each planning unit, using the records retention manual
as a guide, shall then submit to the university records manager for approval a
draft schedule for the retention and disposition of each records series thusly
inventoried.
(3) Once the draft schedule is approved and signed by the
university records manager and by the head of the planning unit that has
provided the draft proposal, a final records retention schedule shall be
produced for that unit by the university records manager.
(I) Removal and storage of university records
(1) Records for which retention dates have been officially
scheduled shall be retained until such time as their retention dates have been
reached. The university records manager may provide space on a limited basis at
a safe, secure records storage facility where units may store records that have
not yet reached their scheduled expiration dates. Records maintenance personnel
from each unit that is granted permission to transfer records from their unit
to the records storage facility must generate and maintain a complete inventory
of the records that they are transferring to the storage facility, and they
must provide a copy of the inventory to the university records manager. The
records manager will provide records storage boxes to the units transferring
records, and the records generating unit will be responsible for packing the
boxes and labeling those boxes so that the contents of each box may be easily
identified for retrieval or destruction.
(2) Some records, which have longer or permanent retention
periods, also may be stored on a limited basis at the records storage facility
with the approval of the university records manager, who may first require the
unit to make arrangements to have those records more appropriately preserved;
see part (J) ("Preservation of University Records") of this policy.
(3) Records that have been transferred to the records
storage facility are still considered to be the property of the offices from
which they have been transferred, and requests to the university records
manager for retrievals of copies of those records or for retrievals of the
original records in full or in part may be made by the offices from which the
records were sent for storage. No record(s) shall be retrieved or reproduced
from the storage facility at the request of anyone other than the records
maintaining personnel or administrators of the offices from which those records
were originally transferred unless permission is otherwise granted by the
office from which the record(s) were transferred, except in cases of official
university investigation, responding to requests from the office of legal
affairs, or for audit purposes.
(J) Preservation of university records
(1) Records that have been identified in the schedule as
"archival" for their enduring historical value may be transferred to
the university archives upon the approval of the university archivist. The
university archivist may supply standard size records boxes for units that are
preparing to send records to the archives. University records and the boxes in
which they are transferred to the archives shall be clearly identified and
labeled before transfer, and units transferring records to the archives shall
supply the archives with a complete inventory of the records being transferred.
(2) Records that are transferred to university archives
(located in Alden library) become the administrative responsibility of the
archives, and, unless otherwise stipulated by agreement, such records shall
reside permanently in the archives. Most university records housed in the
archives are subject to unrestricted public access. The relatively few series
of archived university records to which access is legally restricted may be
examined by staff from the office of origin of those records upon the request
of the administrator of that office and in agreement with the university
archivist.
(3) In order to help guarantee the preservation, integrity,
and security of records that have been turned over to the archives, access to
records housed in the archives -- whether by the general public or by
university staff -- shall be on-premise only. Archive staff may agree to
photocopy or scan records for a fee if the condition and integrity of the
original records will not be in any way damaged or otherwise altered during the
process of placing them on scanners or photocopiers.
(4) Section 9.01 of the Revised Code authorizes
microfilming the records of public offices for the purpose of preserving them
or for the purpose of conserving space. The office of the university archivist
and records manager therefore urges units that generate large amounts of paper
records that have been determined to be of enduring administrative, legal, or
historical value to make arrangements to have such records microfilmed.
Although digitizing (scanning) has become a convenient way by which to maintain
and access records that are retained over shorter periods, microfilming is
still the safest, most secure, and most durable means of preserving records
that must be retained more permanently. The university records manager shall,
upon request, supply units with information concerning microfilming.
(K) Disposal of university records
(1) When a unit head or his or her designee has determined
by the retention schedule that records within their unit have reached or have
exceeded the legal retention period, and that the records have no further
administrative, legal, or historical value, the administrative head of the unit
shall arrange for the disposal of those records.
(2) Upon the disposal of records, the head of the unit
shall sign and maintain appropriate records documenting such information as
title, contents, and purpose of the disposed records, legal retention period,
as well as date and method of disposal.
(3) When the university records manager is to oversee the
removal and destruction of records that have reached their retention period
from the off-site storage facility, as identified in part (I) of this policy,
the university records manager shall first inform the responsible unit, in
writing, of his or her intent to destroy those records, preserving a copy of
that notice and of the subsequent reply from the unit acknowledging and
consenting to the destruction of the records.
(4) Records that contain materials that are of a
confidential nature -- especially but not exclusively those records that are
included under FERPA or HIPAA stipulations -- shall be destroyed in a manner
consistent with best practices to reasonably ensure that the data is not
recoverable.
(5) Some less-formal records that have shorter-lived
administrative or legal value are categorized as "transitory."
Retention periods for transitory records are usually event-driven, rather than
being a fixed period of time. Examples of transitory records include
preliminary drafts and notes, used in the production of university records,
which are proper to dispose of when those drafts or notes have been superseded
or updated by other records; policies and procedures documents that have been
superseded or withdrawn (university archives shall, and other offices may,
retain copies of superseded and withdrawn policies); voice mail; and records
relating to scheduling meetings and other non-public events. Such records
should be retained until they are no longer of administrative or legal value
and may then be destroyed, deleted, or purged at any time without
acknowledgement or approval of the university records manager. For further
advice as to whether a record should be classified as transitory or not, please
contact the university records manager.
(L) Retention and disposal guidelines for electronic
records
(1) Electronic records, including electronic mail (e-mail)
messages and personal computer disk files, that document the organization,
functions, policies, decisions, procedures, operations, or other activities of
a university office shall be considered records in accordance with the Revised
Code definition of records. (For examples of electronic records that are not
considered to be university records see the next paragraph of this part (L)(1)
of this policy.) Therefore, all such electronic records that are generated or
received by university offices shall fall under all of the regulations
established by the federal and state law, and shall be subject to the
university policies and procedures for records retention and disposal as
outlined previously in this document. For example, the retention period for
requisitions that are created or received electronically by a university office
shall be the same as the retention period for those requisitions that are
generated or received on paper or in any other fixed medium.
Examples of electronic records that would not
fit the criteria for public records as defined by the Revised Code would be
e-mail messages of a personal nature that do not pertain in any way to the
conducting of university business, even though they were received on university
e-mail systems, and messages received from interest-group listservs. These
types of records, generally categorized as transitory, may be deleted or purged
at any time.
(2) The office of information technology will maintain
guidelines for the appropriate management of electronic mail online at
https://www.ohio.edu/oit/security/electronicrecords.cfm.
The version of this rule that includes live links
to associated resources is online at
https://www.ohio.edu/policy/93-002.html
Rule 3337-93-01 | Data classification.
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