Records Management Policy
- Responsible Oversight Executive:ÌýVice President for Administration and Finance
- Date of Current Revision or Creation:ÌýAugust 1, 2019
- Download Policy PDF
The purpose of this policy is to establish responsibilities and requirements for records management.
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, grants authority to the Board of Visitors to make rules and policies concerning the institution. Section 6.01(a)(6) of theÌýBoard of Visitors BylawsÌýgrants authority to the President to implement the policies and procedures of the Board relating to 91¶ÌÊÓƵ operations.
Ìý(, included in the Act), requires state agencies, including universities, to maintain an active and continuing records management program.)
Certificate of DestructionÌý- Also known as an RM-3, the document approving the destruction of records in accordance with Library of Virginia (LVA) Records Retention and Disposition Schedules. A completed RM-3 Form serves as evidence of proper disposal when records are subpoenaed as evidence, audited, or investigated.
Department Records CoordinatorsÌý- Individuals who serve as liaisons between the 91¶ÌÊÓƵ Records Manager and their respective departments.
Historical/Archival RecordsÌý- Records that have long-term historical value as designated by the Library of Virginia, 91¶ÌÊÓƵ Archivist and/or 91¶ÌÊÓƵ Records Manager. Examples of historical records include but are not limited to Board of Visitors meeting minutes, President's correspondence, research final reports and accreditation records. These records cannot be placed in any repository other than the 91¶ÌÊÓƵ Archives.
Records Custody TransferÌý(also known as an ODU RM-1 Form) - The document authorizing transfer of inactive records to an onsite ODU storage facility, a commercial records storage facility, or the 91¶ÌÊÓƵ Archives.
Records Management ProgramÌý- A planned, coordinated set of policies, procedures, and activities needed to manage the 91¶ÌÊÓƵ's recorded information. The program encompasses the creation, distribution and use, maintenance and storage, and disposition of records, regardless of media. Essential elements include issuing up-to-date program policies and standards, properly training individuals responsible for implementation, publicizing the program, and carefully evaluating the results to ensure adequacy, effectiveness, and efficiency.
Records Management Steering CommitteeÌý- Provides overall guidance and direction to the 91¶ÌÊÓƵ's Records Management Program.
Records Retention and Disposition ScheduleÌý- A listing of records series, approved by the Library of Virginia, that provides retention and disposition instructions for 91¶ÌÊÓƵ records.
Reference CopyÌý- Also known as a convenience copy, any copy of an official record created for the purpose of reference or research. If a convenience copy is maintained after the official record has been destroyed, the convenience copy becomes the official record.
Transitory InformationÌý- Records of temporary usefulness that do not document, support, or arise from 91¶ÌÊÓƵ business processes. Examples include departmental social invitations to luncheons, showers, etc., unsolicited advertisements and memoranda of transmittal that add nothing of substance.
91¶ÌÊÓƵ ArchivesÌý- The unit within Special Collections and 91¶ÌÊÓƵ Archives, Perry Library, responsible for the appraisal, preservation of, and access to historical records of Old Dominion 91¶ÌÊÓƵ.
91¶ÌÊÓƵ RecordsÌý- Recorded information that documents a transaction or activity by or with any appointed Board member, officer, or employee of the 91¶ÌÊÓƵ. Regardless of physical form or characteristic, the recorded information is a 91¶ÌÊÓƵ record if it is produced, collected, received or retained in pursuance of law or in connection with the transaction of 91¶ÌÊÓƵ business. The medium upon which such information is recorded has no bearing on the determination of whether the recording is a 91¶ÌÊÓƵ record. 91¶ÌÊÓƵ records include but are not limited to personnel records, student records, academic 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).
91¶ÌÊÓƵ Records ManagerÌý- An official appointed by the Vice President for Administration and Finance who is responsible for providing standards, procedures, training and guidance to meet requirements for the proper management of 91¶ÌÊÓƵ records. This individual is also designated the "Agency Records Officer" for Library of Virginia purposes.
This policy applies to all employees of the 91¶ÌÊÓƵ. Employees include all staff, administrators, faculty, full- or part-time, and classified or non-classified persons who are paid by the 91¶ÌÊÓƵ. This policy does not apply to employees of affiliated organizations who are paid through the 91¶ÌÊÓƵ.
The 91¶ÌÊÓƵ requires that its records be maintained in a consistent and logical manner consistent with applicable law.
The 91¶ÌÊÓƵ's Records Management Program is guided by a set of professional records management standards, best practices, and legal and regulatory requirements and complies with the Virginia Public Records Act.
Records created or received during the normal course of 91¶ÌÊÓƵ business are the property of Old Dominion 91¶ÌÊÓƵ and all employees are responsible for ensuring that records are managed in accordance with the 91¶ÌÊÓƵ Record Management Program and in compliance with applicable Federal and 91¶ÌÊÓƵ laws.
The Records Management Program is administered by the 91¶ÌÊÓƵ Records Manager. The 91¶ÌÊÓƵ Records Manager is assisted by a Records Management Steering Committee consisting of individuals who are primary stakeholders of 91¶ÌÊÓƵ records.
Key components of the 91¶ÌÊÓƵ Records Management Program include:
- Policies and standards that comply with the Virginia Public Records Act and Library of Virginia guidelines.
- Training and awareness opportunities for employees who are responsible for maintaining records in their possession.
- Maintaining 91¶ÌÊÓƵ records so they are accessible throughout their lifecycle.
- Preserving records that are subject to audits or litigation, both potential and pending.
- Disposing of records by appropriate methods in accordance with the Records Retention and Disposition Schedules.
- Transferring records that are inactive by submitting them to Facilities Management, as approved by the Records Manager, for onsite storage or an offsite location approved by the 91¶ÌÊÓƵ Records Manager when they are no longer needed for business use but must be kept until their scheduled retention period expires.
- Transferring records that have historical and archival value by submitting them to Special Collections and 91¶ÌÊÓƵ Archives in Perry Library when they are no longer needed for business use.
- Conducting periodic audits to ensure policies and standards are being met.
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Responsibilities
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Vice President for Administration and Finance
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Appoints the 91¶ÌÊÓƵ Records Manager.
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Appoints the Records Management Steering Committee upon the recommendation of the 91¶ÌÊÓƵ Records Manager.
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Provides necessary support and resources to the 91¶ÌÊÓƵ Records Manager in the development and implementation of the 91¶ÌÊÓƵ's Records Management Program.
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Records Management Steering Committee
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Meets with the 91¶ÌÊÓƵ Records Manager on a regular basis to provide guidance on issues impacting the 91¶ÌÊÓƵ's Records Management Program.
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91¶ÌÊÓƵ Records Manager
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Oversees and directs 91¶ÌÊÓƵ Records Management Program.
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Trains and maintains communication with Department Records Coordinators; develops guidelines, procedures, presentations and tools to assist Department Records Coordinators in their duties.
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Undertakes periodic assessments of departmental records management activities, and reports on the same.
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Authorizes requests for destruction of 91¶ÌÊÓƵ records by approving RM-3 forms.
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Provides approval for all offsite storage locations for university physical records.
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Coordinates with the 91¶ÌÊÓƵ Archivists transfer of historical/archival records to the 91¶ÌÊÓƵ Archives as required by Library of Virginia records retention and disposition schedules.
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Works with appropriate units to ensure that holds on destruction of 91¶ÌÊÓƵ records due to litigation, audit investigation or FOIA requests are observed.
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Advises senior management and Budget Unit Directors on records issues within their departments.
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91¶ÌÊÓƵ Archivist
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Works with Department Records Coordinators on scheduled transfers of historial records to the 91¶ÌÊÓƵ Archives.
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Determines the historical value of select records that ordinarily are scheduled for destruction, but may be of enduring value to the 91¶ÌÊÓƵ and advises departments of the same.
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Department, Academic Unit, School, or Budget Unit Directors (BUDs)
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Appoints one or more Department Records Coordinators for their respective areas and notifies the 91¶ÌÊÓƵ Records Manager when coordinators change.
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Supports the 91¶ÌÊÓƵ Records Manager/Department Records Coordinator in the development and implementation of the Records Management Program within their respective business unit.
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Determines what records they are required to retain in accordance with this policy and the Records Retention and Disposition Schedules.
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Ensures that staff understand their responsibilities and properly manage their records under the Records Management Program.
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Department Records Coordinators
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Serve as an information conduit between the 91¶ÌÊÓƵ Records Manager and their respective departments.
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Meet with individuals and groups to promote awareness of and compliance with the Records Management Program.
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Coordinate the disposal of records within their offices.
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All Employees
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Comply with retention and disposition instructions in the Records Retention and Disposition Schedules approved by the Library of Virginia.
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Store electronic records in accordance with the 91¶ÌÊÓƵ'sÌýÌýand associated standards as well as guidelines from the 91¶ÌÊÓƵ Records Manager for management and authenticity.
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Destroy 91¶ÌÊÓƵ records once the retention period has expired. AÌýÌýshould be submitted and approved by the 91¶ÌÊÓƵ Records Manager as required by the Virginia Public Records Act before destruction. Reference copies and transitory information do not require the submittal of an RM-3 form prior to disposal.
Records with "identifying information" must be disposed of within six months of the expiration of their retention period. Identifying information includes the following categories:
- Social security numbers;
- Driver's license numbers;
- Bank account numbers;
- Credit or debit card numbers;
- Personal identification numbers (PIN);
- Electronic identification codes;
- Automated or electronic signatures or passwords;
- Any other numbers or information that can be used to access a person's financial resources, obtain identification, act as identification, or obtain goods or services.
Information in confidential or privacy-protected records is protected from unauthorized disclosure through the ultimate destruction of the information. Destruction of confidential or privacy-protected paper records will be done by shredding, pulping, or incineration. Electronic records must be overwritten with meaningless data or the storage media must be physically destroyed.
Records containing public information can be recycled or disposed of in the trash.
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Electronic Mail
ODU'sÌýElectronic mail (e-mail) policyÌýis to retain messages only as long as necessary for business purposes, unless they are required to be retained by the Library of Virginia. E-mails are automatically deleted after a specific period unless they are moved to "Managed Folders" that have pre-assigned retention periods. Messages do not require completion of an RM-3 form as deletion and/or preservation is controlled by Information Technology Services. RM-1 forms to transfer records considered to be historical are completed by Departmental Records Coordinators.
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Electronic Images
Hard copy records may be converted to electronic images (preferably TIFF or PDF) as long they are accurate copies of the original records in conformity withÌýITS Standard 11.6.0, 91¶ÌÊÓƵ Source Document Imaging Standard. The electronic image becomes the official document for legal purposes and has the force of the original for audit, legal, FOIA and other related requirements. Destruction of the original hard copy record does not need to be authorized with an RM-3 Form. The 91¶ÌÊÓƵ Records Manager should be consulted before initiating any large conversion effort.
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Historical/Archival 91¶ÌÊÓƵ Records
Records designated with historical/ archival value, as listed in the Records Retention and Disposition Schedules, or determined to be so by the 91¶ÌÊÓƵ Archivist must be transferred to the 91¶ÌÊÓƵ Library's Archive/Special Collections, and accompanied by a completed ODU RM-1 Form.
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Audits, Court Orders, Investigations and Freedom of Information Act Requests
Retain all records requested or placed on hold by internal offices (such as 91¶ÌÊÓƵ Counsel, 91¶ÌÊÓƵ Auditor, 91¶ÌÊÓƵ Registrar, designated FOIA Officer, etc.) until cleared by the office placing the hold, regardless of retention requirements. Offices placing holds or requests for 91¶ÌÊÓƵ records should copy the 91¶ÌÊÓƵ Records Manager on all notices.
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Storage of Regulated or Confidential Information
For electronic records and data in general, ODU follows the requirements ofÌýInformation Technology Services Standard 02.3.0, Data Administration and Classification Standard.
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Affiliated Organizations
While affiliated organizations are not subject to the Virginia Public Records Act, they are strongly advised to follow best practices for records management. Affiliated organizations may use consulting services provided by the 91¶ÌÊÓƵ Records Manager. Affiliated organizations are separate entities that exist for the benefit of the 91¶ÌÊÓƵ and include the Foundations, the Community Development Corporation, and the Alumni Association.
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Certain Federal grant records may be required to be treated as 91¶ÌÊÓƵ records and subject to the Virginia Public Records Act.
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Other records management specific procedures are maintained internally and may be available to relevant parties upon request to the 91¶ÌÊÓƵ Records Manager.
Questions or concerns related to the application of this policy should be directed to the 91¶ÌÊÓƵ Records Manager. The 91¶ÌÊÓƵ Records Manager may consult with the Library of Virginia, as appropriate, to determine application of the records retention schedules to specific 91¶ÌÊÓƵ records.
Applicable records must be retained and then destroyed in accordance with theÌý.
91¶ÌÊÓƵ Records Manager
- Board of Visitors Policy 1424 - Policy on Intellectual Property
- 91¶ÌÊÓƵ Policy 3504 - Data Classification Policy
- 91¶ÌÊÓƵ Policy 3505 - Information Technology Security Policy
- 91¶ÌÊÓƵ Policy 3506 - Electronic Messaging Policy for Official 91¶ÌÊÓƵ Communication
- 91¶ÌÊÓƵ Policy 4100 - Student Record Policy
- Freedom of Information Act (FOIA) - Rights and Responsibilities
- Information Technology Standard 02.3.0 - Data Administration and Classification Standard
- Information Technology Standard 11.6.0 - 91¶ÌÊÓƵ Source Document Imaging Standard
Policy History
Policy Formulation Committee (PFC) & Responsible Officer Approval to Proceed:
/s/ÌýG. Mark Walsh
Responsible Officer
May 28, 2019
Date
Policy Review Committee (PRC) Approval to Proceed:
/s/ÌýDonna W. Meeks
Chair, Policy Review Committee (PRC)
February 26, 2019
Date
Executive Policy Review Committee (EPRC) Approval to Proceed:
/s/ÌýGregory DuBois
Responsible Oversight Executive
July 25, 2019
Date
91¶ÌÊÓƵ Counsel Approval to Proceed:
/s/ÌýR. Earl Nance
91¶ÌÊÓƵ Counsel
July 31, 2019
Date
Presidential Approval:
/s/ÌýJohn R. Broderick
President
August 1, 2019
Date
Previous Revisions: November 7, 1990; August 1, 1991; June 18, 2013; August 1, 2019
Scheduled Review Date: July 31, 2024