AD35 University Archives and Records Management
Subject Matter Expert:
Policy Steward:Senior Vice President and Chief of Staff>
- Definition of Terms
- Roles and Responsibilities
- Further Information
- Cross References
This policy specifies the regulations by which University Records are defined, captured, utilized, stored, disposed of, and properly archived when they meet the University's criteria for constituting a “University Record.” This policy provides the means to define and offer counsel to University offices during the creation and use of all University Records. Further, it sets records management standards and creates Records Retention Schedules for those records. It also establishes archival criteria to maintain and assure continued access to appropriate historical records, in all formats in which they are created and retained.
This policy is applicable to all areas, campuses, centers, colleges, departments, institutes, locations, programs, schools, offices, and units of the University (hereinafter referred to as "Units"). A Records Management Liaison, hereinafter referred to as a "RML," must be appointed for each Unit to serve as steward for those records in conjunction with the University’s Office of Records Management and University Archives. Certain Units that store and maintain institutional records may have individual guidelines which supplement, but do not supplant, this policy.
The record retention guidelines that correspond with this policy apply only to the originating Unit, the Unit responsible for action related to the record(s), and/or the originating employee. Other Units or employees receiving copies of these records should retain such copies only as long as useful, but in no event longer than the record retention guidelines (See definition of Transitory/Disposable Records below). Where multiple Units are responsible for action related to a single record, those Units should agree as to which will be responsible for record retention and disposition. The objective is to minimize the number of copies kept while ensuring that records are retained as required.
Archival Records - University Records that are not-active , have been retained for the duration of the retention period for the specific records series or document type, and are designated as having a disposition method of “Transfers to Archives”, or “Review by Archives”. Archival Records are not required to be retained in the Unit in which they originate or are received. These records have enduring research or historical value and, as a result thereof, should be retained and preserved indefinitely.
Disposition Method - The method by which the originating Unit or the Inactive Records Center (IRC) disposes of University Records. Proper disposition methods include the following: secure destruction beyond recovery via cross-cut shredding physical records, purging electronic records/data, or pulverizing hard drives, as well as “Review by Archives”, and “Transfer to Archives”.
Electronic Records – Electronic records are created and stored in a wide variety of technologies and formats, including, but not limited to email, data (in structured or unstructured formats), web pages and other “born digital” records. Specifically, “born digital” records are University Records created and maintained in digital format throughout their life span. Any of these technologies are used to store University records. As such, this Policy applies to all University Records that are electronic.
Faculty-Related Records – University Records that typically are created, maintained, kept, or stored by University faculty. See the Faculty Records section of the University Records FAQ page and General Records Retention Schedule for more information.
Financial Records Retention Schedule - A list of University Records related to financial operations that indicates how records are required to be organized, who is responsible for managing them, how long they are to be retained and the appropriate means of disposition for each series of records.
General Records Retention Schedule - A list of University Records related to general operations as well as specific Units that indicates how records are required to be organized, who is responsible for managing them, how long they are to be retained and the appropriate means of disposition for each series of records.
Permanent Records - University Records that have enduring legal or financial value that remain active in perpetuity. University Records must be designated as Permanent Records by the Records Management Advisory Committee (RMAC). Permanent Records do not necessarily have historical or research value and, therefore, are not designated as Archival Records.
Information Classification - See policy AD95, Information Assurance and IT Security.
Record Series - Specific groups of related University Records which are normally used and filed as related items and which can be evaluated as related items for disposition purposes.
Responsible Party or System of Record - The University Unit or computer system that is responsible for retaining the official copy of the University Record. Please note generally that all other copies of the University Record in question are Transitory/Disposable Records, used as convenience copies or for reference, and must be securely destroyed when no longer needed.
Retention Period - The time that must elapse before University Records are disposed via secure destruction, or transferred to the University Archives.
Transitory/Disposable Records - University Records that have temporary value and, as a result, may be destroyed after they are no longer needed. In no event shall be retained longer than the official copy of the University Records as delineated on the Records Retention Schedule. Examples include photocopies of official University Records, a printed copy of a University Record that is held by the Responsible Party or within a System of Record, a spreadsheet containing data that is exported from an officially resides in another systems, personal emails not related to University business or activity, and/or mass emails or communications.
University Essential Records - Records essential to the continued functioning or reconstitution of the University during and after an emergency. This definition also includes, records essential to protecting the rights and interests of the University and the individuals directly affected by its activities. Permanent records within this category should be transferred to the University Archives at the end of their life cycle as delineated in the Records Retention Schedules.
University Records - Information that documents a transaction or regularly conducted activity of the University and that is created, received or retained pursuant to law, University policy, or in connection with a transaction, business, or activity of the University. The term includes documents, papers, letters, books, drawings, maps, plans, photographs, tapes, film or sound recordings, microforms, digital or analog files, information stored or maintained electronically, and data- or image-processed documents.
Excluded from the definition of University Records are three categories of materials:
- University Library and Museum Material made or acquired and preserved solely for reference or exhibition purposes, stocks of publications and of processed documents, and extra copies of documents preserved only for convenience of reference;
- Faculty Personal Papers that are maintained at the sole discretion of a faculty member for scholarly purposes that shall not contain personally identifiable information; and
- Personal Papers not related to the official function of a Unit or created in pursuance of non-University activities.
Units of the University - All areas, campuses, centers, colleges, departments, insituteus, locations, programs, schools, offices, and units (hereinafter referred to as "Units") of the University are required to follow this Policy and the requirements outlined in the General Records Retention Schedule and the Financial Records Retention Schedule for University Records. The Unit that generates or creates a University Record is referred to as the Originating Unit. The Unit that receives a University Record from other Units (such as, an Originating Unit) is referred to as the Receiving Unit.
Records Management Liaison (RML)– University employees assigned by the Budget Executive or Financial Officer to serve as a conduit for policy, procedure, and information between the University Archives/Office of Records Management and their respective administrative area.
Records Management Assistant (RMA) – University employees designated to support the Records Management Liaison with specific responsibility for a Unit or units within the administrative area.
Records Management (RM) - The mission of the Records Management Program (the “Program”) is to achieve compliance, economy, and efficiency in the creation, maintenance, use, and disposition of University Records. The Program provides services, resources, training, and guidance on the creation, management, access, retention, and disposition of University Records. The Program oversees this Policy, updates Records Retention Schedules, leads the Records Management Advisory Committee (RMAC), manages the Inactive Records Center (IRC), coordinates with the Records Management Liaisons and Assistants (RML/As), conducts records management assessments, and helps implement electronic records keeping systems
Records Management Officer - The head of the University’s Records Management Program and chair of the Records Management Advisory Committee. The RMO advocates for records management resources, services, systems, processes, and compliance with stakeholders, partners, and leaders across the University. The RMO leads the Program in all capacities, as stated above.
Records Management Advisory Committee (RMAC) - committee of University leaders and partners that advises, consults, and collaborates with the Program. RMAC reviews and approves changes to this Policy and the Records Retention Schedules and advises on records management projects, systems, and services. The RMO serves as the chairperson for RMAC.
Inactive Records Center (IRC) - The University’s official records management facility that provides the services of storage, access, and destruction of University Records. It also provide destruction services for Transitory/Disposable records that are confidential.
University Archives - University Archives serves as the institutional memory of the University and plays an integral role in the management of Penn State's information resources in all media and formats. To fulfill the responsibilities of that role, University Archives identifies, acquires, and maintains records of enduring value that chronicle the development of the University and ensures these records continued existence. University Archives also documents the process of institutional evolution by retaining both the evidence - which shapes decisions - and the decisions themselves.
University Archivist - A member of the Penn State Libraries, the University Archivist works with all areas, campuses, centers, colleges, departments, insituteus, locations, programs, schools, offices, and units of the University to appraise records that they create in the course of their University activities and to select those that need to be preserved for future research and scholarly use. The University Archivist also promotes, supports, and sponsors programs and activities that contribute to accessible information, interpretations, and research on University history.
Regardless of format, University Records have a life span. When University Records eventually become inactive, the University will determine the most appropriate disposition of these records in the interest of economy, efficiency, history, or administrative necessity. Records either will be designated University Records, Archival Records and transferred to the custody of the University Archives, or Transitory/Disposable Records that need to be destroyed in a systematic manner as outlined in this policy. Designations are delineated by record series in the Records Retention Schedules.
University Records in custody of their originating and receiving Units are University property and may not be disposed of except through policy and guidelines established herein. Access to University Records still in originating or receiving Units is governed by statute, regulation, or existing University policies and guidelines. Records from Units which are merged in reorganizations should be brought into the new Units carrying out those functions; records from those Units which are phased out should be reviewed by the Records Management Program and University Archives for appropriate action.
Records Retention Schedules will be developed for general record series and for the specific records of a particular Unit. All general records shall be included as part of the General Records Retention Schedule. Retention and disposition information for specific financial forms is included as Financial Records Retention Schedule.
Purpose of the Records Records Schedules: To provide uniform, effective, and systematic control of record keeping, destruction, and disposition. The University’s Records Retention Schedules also ensure that valuable records are preserved and that records of a temporary nature are properly disposed of when no longer needed.
Steps in creating Records Retention Schedules: The Records Management Program surveys records and drafts organization, retention, and disposition recommendations; Proposed schedules are approved by officials primarily concerned with the records (for example Budget Executive, Financial Officers, Unit Manager/Director, and RML). The proposed schedules are then reviewed and approved by the RMAC, the Office of General Counsel, and the Vice President for Administration.
Where possible, Units should store the original University Record(s), including Transitory/Disposable records retained reference/convenience copies, samples, or models, in a central physical file or on a shared server or in cloud storage, or in an electronic recordkeeping system/repository rather than maintaining several copies in various employee offices or workstations. Employees should consider whether they are an official source for a particular record when determining whether retention of additional copies of that record is necessary.
Units shall annually review the records in their possession and under their operational jurisdiction, and document such review. The regulations defined in this Policy must be consulted and followed in determining the retention, disposition and destruction of the records managed by Units.
The Budget Executive or Financial Officer will be responsible for the certification of such a review in their administrative area, certifying that the area complies with this Policy to the best of their knowledge and belief. To this end, the area's Budget Administrator, Department Head(s), Unit Head(s) and Director(s) and/or other administrators, as applicable and as designated by the Budget Executive or Financial Officer, will support him/her in the certification process. In fulfilling this process, the Budget Executive will designate one (1) primary RML to oversee such a review for their administrative area. There should be a minimum of one primary RML per administrative area. Based on the size of the Unit, an RML has the option to designate additional individuals as Records Management Assistants (RMA), to support the RML.
Documentation of this review will be maintained by the Unit RML as evidence that the review was conducted. The RML can document what records were reviewed through whatever means is most efficient and effective for the administrative area.
Note that records retained on centrally provided servers or in cloud storage, or in systems, such as in Administrative Information Systems (AIS), fall under the responsibility of the Unit that generated, collected, or maintained the records (as opposed to the Unit that manages the centrally provided server, cloud storage, or systems).
PURPOSE OF REFORMATTING UNIVERSITY RECORDS:
University records may be microfilmed, and/or scanned for storage in optical or other electronic media, for the purpose of reducing storage costs and/or improving access to and manipulability of the data. Documentation of reformatting process and procedures must be maintained. Physical or electronic records containing information classified as "Restricted" or "High" may be digitized or reformatted, but must be securely stored, with proper access controls, as defined in Policy AD95: Information Assurance and IT Security.
QUALITY STANDARDS FOR REFORMATTING UNIVERSITY RECORDS:
All significant detail on originals must be included on the new medium. Reformatted reproductions must have the same acceptability and legal status as the original record. If the records series has a disposition method of Transfer to Archives or Review by Archives the reformatted reproduction must meet archival standards. Reformatted records retain their original information classification pursuant to Policy AD95.
UNITS MUST PROVIDE ADVANCE NOTIFICATION:
Units must provide advance notification to the Records Management Program of their intent to reformat records. If the records series has disposition method of “Transfer to Archives” or “Review by Archives,” then the Unit and the Records Management Program will need to notify the University Archives for additional digital preservation considerations and requirements. Such Units must show that space savings and/or improved access to information will result from reformatting, as well as meeting quality and metadata standards. No reformatting shall take place unless an approved Records Retention Schedule exists which covers the records in question. All notifications of reformatting will be checked against established standards.
The destruction of records, documents, drafts, and copies will be suspended immediately upon notice that an investigation or litigation is pending, imminent, or reasonably foreseeable. The suspension will be tailored to cover only those records, documents, drafts, and copies relevant to the investigation or litigation.
Retention procedures will be suspended when, in the judgment of the University’s Office of General Counsel, a record or group of records should be placed on a legal hold. A legal hold requires preservation of appropriate records under special circumstances, such as litigation or government investigations. The Office of General Counsel determines and identifies what records and documents are required to be placed under a legal hold.Members of the University community will be notified if a legal hold is placed on records for which they are responsible.
Members of the University community are then required to locate, index, segregate, and protect the necessary hard copy records and records in electronic form, in conjunction with the Office of Information Security and local Information Technology staff, where appropriate. Any record that is relevant to a legal hold must be retained and preserved. If a member of the University community is unsure whether a record is relevant to a legal hold, that member of the University community should protect that record until consultation with the Office of General Counsel.
A legal hold remains effective until it is released in writing by the Office of General Counsel. After the University community receives written notice of the lifting of a legal hold, all records relevant to the legal hold shall return to their normal handling procedures and retention schedules.
To promote its mission of teaching, research, and service, the University has decided to make available certain University Records in custody of the University Archives for inspection, copying, and general/public research use, subject to those constraints that may apply by virtue of federal or state law or regulation, University policies, guidelines, or standards.
ARCHIVAL RECORDS MUST BE TRANSFERRED:
Archival Records as designated in the Records Retention Schedules, must be reviwed and, upon approval by the University Archivist, transferred to the University Archives for permanent preservation. The University Archives in collaboration with the Records Management Program shall designate which records are archival and shall have the authority to examine any and all University Records in their originating Units, subject to possible conditions of national security classification.
The transfer of Archival Records from the originating Unit to the University Archives shall be made at such times and in the manner and form prescribed by the University Archives and subject to the appropriate Records Retention Schedules.
RELEVANT RESTRICTIONS ON UNIVERSITY RECORDS TRANSFERRED TO THE ARCHIVES:
University Records transferred to the University Archives shall be subject to the information classifications defined in Policy AD95 and its corresponding Security Standards. University records maintained in the University Archives that contain information classified as "Low" or "Moderate" are closed to public access until twenty (20) years after their date of creation. University records maintained in the University Archives that contain information classified as "Restricted" or "High" are closed to public access until their status is changed by the Office of the President via a written request submitted by the University Archivist. Information classified as "Low," but made available to the public by the University prior to transfer to the University Archives, may be made available upon processing.
UNIVERSITY ARCHIVAL RECORDS MAY BE USED BY ANY INDIVIDUAL:
University Archival Records may be used by any individual, whether a member of the University Community or of the public, subject to their agreement to abide by archival rules governing access and use.
REQUESTS FOR EXCEPTIONS:
A request for an exception to access University Archival Records that contain information classified as "Low" or "Moderate" information, as defined in Policy AD95, shall be submitted in writing to the University Archivist and Records Management Advisory Committee who shall be governed by criteria approved by the Office of General Counsel and the Office of the President (or the President's designated representative) for evaluating such requests.
University Essential Records shall be transferred to the University Archives, as delineated in the Records Retention Schedules.
MASTER RECORDS OF MICROFILMED RECORDS:
Master negatives of microfilmed records that are identified as Archival Records will be transferred to the University Archives for inclusion in the "University Essential Records" master negative storage program. Original Archival Records that have been microfilmed may be destroyed if the use-copies of the microfilm are scheduled for later transfer to the University Archives. Original Archival Records that are scanned or otherwise converted for digital storage shall be transferred to the Archives unless an Archives-acceptable copy of the information can be provided for Archives storage.
AUTHORITY FOR DESTRUCTION:
No destruction shall take place unless an approved Records Retention Schedule exists that covers the records in question. Questions about documents not covered should be directed to the Records Management Program.
THE MANNER OF DESTRUCTION OF UNIVERSITY RECORDS:
The manner of destruction of Transitory/Disposable Records will depend on the classification of University Records in question. Records containing information classified as "Restricted," "High" or "Moderate" (including, but not limited to, any records containing unencrypted or un-redacted personally identifiable information) must be securely destroyed beyond recovery via cross cut shredding, electronic purging, or pulverizing hard drives. Records containing information classified as "Low" should be recycled. For electronic records, see the Electronic Data Disposal and Media Sanitization Standard adopted as a supplement to Policy AD95.
THE MANNER OF DESTRUCTION OF TRANSITORY/DISPOSABLE RECORDS:
The manner of destruction of disposable (or transactional) records will depend on the classification of University records destroyed. Records containing information classified as "Restricted," "High" or "Moderate" (including, but not limited to, any records containing unencrypted or unredacted personally identifiable information) must be shredded. Records containing information classified as "Low" should be recycled. For electronic records, see the Electronic Data Disposal and Media Sanitization Standard adopted as a supplement to AD95.
DESTRUCTION OF DRAFTS:
Units may retain drafts of any record during preparation. Upon finalization of the record, however, Units will retain only the final record, and all prior drafts shall be destroyed or deleted, as applicable, in accordance with this Policy. Once a record is slated for destruction under this Policy, all drafts of that record (both paper and electronic) must be destroyed.
For questions, additional detail, or to request changes to this policy, please contact the Records Management Officer or University Archivist.
Other Policies in this Manual should also be referenced, especially the following:
AD11 - University Policy on Confidentiality of Student Records
AD22 - Health Insurance Portability and Accountability Act (HIPAA)
AD23 - Use of Institutional Data
AD34 - University Recycling Program
AD95 - Information Assurance and IT Security
ADG01 - Glossary of Computer Data and System Terminology
ADG02 - Computer Security (formerly Computer Facility Security Guideline)
ADG08 - Collection, Storage and Authorized Use of Social Security Numbers (SSNs) and Penn State Identification Numbers
BS15 - Disposal and Purchase of Obsolete, Surplus or Scrap University-Owned Equipment, Supplies and/or Materials
FN14 - Use of University Tangible Assets, Equipment, Supplies, and Services
FN19 - Policy for Handling and Distributing Confidential Internal Audit Reports and Other Documents
HR60 - Access to Personnel Files
IP01 - IP01 Ownership and Management of Intellectual Property (Formerly RA11 - Patents and Copyrights [Intellectual Property])
Most Recent Changes:
- September 23, 2019 - Edited for the consistent use of and to clarify the DEFINITION OF TERM. Reorganized the POLICY section to align with the Records and Information Lifecycle as well as the services, procedures, and processes related to how University Records are managed. Added the new section of ROLES AND RESPONSIBILITIES to define the differences between the Records Management Program and the University Archives, as well as role and responsibility of the Units/College/Campuses to manage University Records.
Revision History (and effective dates):
- August 24, 2018 - Updated cross reference from AD20 to AD95.
April 17, 2018 - Edited to clarify the DEFINITION OF TERMS, and revised the POLICY section to reference AD95. Records falling under the moderate restriction must now be shredded. The process for the University Archives to open high and restricted collections to researchers has been updated. The FAQ is now listed as a cross reference.
- October 5, 2017 - Edited to change all references to GURU to the new Penn State Policies website.
- May 4, 2016 - Major edits to the SCOPE, DEFINITION OF TERMS, and POLICY sections to clarify terminology, responsibilities and parameters by which records management should be conducted. In the "Contents" section a link has been added to an FAQ, which answers to common questions about records management issues.
- September 17, 2014 - Editorial change- addition of policy steward information, in the event that there are questions or requests for changes to the policy.
- October 30, 2007 - Major revisions, per recommendations of the Digital Preservation Steering Committee and Records Management Advisory Committee.
- June 15, 2006 - Revision History added.
- June 1, 2005 - Editorial change to eliminate "General Forms Usage Guide" reference, and to add the correct links for the appendices referenced in the policy.
- August 3, 1998 - Added guidelines on the retention of email.
- January 10, 1995 - Numerous editorial changes.
- May 31, 1991 - New Policy.
Date Approved:September 23, 2019>
Date Published:September 23, 2019>