MEMO 7/28/13 To: Arkansas Records Retention Workgroup RE: The Arkansas General Records Retention Schedule Prepared

by: Christine Edwards

After reviewing your current records retention schedule there are several components I can compliment. The fact that you already have a schedule in place shows that you have at least a general knowledge of the importance of systematic records management. There are a few areas in which I would like to make suggestions for revision and some information which I feel your schedule is currently missing. First, however, I believe we should address the importance of this retention schedule to your organizations mission and daily operations. According to the copy provided, your workforce is overseen by the Office of Information Technology. Seeing as this is not a position normally schooled in records management procedures, I would like to provide you with the Generally Accepted Recordkeeping Principles (GARP) which were in 2009 by ARMA International.1 They are accountability, integrity, protection, compliance, availability, retention, disposition, and transparency (more details about each of the 8 principles can be found at www.arma.org/garp). As the Records Retention Workgroup you should be most concerned with retention, but please also realize that the other principles are applicable as well. The policies and practices which you develop are the foundation for other records management activities.2 A systematic records management program can reduce your operating costs (by reducing storage requirements, increasing information retrievability, and reducing the potentially costly consequences of adverse events), minimize risks to your organization (by having records available for litigation, audits, or other governmental investigations), and even increase revenues (by creating business opportunities, conferring competitive advantages, and having readily available the recorded information for marketable objects).3 Your current records retention schedule is quite nicely formatted. The table of contents and glossary are additionally helpful in navigating the information. It appears that you took into account the legal, operational, and administrative criteria when considering the retention periods within the schedule. Where appropriate, you have indicated the Code or Act from which the retention period was derived. This is important for legal compliance especially. I appreciate the clarity in stating that determination is by content, not format or media. With the emergence of so many digital records, it is important to make this distinction. The categories in which you have chosen to organize the document have given you a functional retention schedule. This big bucket approach has kept your schedule simple and easy to understand.4 It also leaves room for individual agencies to develop their own program-specific retention schedules within your general guidelines, which is something I would encourage your individual agencies to do if they have not done so already. This brings us to my first question: by only establishing minimum retention periods, do you believe your individual agencies, and thus your government as a whole, are effectively following the GARP principle of disposition? How do you prevent your agencies from establishing permanency for records that do not require that status? You address the concept and methods for disposition in your
1 2

Saffady 12 Saffady 13 3 Saffady 17-21 4 Saffady 61

glossary, but other than determining permanent value, I do not see any recommendations for maximum retention periods. Perhaps your workforce should consider record retention audits of the individual agencies to ensure that they are both in compliance with the Arkansas General Records Retention Schedule and that records are not being kept beyond a reasonably acceptable amount of time.5 This type of audit would typically be conducted by your records management department, but lacking such a department the responsibility would fall to those who administrate in such a manner. Perhaps this could be part of the audit conducted by the legislative auditor mentioned in the fiscal records section? You also indicate that this schedule applies only to official copies and not to duplicates, but I have no understanding of who in the organization holds this authoritative document and am confused by your glossary note that a copy made of the original record may become the official version. It thus appears that my duplicate may or may not be an official version. This undoubtedly only needs clarification in the wording of the instructions. In addition to addressing the official version of a record, you may also want to consider adding a note on vital records those records which contain information that is essential to the organizations mission.6 These records, which address your mission-critical operations, will be your most important assets in any adverse event or disaster. Should you choose to add a vital records requirement to your retention schedule, an audit for compliance could be conducted in coordination with other auditing activities.7 Overall, your retention schedule reads very clearly. There a couple minor spots that you may want to consider re-phrasing, such as: Under the General Administrative Records, GS 01009, your minimum retention period reads 1 year after updated or after it has served its intended purpose. I am unsure if the 1 year applies to both the update and its purpose, or if it applies only to the update. If the former, consider restating the 1 year (1 year after updated or 1 year after it has served its intended purpose). If it is the latter, you could rearrange the order to have the 1 year being applied only to the update more clearly defined (After it has served its intended purpose or 1 year after updated). Under the Legal Records, GS 06001, GS 06002, and GS 06006 all use the term disposition in their minimum retention period. While the assumption is that this refers to a legal disposition. Your glossary only defines the word as it pertains to the records management function of the transfer or destruction of a record series.

Another area in which your retention schedule is strong is in its records descriptions. While not all-inclusive, the examples give a good indication of what constitutes a record for each category or series. Consider also adding a description of what constitutes a nonrecord. Personal papers, for example, if allowed at work should be kept separate from work files. These personal papers as well as certain publications, brochures, catalogs, e-mails, blank copies and other undistributed inventory are nonrecords and should be handled accordingly. The policies and procedures listed in the record retention schedule would not apply to any object that did not meet record status. As a final note, I would encourage the Arkansas Record Retention Workgroup to reconvene and reassess the current record retention schedule. This is not only to discuss revisions suggested here, but also in light of the fact that the current schedule is now at seven years old and new laws or codes may have been established that should be included. You may also have found that individual agencies need to retain records longer than the minimum requirement should suggest a change in that minimum time period. If, by chance, the State of Arkansas has hired a records manager or designated a records
5 6

Saffady 96 Saffady 151 7 Saffady 173

management department, this task could and should be turned over to that individual or department. Here is a possible timeline for which to accomplish revision of the Arkansas General Records Retention Schedule: 1. Survey the individual agencies to find out how long records are being kept and for what purpose. This survey should be conducted by the records management department or the Arkansas Records Retention Workforce. (An inventory would produce better results, but for a large organization such as yours, it would need to be conducted in stages and the preparation of a new retention schedule would be correspondingly delayed8). 2. Having obtained survey results, these results should be synthesized and used by the records management department or the Workforce to readdress current minimum retention requirements. These results should be discussed, along with the recommendations above, at a meeting date no later than 3 months from the distribution of this memo. 3. The records manager or the facilitator from the Office of Information Technology will formally prepare the new records retention schedule which will be sent via mail (paper or electronic) to each member of the Workforce or agency administrator for review and approval (i.e. those who will be responsible for implementing the schedule9). 4. Once approved the new Arkansas General Record Retention Schedule should be implemented. Agencies will be given one year from the dispersal of the Schedule to comply with said schedule. Any records that have elapsed should be destroyed, inactive records should be transferred to offsite storage, and microfilming or scanning of records should be followed by destruction or transfer to offsite storage of paper copies.10 5. Following the initial year of compliance, an unscheduled records retention audit should be conducted in each agency no less than once every five years. (Audit can be conducted by Office of Information Technology, a Workforce member, or a records management department administrator. Audit can also be conducted in conjunction with other audit activities).

8 9

Saffady 33 Saffady 88 10 Saffady 90