A Beginners Guide to Record Retention

This is a guest post by Carmel Curtis.

Over the past eight months I have been working as the National Digital Stewardship Resident at the Brooklyn Academy of Music. BAM is the oldest continually running performing arts center in the country and is home to a range of artistic expressions in dance, theater, film, and beyond. Over 150 years old, BAM has a rich history.

I have been working on a records management project at BAM. My mentor, processing archivist Evelyn Shunaman, and I have conducted 41 hour-long interviews with all divisions, departments and sub-departments to get a sense of what and how many electronic records are being created, saved and accessed. Then we created or revised departmental Record Retention Schedules to ensure they reflect BAM’s current workflows and practices.

Here are some of basics of records retention and tips on creating a Records Retention Schedule.

A Records Retention Schedule is an institutional or organizational policy that defines the information that is being created and identifies retention requirements based on legal, business and preservation requirements. An RRS can take many forms. Example 1 shows our RRS spreadsheet.

Example 1. BAM RRS spreadsheet.

An RRS is a way for an institution to:

• Be accountable to any legal requirements – An RRS is a policy that ensures records are retained in accordance with state or federal legal requirements. It provides an outline for the minimum legal requirements related to the retention and destruction of records.
• Identify archivally significant materials – Appraisal and selection are not dead. While storage may be increasing in capacity and decreasing in cost, there is still considerable need for decisions to be made around what comes into the Archive and what does not. An RRS can help provide a framework for this decision making process.
• Identify when things can be deleted – People want permission to be able to delete their digital content. Similar to paper and other physical based records, there is little incentive to get rid of things until one runs out of space. With electronic records, it is not uncommon to purchase more storage instead of deleting unnecessary files. However, digital clutter is a real thing that can induce stress and anxiety as well as make retrievability challenging. Having an RRS can help reduce digital clutter by identifying what records can be deleted and when.
• Assist archive in preservation planning – Once an RRS has been created, it can be a helpful tool in planning for the specific preservation needs of the categories of records coming into the Archive. With the assistance of an RSS, you can think through file-format identification and decisions around normalization, requirements around minimum associated metadata, and estimations of how much information will be needed to be transferred into the Archive and thus how much space will be required.

Records management may be different than archives management but when there is no Records Manager, the responsibility often falls on the Archivist. While records management is concerned with all information created, not exclusively information that has archival significance, it can be useful for the Archive to have a comprehensive picture of work that is being done across the institution. Having a wide-ranging understanding of workflows will only strengthen decisions around selection of what needs to come into the Archive.

So how do you begin? Here are some tips on developing an RRS based off of my experience at BAM.

1. Work with IT. While the creation of an RRS does not necessarily require the technical expertise or someone with an information technology background, the eventual transfer of materials into the Archive and the management of an electronic repository will take some technical know-how. Collaborating with IT at an early stage will only improve relations down the road. If you don’t have an IT Department, it is okay! The Archivist often wears many hats.
2. Talk to as many staff members as possible! Those who create records are the experts in the records they are creating. Trust their words and do not aim to alter their workflows. Work with them! Conduct an interview with a general framework, not a strict roadmap. Give people space to speak and guide them when necessary. Consider this interview outline:
1. Walk through the general responsibilities of your department with an emphasis on what kinds of records or information is being created.
1. Who creates record(s)?
2. How it is created? Specific software?
3. What format is it?
4. How is it identified (filename/folder)? Standard naming conventions?
5. Are there multiple copies? Multiple versions? How are finals identified?
6. Where is it stored?
7. How long is it used/accessed/relevant to your department?

2. What is the historical significance/long-term research value in information created by your department?

3. Make people feel comfortable and not embarrassed. The Archive asking about records can have an intimidating feel. Few people are as organized as they would like to be. These interviews should not be about shaming people but are an opportunity to listen and identify issues across your institution.
4. To record or not to record? To transcribe or not to transcribe? Think carefully about the decision to audio or video record these interviews. You want your interviewee to feel comfortable and you also want to be able to refer back to things you may have missed. Transcribing interviews can be helpful but it takes a considerable effort. Consider the amount of time and resources that are available to you.
5. Determine a format for your RRS. Consider making a spreadsheet with the column headings from Example 1.
6. Develop Record Series Titles based off of workflows present within the department. To encourage compliance to an RRS, it is recommended to have the categories be as reflective of workflows within your institution as possible. If you think of it as a map or a crosswalk, developing an RRS to mirror record types and folder structures currently being used will only make things easier. Directly referencing language used by departments within the Records Series Title or Description will facilitate the process of compliance.
7. Determine retention periods and whether or not records should be transferred to the Archive. Use this decision tree to help establish appropriate time periods.
8. Get legal advice. For record series with legal considerations, consult your legal department. If there is no legal department, look at existing records retention schedules and at your local legal requirements. Here are some useful resources:
   1. New York State Archives Retention and Disposition Schedule for Government Based Records – Includes useful justifications of all retention categories.
   2. IRS – How Long Should I Keep Records? – Guidance on financial based records.
   3. Society for Human Resource Management’s Federal Records Retention Requirements – Legal guidance on retention periods for HR based records.

   It is always best to look up the underlying laws cited in example RRSs to confirm applicable interpretation.

9. To help mitigate duplication, consider limiting records transferred to the Archive exclusively to the creating department. In other words, for information shared across departments or created collaboratively across departments, consider getting the department that holds the final version to transfer the record to the Archive, as opposed to all departments that have a copy.
10. Make a note of information that is required to be transferred to the Archive but is stored in databases or other systems used by your institution. If any information that is required to be transferred into the Archive is stored on removable media or third party proprietary systems, make sure these are flagged and a specific archival ingest process is developed for these records.
11. Appoint a departmental records coordinator and require yearly approval. Designating responsibility to a specific person will dissuade finger pointing. If every department has a specific records retention coordinator, there will be a person with whom the Archives can communicate with, thus improving likelihood of compliance. It is important to make sure that the RRS is reviewed annually to ensure that it continues to reflect current workflows and practices.

Writing an RRS is big step; however, it is only the beginning. At BAM, now that we have completed revisions on our RRS, we are working on developing workflows for transferring materials into the Archive.

Using TreeSize Pro, we have scanned the network storage systems of all departments and have estimated the amount of data that will need to be brought into the Archives based off of the RRS.

We are now working to establish timelines and requirements for when and how departments should transfer materials to the Archive. Presently, we are testing AVPS’s Exactly file delivery tool as a way to receive files and require minimum metadata associated with deposits. Follow the NDSR-NY blog for updates on this phase of the project as it continues to unfold.