MCCCD Records & Information Management (RIM)
- What is a record? What is not?
- What are records management, information and information management?
- What are public records?
- Are MCCCD records considered public records?
- What types of records are there?
- Who is responsible for managing MCCCD records?
- What does "custodian of record" mean?
- Who is the custodian of record?
- How long do I keep my records?
- How do I dispose of records?
- What do I do when there is a legal investigation / possibility of one?
- How do we secure confidential records? Destroy them?
- Can confidential personnel information be included in adjunct faculty files?
- Can we store our records offsite?
- Are there legal requirements to protect records from fire, smoke, or water damage?
- Who holds the official document when it passes multiple "hands?"
- Are copies considered records?
- If a paper document is scanned can the electronic file serve as the official record? Can the paper document be destroyed?
- What are the standards a vendor has to meet in order to scan documents for us?
- How long should adjunct faculty files be maintained?
- Are student classroom assignments/projects considered records?
- How long past a grant end do files need to be kept? Where should they be stored?
- Who is the custodian of grant records?
- What records have already been placed on the retention schedule?
- Who prepares new Records Retention and Disposition Schedules? Does the District have to approve it?
- Who prepares and signs the Certificate of Records Destruction form?
- Are there district-wide services available to help with records destruction?
- Data management resources (provided by District IT)
- ARS §41-1350 states records are: All books, papers, maps, photographs or other documentary material, regardless of physical form or characteristics… made or received… in connection with the transaction of public business… Records may include computer-based records, voicemail, text messages, email, photographs, motion pictures, video and audio recordings, charts, maps, drawings, plans, micrographics and more.
- ARS §41-1350 states: …material made or acquired solely for reference or exhibition purposes, extra copies of documents preserved only for convenience or reference and stocks of publications or documents intended for sale or distribution are not included within the definition of records…
- Records management is the maintenance and disposition of records (Arizona Revised Statute, ARS §41-1346.D defines records management as....the creation and implementation of systematic controls for records and information activities from the point where they are created or received through final disposition or archival retention, including distribution, use, storage, retrieval, protection and preservation)
- Information is data that has been given value through analysis, interpretation or compilation in a meaningful form
- Information management is the infrastructure, processes and technologies used to store, generate, manipulate and transmit information to support an organization
- Other common terms used in relation to records management:
- Records retention is the maintenance of documents for further use (includes security for confidential information)
- Records disposition is the destruction of records with lawful authority based on an approved retention and disposition schedule by the Arizona State Library, Archives and Public Records Department
- NOTE: Destroying public records without lawful authority is a class 4 felony (ARS §38-421) as are destroying records while a legal investigation is in action/pending
- All records made or received by public officials or employees of the state in the course of their public duties are the property of the state (ARS §41-1347(A))
- Public records shall be open to inspection by any person at all times during office hours (ARS §39-121)
- All public bodies shall maintain all records... reasonably necessary or appropriate to maintain an accurate knowledge of their official activities and of any of their activities which are supported by monies from the state or any political subdivision of the state (ARS §39-121.01(B))
- MCCCD is a political subdivision of the state
- A political subdivision is a quasi-government agency with powers and duties established in the state constitution and in state statute.
- Most records created by the MCCCD are considered public records
- Disclosure: To reveal, to make known, or to make available for inspection. With the exception of student education records, the majority of records that are created are subject to review.
- Non-disclosure: The act of, or decision made, to not disclose a record. Public officials cannot arbitrarily decide what information not to disclose. Requests may be denied based upon the requirements established by state and federal law. Denying access to public records may occur if:
- The information is statutorily confidential or privileged (FERPA, HIPAA)
- The information falls within an individual’s right to privacy (personal address/phone, social security number)
- It is not in the best interest of the State to release it (to do so would seriously impair performance of duties)
- The records are sealed by Court Order
- Questions regarding disclosure or non-disclosure should be directed to the Office of General Counsel
- Confidential information is protected from Public Records Requests (except during a legal discovery process)
Documents (and data) are considered records if they provide value to the MCCCD
- Administrative: Records that are needed to conduct an office’s daily business (i.e., Procedures Manuals, Retention Schedules, Memos, Reports)
- Fiscal: Records needed to document the audit trail of monies (i.e., Budget Records and Expenditure Reports, Wage and Salary, Benefits, Business Forms-Petty Cash Vouchers, Book Vouchers, Travel Requests, Expense Claim Forms)
- Legal: Specific legal requirements to keep records for a given period of time can be found in the Arizona Revised Statues (ARS), United States Code (USC) and Code of Federal Regulations (CFR) or any document that shows an agreement between MCCCD and another entity or that MCCCD uses to regulate itself by aligning with State/Federal laws (i.e., Contracts and Agreements, Administrative Regulations, Governing Board Policies)
- Historical: Any document that details the conception, creation, operation, and evolution of MCCCD and its community partnerships (i.e., Governing Board Minutes, Student Records, Chancellor/President Papers, College History, Photos, Plans, Architectural Renderings)
- Academic / Instructional: Documents that are used in the process of instruction (i.e., course syllabi, instructional materials and student work–papers, exams, projects, portfolios, art work, performance pieces, etc). Although student work is not subjet to a retention schedule or release, it must be protected as confidential information.
- All Maricopans (whether full-time, part-time, OSO, OYO, temporary or adjunct) are responsible for the documents they create in the course of daily operations
- All faculty, staff and administrators are responsible for knowing about records management, information management and public records
- The Office of Public Stewardship provides training and guidance on records management
- The party or area at a college or at the district office designated as being responsible for the maintenance and/or retention of specific records
- The custodian of record will also oversee the review of records prior to release as well as the reproduction of records when requests for copies are made
It depends on who created it, the purpose and who has jurisdiction over the final product …
- Performing a records inventory can help determine which records a department / division / group are responsible for
- Knowing the process each document goes through is also valuable in determining who holds the official record
- A retention and disposition schedule approved by the Arizona State Library, Archives and Public Records for Arizona Community Colleges and Districts can be found online at http://www.lib.az.us
- In the event documents in your department / division / group are not listed as part of the schedule, a new schedule can be created by working directly with the Office of Public Stewardship
- Check to see if there is a pending or imminent litigation, audit or government investigation
- If there is a question, do not destroy anything even if the schedule says it’s time
- If there is no action pending:
- Non-confidential records may be recycled or thrown away
- Confidential records must be shredded or burned in a manner which maintans confidentiality
- Non-record copies should be destroyed at the same time as the record
- A Certificate of Document Destruction form should be prepared and sent to the Arizona State Library, Archive and Public Records
- Destroy nothing until the legal action, audit or investigation has been released or completed
- You may box records and mark for destruction at a later date but they must remain available and accessible
- Confidential records should be kept in a location that provides limited access to approved individuals (those responsible for maintaining them)
- This can be done either by securing them in a locked cabinet, locked storage area, or offsite in a storage facility that provides limited access to approved individuals
- Confidential records must be shredded or burned in a manner which maintains confidentiality
Provided adequate security is provided, yes, with the following exceptions:
- I9 forms
- Medical information (i.e., FMLA requests)
Yes, provided the vendor can adequately guarantee appropriate security for confidential records and relative ease to retrieve records in a timely manner (normal business hours)
There are legal requirements for MCCCD to maintain records but no specific laws stating that those records must be stored in fire-proof or water-proof containers; however, it's a good idea to make sure that they are reasonably protected
- It depends on the document
- In most cases, the creator of the document is considered the custodian of record; however, in instances where the document needs to be signed or in which the "original" is considered the official version, that document, wherever it ends up, is the record
A copy is not a record, but may become one if the original is destroyed but the copy is not
- It depends on the document, what function is serves and how long the record needs to be preserved
- If the document serves an historical or legal purpose, the paper document must be preserved (forever, in the case of documents with historical value)
- If the document falls in the administrative or fiscal categories (i.e., invoices) then those may be destroyed once scanned as long as there are no statues or federal regulations stipulating otherwise
- Areas interested in scanning documents need to fill out an Imaging Request form and ensure the vendor responsible for scanning the documents is in compliance
- Imaging Request for Minutes – Source Docs Not Destroyed – strictly used when Minute records are imaged and used online (Word)
- Imaging Request for Microfilm – used if you would like to microfilm Permanent records (Word)
- Imaging Request – Source Docs Not Destroyed – used for records with a total retention period less than 10 years, where you would like to image the records, but still hold on to the paper copies (Word)
- Imaging Request – Source Docs Destroyed - used for records with a total retention period less than 10 years, where you would like to image the records, and then destroy the paper copies (Word)
- Imaging Request – Old style form – used if you would like to image records that have a total retention period greater than 10 years, or if the records have an indefinite retention period, or for multiple records series with various retention periods (Word)
Minimum Standards for Digital Imaging or Scanning Textual Documents
Standards for additional formats to follow.
For further information please call the State Archives (602) 926-3720
Scan Resolution assumes 100% scan ration and original 8.5"x11"
Your scanning request must be approved by the Records Management Division, Arizona State Library, Archives and Public Records. Please contact Jerry Lucente-Kirkpatrick at: 602-926-3820.
Textual Documents With/Without Illustrations in Text Retention of Records 20 Years or Less Retention of Records 21 Years to Permanent Minimum Scan Resolution Save as File Format Additional Notes Minimum Scan Resolution Save as File Format Additional Notes Use lossless compression Some exceptions may apply Details Clean, high contrast documents with smallest character of 1.0mm or larger, text only 200 dpi bitonal
TIF (group 4 or 6)
OCRing will require 300 dpi 400 dpi TIFF (RAW or group 6)
Grayscale as needed Documents with handwritten notes/markings, low contrast, half-tone illustrations, photographs or poor legibility 300 dpi grayscale
TIF (group 4 or 6)
600 dpi grayscale TIFF (RAW or group 6)
Documents and items where color is important for accurate representation 300 dpi 24-bit color JPEG
600 dpi 32-bit color TIFF (RAW or group 6)
Note: Careful attention must be paid to metadata, file naming schemas, directory structure, versioning, naming of derivative files, long term storage, migration, backup and disaster recovery to ensure "faithful reproduction" and access to the document over time.
"Faithful digital reproductions are digital objects that are optimally formatted and described with a view to their quality (functionality and use value), persistence (long-term access), and interoperability (e.g. across platforms and software environments). Faithful reproductions meet these criteria, and are intended to accurately render the underlying source document, with respect to its completeness, appearance of original pages (including tonality and color), and correct (that is, original) sequence of pages. Faithful digital reproductions will support production of legible printed facsimiles when produced in the same size as the originals (that is, 1:1)." (Quoted from: Digital Library Federation's Benchmark for Faithful Digital Reproductions of Monographs and Serials at http://www.diglib.org/standards/bmarkfin.htm and supported by Federal Agencies Initiative Still Image Working Group's Technical Guidelines for Digitizing Cultural Heritage Materials http://www.digitizationguidelines.gov/guidelines/FADGI_Still_Image-Tech_Guidelines_2010-08-24.pdf .)
• These are general recommendations. Considerations such as original document size, quality, legibility, image characteristics (spatial resolution, signal resolution, and color mode) and intended use will be needed to be taken into account digital reproductions.
• Scan resolution assumes 100% scan ratio (1:1).
• This table provides the minimum guidelines for digitization. Use the appropriate standard in the table above that most closely matches the overall content of the items you wish to digitize.
• Quality control will need to be performed consistently throughout the process to ensure quality of scans. Check with Records Management Division for quality control requirements.
• Digitization thresholds need to be adjusted based on contrast of original document. You must evaluate the digital output quality to verify that the digitized version accurately represents the content of the original document.
• You must evaluate the legibility of the scans regardless of meeting standards. Meeting minimum standards does not imply legibility of the digital reproduction.
These standards are based, in part, on the following:
Federal Agencies Initiative Still Image Working Group's Technical Guidelines for Digitizing Cultural Heritage Materials http://www.digitizationguidelines.gov/guidelines/FADGI_Still_Image-Tech_Guidelines_2010-08-24.pdf
A Framework of Guidance for Building Good Digital Collections - NISO Recommended Practice
Technical Guidelines for Digitizing Archival Materials for Electronic Access
Last Updated: February 13, 2011 by LR
- Personnel files should be maintained for five years from date of separation; contracts should be maintained for three years after completion or cancelation
- If the information in the files is duplicative of records held elsewhere, the college may dispose of the documents as designated by the department/division (they are considered "copies")
- If the documents are not housed elsewhere, then the college is responsible for ensuring the records are maintained for the appropriate duration set by the retention schedule
- Student classroom assignments/projects are not items subject to a retention schedule or public release—however, they are items that need proper disposal or destruction
- Faculty may choose to:
- Return assignments/projects to students OR
- Retain up to one year (the length of time a student has to put in a grade grievance) and then destroy as per confidential records
- It depends on the type of grant and what part
- Some parts, like the administrative sections which concern money, budget and allocation, can be discarded after the appropriate time limit (which are usually regulated by the grant funding source)
- Other parts, like the written plan and final project report are considered historical and will need to be kept forever
The grant manager is the custodian of record
The retention schedule for community colleges can be found online at http://www.lib.az.us/records/pdf/CommCollRD1.pdf
Any department/division/group may prepare a schedule in conjunction with the Office of Public Stewardship to meet the needs of their area if they have not already been defined in the retention schedule
The custodian of record
Several colleges have contracted to outside vendors to securely destroy confidential records or recycle non-confidential records and some colleges have shredders onsite; contact your college business office for more information