Compliance

RECORDS MANAGEMENT

Records Management is the administrative and systematic control of institutional records throughout their life cycle to ensure efficiency and economy in their creation, utilization, maintenance, retention, preservation, and disposition. NEOMED’s Records Management Program is coordinated across University departments and offices to ensure compliance with applicable laws as well as NEOMED’s Records Management Policy and Records Retention Schedule.

In short, records serve as NEOMED’s institutional memory. By managing these records in an efficient and economical manner, Records Management can:

  • Increase operational efficiencies;
  • Preserve NEOMED’s historical, administrative and other significant decisions for future management use;
  • Protect records from improper or unauthorized disposal;
  • Ensure that records are not retained unnecessarily;
  • Provide historical references of events and transactions as well as litigation support; and
  • Demonstrate compliance with legal and regulatory compliance.

What is a Record?

A record refers to any document, device, or item, regardless of physical form or characteristic, including electronic records, that is created, received by, or comes under the purview of the University, which serves to document the organization, its functions, policies, decisions, procedures, operations or other activities of the University. Records may include, but are not limited to:

  • Financial records such as requisitions, purchase orders, and invoices;
  • Administrative records such as annual reports, University bylaws, and policies; and
  • Publications issued by the University.

 

Transient Records

Transient (or transitory) records do not have long-term value and are not needed to preserve the actions of the University. Transient records exist for short-term usage and/or convenience and should be disposed in an appropriate manner once their administrative, legal, or fiscal use has expired. Examples of transitory records may include, but are not limited to:

  • Draft documents and supporting materials used in the preparation of final records;
  • User copies (not the original record);
  • “CC”, “BCC”, or FYI copies kept only for convenience; and
  • Meeting notices

 

Non-Records

As the name implies, non-records are documents, devices, or items, regardless of physical form or characteristic, including electronic records, that do not meet the “Record” definition. Examples of non-records may include, but are not limited to:

  • Personal notes to assist in recalling events;
  • Junk mail/spam;
  • Listserv® materials; and
  • Non-NEOMED publications

 

The Life cycle of a Record

All records have a life cycle with varying lengths. Records are created, used, kept for valid administrative, legal, or fiscal reasons, and are often disposed of at the end of their life cycles (minimum retention periods). There are some records with enduring historical value that will be archived in lieu of destruction.

A significant number of documents, items, etc. that we handle have no retention requirements at all (non-records) or have a very short retention period (transient records). By routinely and appropriately disposing these types of records, we can more effectively allocate our efforts on managing records with longer term retention periods and not be overwhelmed by managing large quantities of records with very short retention periods.

NEOMED has developed a Records Retention Schedule to comply with the specific requirements of the Ohio Revised Code that govern the management and destruction of records at Ohio public universities (Sections 149.33 and 149.351). The NEOMED Records Retention Schedule includes definitions and additional guidance to assist with the use of the Schedule.

University departments and offices shall manage University records in accordance with the Records Management Policy, which includes conducting a periodic inventory of records within their area and aligning them to the NEOMED Records Retention Schedule.

How Long Do I have to Keep/retain a Record?

  • Non-records may be destroyed at any time, without following the University destruction process.
  • Transient or transitory records have very short-lived administrative, legal or fiscal uses and should be disposed in an appropriate manner once those uses have expired (providing there is no legal or litigation hold), and may be disposed of without following the University destruction process. Generally, retention of transient/transitory records is not for a fixed period of time and is typically event driven – it may be as short as a few hours or it could be as long as several days or weeks.
  • All other records must be retained in accordance with the NEOMED Records Retention Schedule.

Avoid split records! The availability and accuracy of a record may be significantly compromised if the information is separated between documents and document types (for example, split between paper and electronic records).

Disposition of records shall be done in a timely manner and in accordance with the NEOMED Records Retention Schedule. Prior to disposition, a department or office needs to confirm that the minimum retention period of the records has been reached. Upon disposition, each Departmental Head/Lead, or their designee, shall sign and maintain appropriate Certificate of Records documentation, which includes appropriate cataloging information regarding the records being disposed.

There are two broad types of disposition available to University departments and offices: Destruction and Transfer.

Record Destruction

The appropriate method of destruction is determined based upon the University Data within a Record and the medium (i.e. electronic, paper) in which it exists. The “Disposal Method” column within the NEOMED Records Retention Schedule indicates whether the destruction should be done securely via shredding or electronic deletion (“Destroy – Secure”) or simply via recycling or wastebasket disposal (“Destroy”).

University departments and offices are strongly encouraged to review their records and facilitate the appropriate destruction of applicable records annually.

Destruction Process
  1. Once it has been determined that records have passed their minimum retention period, an employee should begin a Certificate of Records Destruction (“CRD”). By using the Records Retention Schedule, an employee can document the records they wish to destroy within the “Record Inventory” section of the CRD.
  2. Once that section is completed, the employee can then forward the CRD to the respective Departmental Head/Lead, or their designee, which serves as the Keeper of Record (as noted within the Records Retention Schedule).
  3. The Departmental Head/Lead, or their designee, should then review the Record Inventory, verify that the records meet the requirements outlined in the CRD, and if approved, sign.
  4. Upon signature by the Departmental Head/Lead, or their designee, the signed CRD should then be forwarded to the Office of the General Counsel for review and signature.
  5. The Office of the General Counsel will review the Certificate and conditionally authorize the destruction of the records (via the CRD) to ensure that no records are disposed of prematurely or in violation of existing laws or statutes.
  6. Upon signature, a signed copy will be returned to the employee.
  7. Upon receipt of the fully signed and approved CRD, the record inventory may be destroyed using the appropriate method outlined within the Records Retention Schedule. The CRD must be fully signed and approved before any records are destroyed.

Record Transfer

Whether a record should be transferred to a Departmental Archive is ultimately determined based upon its historical value, such as documenting the significant decisions, reports, or operations of the University. The “Disposal Method” column within the NEOMED Records Retention Schedule indicates whether records should be reviewed for archival (“Archival Review”) or transferred to the respective Departmental Archives (“Transfer to Archives”).

Please allow sufficient time by the department/office prior to the date you wish to transfer records. Adequate lead time will allow others to be fully prepared to receive transfer of materials.

Transfer Process (Paper Records)
  1. Once it has been determined that records have passed their minimum retention period, an employee should begin a Certificate of Records Transfer (“CRT”). By using the Records Retention Schedule, the employee can document the records they wish to transfer within the “Record Inventory” section of the CRT.
  2. Once that section is completed, they can then forward the CRT to the respective Departmental Head/Lead, or their designee, of the University office or department which serves as the Keeper of Record (as noted within the Records Retention Schedule).
  3. The Departmental Head/Lead, or designee, should then review the Record Inventory, verify that the records meet the requirements outlined in the CRT, and if approved, sign.
  4. Upon signature, the Departmental Head/Lead, or designee, will return a signed copy of the CRT to the employee who completed the Certificate to be used in the transfer process. The original will be retained by the Departmental Head/Lead.
  5. The employee will then coordinate the transfer of records with the Departmental Head/Lead, or designee, to the Departmental Archive.
    1. Large volumes of paper records should be packed into appropriate record containers. Please do not remove records from file folders when packing.
    2. Records transferred must have the signed CRT attached to the container for appropriate storage and efficient retrieval.
Electronic Records

Paper-based records may be converted to an imaged electronic record through document imaging (often referred to as a “scanned document”). Electronic records are to be managed in the same manner as Records in other formats (i.e. paper, audiotape) and in accordance with the NEOMED Records Retention Schedule. For additional assistance with electronic records, please contact recordsmanagement@neomed.edu.

What is Email?

An email (electronic mail) is a digital message that is comprised of the textual message, attachments, and metadata (To, From, Subject, Time, Date, System, etc.)

Is Email a Record?

What is key to understand is that email is not a type of record, but is a means of conveying information, similar to the Unites States Postal Service. As such, email retention is based upon the content of the email, not the fact that it is an email. As such, each component is part of the record or non-record, as the case may be. In many instances, email has taken over the role of memos, general correspondence, and making a telephone call.
If an email meets the criteria of a “record”, it must be managed as such, with as much effort and vigilance as one would a “traditional” record; however, keep in mind there are only a small percentage that meet this criteria, therefore there are few emails we should have to manage for any significant period of time.

Email Management

University email servers are not intended for long-term or indefinite record retention; therefore, appropriate management of email by each user is important. In order to do this, one must determine whether the content of the email is a record or not.

The following are high level steps one can follow to manage email:

  • Open  the  email  and  review  its  content. This  may  mean  thoroughly  reading  the  document,  but  more  often than not, one is able to judge just by a cursory look at the document, the subject line, and/or the sender. Then…
    • If after review, the email is a Non-Record:
      • After its use, delete the message outright,  just as one would  dump the “junk  mail” non-record into the trash can or recycle bin.
    • If after review, the email is a Transient Record:
      • Place it in a folder or sub-folder that is designated for periodic review and dispose of it as soon as allowable. You could create a “Transient” folder or create sub-folders of record categories for transient records.
    • If after review, the email is a Record:
      • Place it in an appropriate folder that allows you to effectively manage the life cycle of the record, whether electronically or printed. This could be done by Record Series or Category, retention period, or as recommended by your department, office, or the University.

Other Considerations

  • When email is deleted from your computer, it may not be fully deleted. Your email may be retained by the sender (or some other recipient) or it may be backed up and stored elsewhere.
  • When an email is deleted, its metadata is lost (i.e. the To, From, Subject, Time, etc.). Metadata can establish when the email was created, if it was altered, etc,. and in some circumstances, that information can be very important when such detail is needed.

NEOMED has created a Public Records Policy to assist in facilitating prompt access to public records and to ensure compliance with the Ohio Public Records Act. The Office of the General Counsel is the designated office for receiving and reviewing all public records requests. For more information, please refer to the Office of the General Counsel’s website.

I believe I have records that are not listed on the Records Retention Schedule. What should I do?

All records on the Records Retention Schedule are categorized by Record Category and Record Series; therefore a specific record may not be explicitly listed. A Record Series is a group of related records filed and/or used together as a unit because they relate to a particular subject or function, result from the same activity, or document a specific kind of transaction; therefore, these related records are evaluated as a unit for retention and disposition purposes. For example, library fines are not explicitly listed on the Schedule as its own record series, but since they deal with debt, they can be found under “Bad Debt Documentation” and in this case, is noted within the Record Series Description. In addition to searching by Record Category, you can use the “find” function (CTRL+F) within the Schedule to do a word search.

If after review, the NEOMED Records Retention Schedule does not appear to list the type of record you have, please contact recordsmanagement@neomed.edu for guidance.

Where Can I Find the NEOMED Records Retention Schedule and the Certificates of Records Destruction and Transfer?

Links to the NEOMED Records Retention Schedule and Certificates can be found on the top-left portion of this webpage.

Can I keep records for a longer period than what I found on the Records retention schedule?

Many often ask about keeping records longer than the minimum retention period due to worry that they might eventually need the records one day. We discourage this practice, since it leads to inefficient and ineffective records management and potentially opens the University to liability. If you believe you have a legitimate business reason to maintain records longer than what is suggested on the Records Retention Schedule, please contact recordsmanagement@neomed.edu for guidance.

can I keep records for a shorter period than what I found on the Records retention schedule?

No department or office may keep records for a shorter period than indicated on the NEOMED Records Retention Schedule, under any circumstances. Many minimum retention periods within the Schedule represent the minimum legal periods necessary to ensure the University’s compliance with various state and federal laws and regulations.

Is there any training on records management?

Yes. In addition to classroom trainings being held in the Fall of 2019, the training will be made available within the NEOMED Success Center before in the coming months. If you would like to request a training for your department or office, please contact recordsmanagement@neomed.edu.

If a Minimum retention period is “Active+years”, when does the active period end?

“Active” means as long as the relationship is active. It is often seen with employee, student, grant, equipment, and research records. In these examples, it would mean as long as the employee has an active employment relationship with NEOMED, as long as the student is actively enrolled at NEOMED, as long as the grant period is active, as long as the equipment is active (life of equipment), and as long as the research study, activity, or project is ongoing (not completed or closed), respectively.

What do I do once the Minimum Retention Period has passed?

After the minimum retention period for records has passed, you should follow the corresponding instruction within the “Disposal Method” column of the NEOMED Records Retention Schedule. Most records will be destroyed after the minimum retention period has passed. If the Disposal Method is “Transfer to Archives”, you must transfer the records to respective Departmental Archive. Please see the “Records Destruction and Transfer” section on this webpage for more information about the Destruction and Transfer processes.

How do I transfer records to the Departmental archives?

Please see the “Records Destruction and Transfer” section on this webpage for more information.

How do I destroy records?

Please see the “Records Destruction and Transfer” section on this webpage for more information.

I have a whole room full of boxed paper records I want to destroy. Can you shred them for me?

Centralized shredding services are not offered; however, the University utilizes approved shredding vendors that can be utilized. Please contact the Office of Accounting and Budget for more information on larger destruction opportunities.

If I convert a paper-based record to an electronic record, Do I still need the paper-based Record?

No. You can destroy the paper-based record once the electronic record has been created and inventoried.

If I convert a paper-based record to an electronic record, Do I need to fill out a Certificate of records destruction to destroy the paper-based record?

No, a Certificate of Records Destruction (CRD) is only needed when the final record, regardless of form, is ready for destruction. Please keep in mind, the appropriate method of destruction should be used for the paper-based records in accordance with the Records Retention Schedule (the method used is based upon the classification of University Data within the record, i.e. non-public personally identifiable information, financial information, etc.)