Guidelines for the Management of Electronic Information
Scheduling Electronic Records
Why must electronic records be scheduled?
Are there benefits to the agency in preparing schedules covering their electronic data?
Electronic information falls under the statutory definition of "records." (See Background Information) Therefore, a formal Records Retention/Disposition Authorization (RDA), or records schedule, must be prepared and approved prior to disposal of the information. Apart from fulfilling statutory records scheduling requirements, there are other benefits to the agency. Approved schedules offer a mechanism for:
- routine recycling of storage media
- insuring accessibility and utility of specific electronic data for appropriate periods of time
- preventing unauthorized disposition of data
- assisting agencies in establishing policies for insuring that routine data is erased promptly and
- protecting data of long term or permanent value.
Not only is information one of the most valuable resources of any government agency, but it is also being created at an ever-accelerating pace. Through the appraisal and scheduling processes, agencies have an opportunity to assess the efficiency of their information systems, analyze costs, and determine what techniques might improve them. Appraisal is the process of evaluating the worth of a given set of records, manual or automated. This process takes into consideration every facet of a record, e.g., purpose, creating body, content, duplication, physical characteristics.
State agencies also have an obligation to insure that the public interest is served in the management of information resources. Many electronic data files developed to assist in making policy decisions will have ongoing significance to the State and its citizens. Various public issues such as health care, air and water quality, transportation to name a few will be of ongoing significance to everyone. The data files concerning these important issues need to be properly identified and cared for, so that information for future decision making is available.
Is there a general schedule that covers electronic information?
No. As part of a grant project conducted by the State Archives, a general schedule for machine readable records was prepared and approved by the Public Records Board in 1981. For a variety of reasons, the schedule was not uniformly implemented. It sunset in 1991, and no plans exist to revise it at this time.
Who is responsible for the management of electronic information in state government?
Information technology should increase everyone's awareness of the need for adequate programs to manage electronic information. It is therefore important that all state employees who have access to or input into any type of electronic information system understand the responsibility that they have to maintain and preserve the records in the system. All offices should have basic data management procedures incorporated into daily operating procedures. Each state office should consider the need for a staff person to serve as data coordinator responsible for monitoring all data files for the office.
In the management of electronic information, a cooperative and coordinated approach is required. Automated information systems development normally requires the involvement of at least the primary user, program manager, and data processing or information technology staff. Records managers and archivists should be consulted during systems development. They can provide valuable input in terms of data duplication, alternative storage media, and long-term implications. It is imperative that all these individuals be involved in determining the retention and disposition of data in the system.
It is the responsibility of the agency head to insure that all statutory requirements regarding the management of information are met by his/her agency. This includes providing sufficient staff and resources to schedule all the information created and/or maintained by the agency. S. 15.04(1)(i) and (j) requires agency heads to establish and maintain a records management program and appoint a records and forms officer.
The program manager must recognize the importance of information to the operation of his/her program and provide for its appropriate management. The program manager must take into account that electronic records are subject to the same requirements of public access, records scheduling, audits, accuracy and authenticity as paper documents.
The program manager plays a significant role in communicating records requirements to his/her staff. Today's decentralized information technology environment means that program staff have greater capabilities to access and manipulate information. Therefore, all staff should be aware of the impact of technology and public records laws. The program manager should have an overview of all information systems needed to carry out his/her program functions, insure that procedures are in place for the routine evaluation of systems, provide adequate protection for the program's information resources, and insure that all program information is scheduled for retention and disposition. This includes informing program staff of records requirements and involving the agency records officer in the development of new or revised information systems.
Information Technology Specialists
Some agencies have personnel with assigned responsibility for various aspects of information technology. Technology specialists have a valuable role to play in insuring that data procedures routinely include provisions for adequate backup and security of the information in each information system. These individuals need to coordinate efforts with others responsible for the retention and disposition of data in the system. They provide a valuable communication link to the information user, and they should also assist in providing the records officer with the details of a particular information system and its storage capabilities.
Public Records and Forms Board
It is the responsibility of the Public Records and Forms Board to insure that agencies comply with requirements for developing schedules (Records Retention/Disposition Authorizations or RDAs) for public records. The Board reviews RDAs that agencies submit and assures that recommended retention periods meet requirements for administrative, fiscal, legal and historical records values. Board members establish certain policies for recordkeeping for the state, and Board staff provide technical assistance and records analysis expertise to agencies upon request.
It is the responsibility of the statutorily designated records officer to insure that an in-depth records analysis and appraisal of the information is conducted; that all potential records values (legal, audit, administrative, permanent, and historical) are taken into consideration; and that the conclusions of the appraisal process are incorporated into a records retention and disposition policy covering the information. As part of this process, the records officer needs to be sure that all appropriate personnel in the agency are contacted, i.e. technology specialists, program managers, records creators, and legal counsel. As noted previously, retention and disposition determinations regarding electronic records require the coordinated efforts of everyone involved in the information system.
The records officer should work with agency information technology staff to raise records management issues during the early stages of system development such as: data migration, data integrity, data duplication, backup procedures and data retention decisions. Particularly in large, complex information systems, it is advantageous to establish retention and disposition provisions during the design phase. By incorporating a records management perspective in the design phase of information systems, the records officer can play a valuable role in information resource planning for his/her agency.
Archivists have special expertise in records appraisal and records preservation. In Wisconsin, archival services are provided by the State Archives, State Historical Society, for all of State government except the University of Wisconsin System. Many of the campuses in the UW System have their own archives programs and professional staff. It is the archivist's responsibility to insure that the small percentage of historically-valuable public records are preserved and made accessible. These records serve as the State's collective memory and will be used future generations of Wisconsin citizens and researchers. Rapid developments in information technology and the fragile nature of electronic media make it imperative that historical data be explicitly identified and addressed in the design of information and data processing systems. In order for Wisconsin to continue its tradition of preserving important information resources for future use, the archivist's perspective is needed.
The State Archives also provides state agencies and local units of government with records scheduling assistance and expertise concerning historical records. Archives staff offers assistance and training to help agencies judge records values.
What is the basic concept regarding the scheduling of electronic information?
How does the systems approach facilitate records appraisal?
In the electronic environment, it is advantageous for the agency to consider records issues as systems are developed. The systems approach addresses records issues in relationship to each other and tracks information flow within an agency. This approach facilitates records appraisal and provides the opportunity for the agency to review its records keeping processes. Further, a systems approach to scheduling electronic records insures that all component parts of an information system are considered during the analysis and appraisal process. The goal is to develop a records retention schedule that is comprehensive.
Collect the following information about a particular electronic information system
Obtain an overview of the system including a statement regarding its purpose and objectives. A description of the system may be available in your agency's information technology (data processing) strategic plan and/or annual reports. Is the system managed by computer programs developed by in house staff or is the system run by a purchased software package? Has the software package been customized? Who maintains the documentation for the system?
Chart the flow of information through the system, noting system input, processing, and output. Ask the following types of records analysis and appraisal questions:
What input documents are needed and how long should they be retained? Are input documents needed for legal or audit purposes? Is the input electronically transferred?
What happens during the processing of the input? Are additional hard copy or electronic data used to process the input? Are there preset tables or logs in the computer that are used in processing the information? Are interim modifications made to the central data file? Are interim transactional reports issued?
What are the outputs from the information system? In what media are they distributed? If multiple copies of a report are needed, in what medium are they distributed? What happens to all the copies? (Some systems do not issue reports, but modifications made to the data in the system are reflected in system backup tapes.)
Describe contents of database(s) or data sets
How is the information in the system structured? Is it a flat file? A relational database? A hierarchical database? Identify some of the major data elements.
Determine through analysis and appraisal what parts of the system should be retained and for how long. How long should the input documents be retained? Do the input documents or tape have any audit or legal value once the information has been entered into the data system? Is it sufficient to retain summary reports and in what format and media?
Consider the following types of data retention, retrieval and documentation issues:
- What are the oldest data that need to be kept on-line? When can data be written to off-line storage (magnetic tape, floppy disks, other Imaging media)? How long do they need to be retained? Has agency staff created purge criteria? As noted on page , when agencies set purge criteria, they are establishing retention and disposition policies which must be approved by the Public Records and Forms Board.
- What are the backup and library maintenance policies of the administrative data processing unit responsible for the particular application? What are their data recovery policies? Will additional programming be required to restore data after a given period of time?
- Who maintains the system program documentation? Is it regularly updated to reflect changes to the system?
Records retention decisions are based on the informational content of the records. The selection of appropriate storage media should be made after appraisal. Decide what medium is most appropriate to accomplish the retention objectives. There may be specific advantages to retaining information in its electronic form. Storing information in electronic form makes it easier to access and manipulate and thus may make it more useful than paper to future researchers. Therefore, the retention and disposition of information in electronic form may differ from the retention and disposition of the same information maintained on paper or other media. However, keep in mind the life of the media and retention of the information need to be addressed.
How should the records schedule or Records Retention Disposition Authorization (RDA) be prepared and reported to the Public Records and Forms Board?
Since its inception, the Public Records and Forms Board has prescribed methods and formats for scheduling records. The formats for scheduling records are simply tools to facilitate the records scheduling process and insure that agencies and the Board identify the records series clearly. The Board encourages agencies to explore varied methods of developing schedules covering all components of electronic recordkeeping systems. Agencies may use any method that achieves the desired end and provides basic identifying information about the records series.
Four suggested records scheduling methodologies are discussed here. From a systems perspective or from the standpoint of implementation, there may be other ways to proceed to complete the statutory records scheduling requirement.
The Public Records and Forms Board (PRFB) requires certain base information in all cases. Information needed: identification of agency and office, records schedule number for each records series or file group, specification of retention and disposition requirements for each, description of records series or data set or group of data elements being scheduled, whether information is confidential or not (if yes, statutory citation for confidentiality status must be noted on form), whether series contains personally identifiable information, signature of program manager or director, signature of the agency records officer, and date.
In reporting the records schedule to the PRFB, agencies may use the existing PRFB-1 form. However, if agency staff use this form, they will need to complete several PRFB-1 forms describing various components of the information system and submit them to the PRFB at one time.
General Records Schedule Format
In developing schedules by the functional general scheduling method, agencies schedule all records and information related to a particular subject or function at one time, regardless of location or media. Schedules should identify all related information in all locations throughout the organization and in all media. They should identify official copies of records and duplicate copies. The benefits of using this method include: better appraisal, less duplication and better media decisions. The general schedule format also reduces the number of individual records schedules that need to be processed for a given information system and reduces the necessity to rewrite records schedules.
The format of a general schedule can vary, but the most logical to follow and implement is functionally-based. For example, establishing a general schedule to cover personnel operations might include sections on: recruitment, hiring, employee evaluation, grievances or complaints, and employee retirement or termination. For each functional area, retention and disposition requirements should be spelled out for various inputs, processing, database(s), and outputs for each component of the function.
This method provides the most comprehensive method for completing the scheduling requirement, and it may apply to schedules covering state, agency or unit-wide functions. The following general records schedules might serve as format models for this scheduling method:
- Fiscal and Accounting General Records Retention/Disposition Authorization (RDA).
- Purchasing and Procurement General Records Retention/Disposition Authorization (RDA)
- Retention and Disposition Policy: Personnel and Payroll Records, University of Wisconsin-Madison.
- Wisconsin Records Retention Schedule for School Districts
Copies of approved general schedules which incorporate electronic media are available from the Department of Administration Records Management Section.
Included with this document is a pilot records schedule, RDA, form. It is also based upon the systems approach and tracks the development of the information system from input to output. The form is an expanded version of the current RDA. Particularly in small systems, it may be impractical to review and set retention periods for each specific document in an automated system. This form allows items to be grouped around system components of input, processing, electronic data file generation and output for scheduling purposes.
The information system will have one RDA Number assigned to it, and each component will have a suffix to identify it separately.
A separate instruction sheet is attached to the form to aid in the completion of the form.
Other Alternative Formats
The Public Records and Forms Board is open to other alternatives for the scheduling of electronic information. For example, it may be possible and advisable to include retention and disposition policies in system documentation procedures. These procedures could then be forwarded to the PRFB for formal approval. Agency personnel should contact the DOA-Records Management Section for advice on the appropriateness of suggested formats.
Other Considerations in Developing Retention Plans for Automated Information Systems
The records scheduling process is also an occasion for offices to consider the best formats and storage media for the retention of information. What follows is a list of factors that should be addressed.
It is imperative that agencies schedule their computer program documentation, job logs, JCL's and information that is critical to maintaining systems and retrieving information from them. Documentation includes both paper descriptions of the system and its parameters and computer instructions, data dictionaries and customized programs.
Ease of use
Some storage media are easier than others to handle, read, and act upon.
Program offices can reduce office and storage space requirements by storing voluminous records in electronic formats, on microforms, or in optical imaging systems.
Activity refers to the frequency of retrievals of records. If a set of records is needed by multiple users simultaneously, retrieval is improved by having the information available in electronic form or by having automated indexes available to system users.
Distribution of documents in electronic form can be a cost effective alternative to disseminating large volumes of paper records. Critical factors include the number of copies distributed, the importance of rapid dissemination, and the technological capacity of recipients to handle electronic documents.
Documents are generally authenticated with stamps and signatures. Not all documents require authentication. If a signature is required to meet legal, audit or other purposes, a signed paper copy should be created and maintained. If electronic records are requested for a court proceeding, the agency increases the likelihood that records will be legally admissible by demonstrating that department-wide or agency-wide policies and procedures exist for the management of electronic information.
The success of any information system depends upon the acceptance of staff who must use the system. If the system is perceived as ineffective in meeting office needs, cumbersome to use, or if it does not address the factors outlined above, it will fail. An office will want to be certain that an automated system will meet its stated objectives prior to abandoning an existing manual system.
Next section / Previous Section / Table of Contents