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Policy: Records Management 


Date: 11/26/12 Policy ID: IRM-017 Status: Final

Policy Type: University
   
Contact Office: University Records Management Office or Medical Center Risk Management or College at Wise Library
   
Oversight Executive: Chief Information Officer
   
Applies To: 

Academic Division, Medical Center, College at Wise, and University-related Foundations.

   
Table of Contents:  Policy Statement
  1. Agency Requirements
    1. Records Management
    2. Special Records Requests
  2. University-related Foundations
  3. Responsibilities

Procedures

   
Reason for Policy:  The University of Virginia is committed to adhere to best practices for the management of all University records regardless of format to:
  • comply with state and federal statutory requirements, including the Virginia Public Records Act;
  • reduce risks associated with unintended disclosure of sensitive information;
  • respond efficiently to record requests and preservation orders; and
  • protect vital and historical information about the University.
   
Policy Summary: 

This policy supports the consistent, efficient, and comprehensive management of University records. It establishes expectations for all University state agencies (207, 209, and 246) to comply with the Virginia Public Records Act via standards and guidelines issued by agency designated records officers for the management of University records. It clarifies that University-related Foundations are not subject to the Virginia Public Records Act but are strongly advised to follow best practices for records management.

   
Definition of Terms in Statement: 

University Records: Recorded information that documents a transaction or activity by or with any appointed board member, officer, or employee of the University. Regardless of physical form or characteristic, the recorded information is a University record if it is produced, collected, received or retained in pursuance of law or in connection with the transaction of university business. The medium upon which such information is recorded has no bearing on the determination of whether the recording is a University record.  University records include but are not limited to: personnel records, student records, research records, financial records, patient records and administrative records.  Record formats/media include but are not limited to: email, electronic databases, electronic files, paper, audio, video and images (photographs).

Historical/Archival Records: University records that document transactions or activities of the University designated by the University Archives and/or designated historical records repository, the agency’s designated records officer and the Library of Virginia as having long-term historical value in the Records Retention and Disposition Schedules. Records with historical value may include documentation of decisions, activities, and products of the University. Examples of historical records include but are not limited to: Board of Visitor meeting minutes, President’s correspondence, research final reports and accreditation records.

Records Officer: An appointed official designated by the state agency who is responsible for providing standards, procedures, training and guidance to meet requirements for the proper management of University records. Appointments of agency records officers must be filed with the Library of Virginia per state code § 42.1-85 C

Records Retention and Disposition Schedule: A listing of records series, approved by the Library of Virginia, that provides retention and disposition instructions for University records. 

Disposition: Final destruction or transfer of records to the proper archival repository.

Retention: The length of time records should be kept in a certain location for administrative, legal, fiscal, historical or other purposes.

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Policy Statement: 

The University of Virginia will comply with federal and state statutory requirements and specifically, the Virginia Public Records Act, in the handling of University records.
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  1. Agency Requirements:
    The Academic Division (Agency 207), the Medical Center (Agency 209), the College at Wise (Agency 246) must:
    1. Records Management:
      1. Comply with retention and disposition instructions in the individual agency’s Records Retention and Disposition Schedules approved by the Library of Virginia.  [Note: For the Academic Division, see University Records and Retention Schedules. The Medical Center and the College at Wise Records and Retention Schedules are published on each respective website.]
      2. Store physical records in compliance with the Institutional Physical Records Storage Standards for onsite and offsite locations. Offsite storage requires review and approval of the agency’s designated records officer.
      3. Store electronic records in accordance with the Institutional Data Protection Standards and guidelines from the agency’s records officer for management and authenticity.
      4. Destroy University records once the retention period in the University Records Retention and Disposition Schedules has expired. A Certificate of Records Destruction (RM3 Form) must be approved by the agency’s records officer as required by the Virginia Public Records Act before destruction. [Note: For the Academic Division, see Destruction of Public Records. The Medical Center and the College at Wise Records and Retention Schedules are published on each respective website.]
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    2. Special Records Requests:
      1. Historical/Archival University Records: Transfer records designated with historical/archival value, as listed in the Records Retention and Disposition Schedules, to the designated archival repository.
      2. Audits, Court Orders, Investigations and Freedom of Information Act Requests: Retain all records  requested or placed on hold by internal offices (such as General Counsel, Internal Audit, Office of Sponsored Programs, Public Affairs, Medical Center Corporate Compliance and Privacy Officer, etc.) until cleared by the office placing the hold, regardless of retention requirements.  Offices placing holds or requests for University records should copy the agency’s records officer on all notices.
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  2. University-related Foundations:
    While University-related Foundations are not subject to the Virginia Public Records Act, Foundations are strongly advised to follow best practices for records management.  Foundations may use consulting services provided by the University Records Management Office (Agency 207) in conjunction with proper records management.
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  3. Responsibilities:
    1. The agency records officer is responsible for developing standards, guidance and providing assistance to organizational units within their agency for managing University records, including designation of confidential or records containing highly sensitive data.
    2. All Academic Division, Medical Center and College at Wise employees (faculty, staff and board members) should receive records management information about their responsibilities as an employee/board member at the time of hire/appointment. Each agency will determine the area responsible for providing records management information. For the Academic Division, University Human Resources will provide such information.
    3. Supervisors should support additional records management training for their employees from the agency’s records officer or other approved compliance-related training that includes standardized information on records retention and compliance with the Virginia Public Records Act.

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Procedures: 

For the Academic Division:
All Academic Division (Agency 207) guidance and procedures are available on the University Records Management Office website.
Destruction of University Records and Certificate of Records Destruction (RM3 form)

For the Medical Center:
Medical Center (Agency 209) guidance and procedures are available on the Medical Center Risk Management website

For the College at Wise:
College at Wise (Agency 246) guidance and procedures are available from: the Cataloging Librarian, acv6d@uvawise.edu.

All other agencies and foundations may contact the University Records Management Office for assistance with guidance and procedures for records management.
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Related Information: 

Virginia Public Records Act, Chapter 7 of Title 42.1 of the Code of Virginia (§ 42.1-76 et seq)
Virginia Freedom of Information Act, Chapter 37 of Title 2.2 of the Code of Virginia (§ 2.2-3700 et seq)

University Policies:
XV.C.1, Disclosure of University Records
IRM-004, Electronic Data Removal
IRM-014, Protection and Use of Social Security Numbers
IRM-015, Electronic Storage of Highly Sensitive Data
IRM-016, Use of Email for Official Communication with Students
RES-002, Laboratory Notebook and Recordkeeping
STU-002, Rights of Students at the University of Virginia Pursuant to the Family    Educational Rights and Privacy Act (FERPA)

Medical Center Policies:
0223, Government and Regulatory Investigation Response
0266, Records Management/Document Retention and Destruction
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Policy Background: 
   
Major Category: Information Resource Management
   
Category Cross Reference: 
   
   
Process: 
   
Next Scheduled Review: 11/26/15
   
Approved By, Date: Policy Review Committee, 11/26/12
   
Revision History: Revised 1/15/2013.
   
Supersedes (previous policy):  

II.C.I, Records Retention and Disposition