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RECORDS APPRAISAL AND SCHEDULING
Once you know what records the agency has, the next step is to decide how long each record series should be kept in the office and in storage before being destroyed. To do this you must determine the immediate and future usefulness of the records to the agency, as well as to the entire state government. In general, records should be retained in office areas as long as they serve the immediate administrative, legal and fiscal purposes for which they were created. When records no longer serve these purposes, they should either be destroyed, transferred to a records center or, if flagged on an approved Records Retention Schedule, deposited in the State Archives.
WHY APPRAISE RECORDS?
A sound records management program requires a realistic appraisal of the records in relation to their period of usefulness and value to the agency that created them. By appraising records you are able to:
- Establish reasonable retention periods.
- Identify records that can be destroyed immediately.
- Identify records that can be transferred to a records center.
- Identify vital records.
- Identify confidential records.
- Identify records that are exempt from:
- Information Practices Act (IPA) and/or
- Public Records Act (PRA)
WHAT VALUES SHOULD BE CONSIDERED?
Administrative Value. Records are created to help accomplish the functions for which an agency is responsible. They have administrative value as long as they assist the agency in performing either current or future work. The primary administrative use of most records is exhausted when the transactions to which they relate have been completed. From that point on they lose their value rapidly. However, some administrative records contain basic facts concerning an agency's origin, policies, functions, organization and significant administrative decisions. These records should be preserved to provide adequate documentation of an agency's operations.
Legal Value. Records have legal value if they contain evidence of legally enforceable right of obligations of the state. Examples of these are records that provide the basis for action, such a legal decisions and opinions; fiscal documents representing agreements, such as leases, titles and contracts; and records of action in particular cases, such as claim papers and legal dockets.
Fiscal Value. Records of fiscal value are those which pertain to the financial transactions of the agency, such as budgets, ledgers, allotments, payrolls and vouchers. After records have served their basic administrative functions, they may still have sufficient fiscal value to justify their retention in storage for a time to protect the agency against court action or to account for the expenditure of funds.
Research, Historical of Archival Value. Some records have enduring value because they reflect significant historical events or document the history and development of an agency. The importance of preserving such records is obvious. Not so apparent, however, is the need to examine critically those record selected for research purposes and to re-evaluate them periodically to ensure that the material being accumulated is actually filling a valid research need.
DETERMINING RETENTION PERIODS
Keeping records, either in offices or storage areas, costs large sums of money. The actual or potential value of the records should be weighed against the cost. There is a calculated risk in this business and a good records management program requires that we take it. There have been instances when an organization became so enthusiastic about the possibility of freeing office space by clearing out its old records that it went too far and discarded material too soon. But usually this is not the problem. Most of us tend to be overly cautious and to exaggerate the frequency of our reference to material when considering establishment of retention periods.
The questions we must ask ourselves are: How serious would it be if we were unable to put our hands on a particular record 5 or 10 years from now? What are the chances of it being needed? Are the consequences serious enough to justify our keeping thousands of cubic feet of records for a long period of time at considerable cost? Is the information available anywhere else? What would it cost to reconstruct the record if this became necessary? By asking ourselves these kinds of questions, we can begin to take a more realistic approach to the problem of determining how long records should be kept.
Setting retention periods involves negotiation with those persons who use the records. They must be encouraged to look realistically at their need for them. You should not accept the answer that the records are used all the time and therefore must be kept permanently. You should look at the problem from the viewpoint of the operating person and be willing to compromise on a retention period if the alternative is no retention period at all. Reference data obtained by a file usage survey, in the case of active records, or from the records center, in the case of records stored there, provide a basis for re-evaluating the records at a later time and possible reducing retention periods.
When retention periods have been established for all records, a schedule can be developed to formalize the decisions on retention periods and provide the basis for a continuing program of records management.
WHAT IS A RECORDS RETENTION SCHEDULE
A records retention schedule is a written statement of actions to be taken with respect to all records produced or maintained by the agency. It assists the agency in affecting the prompt disposal of records no longer needed, the storage of records that must be retained temporarily after they are no longer needed for current operations and the preservation of records which are of historical value.
A schedule shall:
- Cover all records created and maintained by the agency.
- Provide an accurate description of each record series.
- State the number of years (retention period) each record series should be retained in office, department and/or records center space before destruction or transfer to the State Archives.
A properly prepared schedule should be used daily as a training aid, for purging instructions and as a reference before disclosed contents of records. It can be used to track increases in workload, changes in procedures and reorganizations. Most importantly, records schedules are planning devices that provide the legal basis of departmental records (and information) treatment and destruction. It is also used to plan for State Records Center (SRC) use, imaging activities, vital records protection and enables the Office of State Archives to identify historically significant records. Schedules make sure decision-makers have information as long as it is needed and help avoid keeping records longer than the information is worth in storage and maintenance costs.
CREATING THE SCHEDULE
Form STD. 73, Records Retention Schedule is to be used for scheduling records. Instructions for completing a schedule are on the back of the form. Contact the CalRIM for training or additional materials for completing schedules.
ALL records must be scheduled. Records kept "permanently" (those which will never be destroyed) must also be scheduled. Schedules must be amended promptly when treatment of the record must be changed.
Experience has shown that without careful and explicit description of the treatment of the records, specific information can be lost when people who originally prepared the schedules leave state service, promote or transfer.
The CalRIM is willing to review a draft of a schedule before it is finalized. Review of a draft can often save time and work. The following points will assist in preparing an accurate schedule on the first attempt.
- The CalRIM reviews schedules for appropriateness of retention periods, clarity and completeness. The Chief of State Archives in the Office of the Secretary of State reviews material worthy of preservation for historical or research purposes. Titles, descriptions and treatment of records listed on a schedule MUST BE CLEAR to persons unfamiliar with the business of the agency or the purpose of the records.
It is important to follow the instructions on the back of the Records Retention Schedule form STD. 73.
- Ensure record schedules have been reviewed and approved by the program manager responsible for the records. The program manager is considered the records custodian and signs as the authorized agent to approve retention and destruction authority.
If records that have been destroyed are subpoenaed for court, agency schedules (AND EVIDENCE OF COMPLIANCE WITH THOSE SCHEDULES) will defend the agency's actions. If schedules are not specific, it may not be possible to prove there was no adverse intent when the records were destroyed. Adverse intent (in keeping records out of court) is both a civil and criminal offense.
- If word processing is available, agencies are encouraged to use this method to prepare schedules. Either the Records Retention Schedule (STD. 73) may be used, or the form may be formatted by word processing with all the titles from the STD. 73. In this latter case, vertical rules do not need to be entered but a sample format must be submitted to the SIRM for review and approval.
- After the schedule has been reviewed by the SIRM and the approval number assigned, the approval number may be used to support a request for a purchase of equipment (see Exhibit B) or to store records in the records centers. Records may not be destroyed according to a new retention period until the State Archivist has completed a review of the schedule.
- When the approved schedule is returned to the agency Records Management Analyst, a copy of the schedule must be sent to the person(s) responsible for maintaining the records.
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