Records Management Frequently Asked Questions
The Governance Office has produced the following Frequently Asked Questions in order to help staff with records management matters.
- What is a record?
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All documents, spreadsheets, databases, presentations, images, sound recordings and so on that staff create, update or refer to in the course of carrying out their contractual duties at the University are records. Records can be in both paper and electronic formats.
Example: While quite different in their function and format, all of the following are records: the minutes of a meeting documenting decisions; an invoice requiring payment; an email approving expenditure; a letter of complaint, a regularly updated database of student information; a formal research grant application; a legal contract; a spreadsheet of external contacts; a podcast of a lecture; a photograph taken at a graduation ceremony for use in promotional materials.
- What is a master record and who holds it?
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A master record is the definitive copy of a record held by the 'records owner'. The records owner is the individual who either created the master record or is formally responsible for the master record as part of their contractual duties. Usually it is straightforward to identify the records owner for a particular record. If you are unsure about whether you hold the master record, you may have to make some investigations amongst colleagues and your line manager to find out if the copy you hold is the definitive master record and therefore that you are the records owner for these purposes. If you are still in doubt having exhausted this process, please contact the Governance Office for advice.
Example: The records owner of an official University policy is its author (rather than the committee that formally approved it). If the policy author leaves the University or moves into a new role, ownership of the master record copy of the policy will pass to the member of staff who takes over their contractual duties or, if there is no direct replacement, to their line manager.
- How many copies are there of a master record?
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There is only one master record within the entire University, meaning that in your School or Division you may in fact hold a duplicate copy of the master record rather than the master record itself.
Example: Staff working in the Schools might create their own informal guidance concerning the admissions criteria for their degree programmes. However, the formal record of such criteria, and therefore the only master record for these purposes, is held within the central Admissions Office.
- Does a master record have to be in any particular medium or format?
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A master record could be a letter, a document, an email, a spreadsheet, a database - indeed, pretty much any format in which information can be held. However, where identical electronic and paper copies of a record exist, the default position is that the paper copy is deemed to be the master record. One exception to this is entries and reports printed out from the central University database - in such cases, the database itself remains the master record and any printed matter derived from it is taken to be a duplicate record.
Example: A committee Secretary will normally hold both paper and electronic versions of the committee's papers but only the paper version as maintained in the official committee file is the master record.
- Are all records master records?
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No. As well as master records, there are duplicate records and transitory records. Duplicate records are copies of the master record held by anyone other than the records owner - these should be destroyed once they are no longer required.
Example: A committee member who receives the minutes of meetings holds a duplicate record rather than the master record. They should retain the minutes while required, for instance to enable them to correctly fulfil any follow-up actions, after which the document should be destroyed. Copies of minutes will remain accessible for reference purposes on Sussex Direct or through the relevant committee Secretary.
Transitory records, meanwhile, are records of purely ephemeral value which do need not be retained for any particular period and should be destroyed periodically to keep offices and computer servers free of unnecessary and redundant material.
Example: A draft letter annotated with minor suggestions and typographical corrections is a transitory record and may be destroyed as soon as the changes have been incorporated into the final version. Similarly, an email received solely for information is a transitory record and should be deleted once the information is no longer of use.
- How should I store my records securely?
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Secure storage of records is especially important if they contain sensitive material, such as commercially confidential information, the personal data of individuals, legally privileged communications, or valuable financial statistics. This applies equally to master, duplicate and transitory records - a letter containing confidential information is still confidential even if you only have a duplicate copy. One of the simplest ways in which to securely store your electronic records is to never reveal your IT Services password to anyone else. It is also good to get in the habit of 'locking' your computer when absent from your desk for any length of time. For paper records, secure storage involves keeping documents in a room that is locked when empty, or even in lockable furniture such as a filing cabinet. For sensitive electronic records you should consider the use of encryption or password protection. Further advice on information security, including how to minimise the threat of breaches and guidance on the University's formal policies in this area, is available on the Information Security webpages.
Example: A paper file containing an individual student's personal information should be stored within an office that is locked when empty. If the file contains the personal information of roughly 1,000 or more different students then the security risks and implications surrounding its loss or theft are much more serious. In such circumstances, wherever possible the file should be stored within locked furniture as well.
- What is the Master Records Retention Schedule?
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The Master Records Retention Schedule sets out the periods for which records owners should retain copies of master records within their School or Professional Services Division. It also informs records owners about what to do with the master records once that retention period has run out. It is important to remember that the retention periods listed in the Schedule relate solely to master records. Duplicate records need not be retained for as long as the master record and staff should actively endeavour to destroy them when no longer in use. Transitory records, precisely because they are of temporary interest, do not appear in the Schedule at all and therefore should be destroyed whenever appropriate.
- How is the Master Records Retention Schedule arranged?
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The Schedule is principally modelled around the University's functions and systems rather than its organisational units. While it is split into sections often named after the different Professional Services Divisions, it is important to note that some master records may not physically be held or maintained by the Division in whose section they appear.
Example: Some master records relating to teaching, such as course handbooks or reading lists, will be maintained by School Offices and/or individual members of academic staff rather than the central Academic Office. Similarly, master record copies ofdata gathered in the course of a research project will be held by the Principal Investigator rather than by Professional Services colleagues in the Research and Enterprise Services Division.
- Are there any circumstances in which the retention period listed in the Master Records Retention Schedule should be extended?
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The retention period given in the Schedule is the formal University policy for the retention of the master record. All periods are based on national guidance and sector best practice and have been developed in consultation with managers across the University. There are, however, some circumstances in which staff are justified in keeping their master records for periods longer than those listed in the Schedule. In such cases, staff should label their master records with an appropriate date for future destruction.
Example: Where the master record needs to be kept for a certain period as the result of a binding contract, for example a research grant entered into by a member of staff on behalf of the University, it should be retained in accordance with those contractual terms. Similarly, if an audit investigation or court case is ongoing it is sensible to keep any master records for a certain number of years after the conclusion of the relevant formal processes (the precise length of the extension will depend on the circumstances of any individual investigation or case). There may be occasions where ongoing business requirements dictate that master records should be kept for longer than the period listed in the Schedule, though such decisions should be taken by a senior manager in most instances. Finally, some Schools or Professional Services Divisions may hold specialist records that need to be retained for longer than the period stated in the Schedule due to an external regulatory requirement - in such cases, the external requirement should always be followed.
- The retention period listed in the Master Records Retention Schedule seems rather vague - how do I decide how long to keep the records for?
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The majority of retention periods given in the Schedule are based on a straightforward timescale. However, for some sorts of master record it is more appropriate to grant the maximum possible flexibility to staff to make decisions depending on local circumstances or the particular case in hand. Usually the best course of action where a particular retention period appears vague is to ask for advice amongst your colleagues and, if appropriate, the relevant central Professional Services office. The Governance Office is usually able to comment on the 'theoretical' records management position, but this may not be the most appropriate course of action in all situations.
Example: The Schedule states that master copies of Examination Board papers and minutes should be retained 'While necessary for reference purposes'. This is because there are some areas of the University where vital information (such as student marks for individual courses) is only held within the relevant Examination Board minutes - it has not been transferred onto the database as part of the student's core electronic record for permanent preservation. Advice may be sought from the Student Systems Office on a School-by-School basis.
- Some records I'm sorting through don't seem to be mentioned in the Master Records Retention Schedule - what should I do?
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Your records could be classed as transitory, meaning that they are of purely ephemeral value and therefore need not be retained for any particular period once you have finished using them. Alternatively, it could be that your records are indeed master records but are featured in the Schedule under a slightly different or broader description. Try searching using similar or related terms (the 'Find' field at the top of the pdf is useful for this). Once you have carried out all sensible searches and sought advice locally, please contact the Governance Office if you still think that your records do not appear in the Schedule.
- I'm sorting through some paper files containing master records which I see should be retained in my School or Division for now but require destruction in the future - what practical measures should I take?
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Wherever possible, you should clearly label the files with their contents and the dates when they are due to be destroyed. The file, or box of files, should then be retained within your School or Division until the destruction date when it should be shredded or placed into confidential waste sacks. Labelling files while you are fully aware of what's contained in them will save a lot of time and effort in the future.
Example: If the Master Records Retention Schedule indicates that a particular type of file should be kept until 'End of current academic year + 3 years', you should first calculate the relevant destruction date. If the file relates to the academic year 2009/10, for instance, it would be due for destruction three years after the summer 2010 year-end, i.e. in summer 2013. You should label the file accordingly and store it somewhere within your School or Division until the date for its destruction is reached.
- I'm sorting through some electronic folders containing master records which I see should be retained in my School or Division for now but require destruction in the future - what practical measures should I take?
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The practical steps surrounding the fixed-term retention of electronic master records should mirror those used for paper records. You should create wherever possible an electronic folder which is clearly labelled with the contents and a future deletion date. Any such folders should be placed within shared drives so that future colleagues can perform the deletion in case you have changed roles or responsibilities by the deletion date and are no longer the records owner. As a general point of good practice, try to get in the habit of sub-dividing your electronic folders by date as well as contents to make sorting your records as simple as possible in the future.
- I see from the Master Records Retention Schedule that I should destroy my electronic master records - how do I do this?
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When you simply delete an electronic file in the normal way, it may remain accessible for a set period from backup tapes maintained by IT Services. However, these tapes are created for business continuity purposes to enable the emergency retrieval of accidentally deleted material and are not deemed to be active records. Therefore electronic copies of master records (and indeed duplicate and transitory records) are considered to be 'destroyed' when the records owner performs the deletion.
- I see from the Master Records Retention Schedule that I should send my electronic master records to the University Archives - how do I do this?
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The University is currently investigating the introduction of an electronic archiving system for its institutional master records. In the meantime, where possible and sensible you should create paper copies for transfer to the University of Sussex Collection in the Library following the archiving procedures set out on page 5 of the Master Records Retention Schedule. Where this is not possible (for instance because it would result in an unnecessarily large quantity of printing), you should retain electronic master records in a separate and clearly labelled folder amongst your own files pending the introduction of the University-wide electronic archiving system.
Example: A five-page policy document which is normally maintained as a master record in electronic format may simply be printed out and transferred to the University of Sussex Collection in the Library for permanent preservation in paper format. However, it would not be an efficient use of time or resources to print out a database with hundreds or thousands of master record entries in order to send it in hard copy to the University Archives - in these circumstances the creation of a separate and clearly labelled folder would clearly be a more sensible option.
- Why should I bother to spend time sorting and clearing out my records?
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Good records management is necessary for a variety of reasons which are detailed in section 2.2 of the Records Management Policy. Many of these relate to legislative requirements to either keep or destroy various classes of master record at certain times and the Master Records Retention Schedule has all of these built in.
Example: The University needs to keep certain types of financial paperwork and other records for a fixed period as set out in the Limitation Act 1980 in order to be able to defend itself against any future act of litigation. Once that period expires, the paperwork legally need not be held and may be destroyed. Conversely, the Data Protection Act 1998 states that the personal data of individuals should not be retained for any longer than necessary and therefore the Schedule has been designed to ensure that the University does not needlessly keep personal information when it is no longer required.
Where there is no strict legal requirement, the retention periods in the Schedule have been developed by the Governance Office in accordance with national guidance and sector best practice as well as consultation with managers across the University. These periods should be adhered to as closely as possible because records and information are one of the University's most important resources and it is vital to ensure consistent practice across the institution. In addition, ensuring that you spend a little time to sort, archive and destroy your own records should prove hugely beneficial by streamlining your working environment and ensuring that redundant material is not left to clutter up offices and electronic file space. You should find that you have the correct information available whenever necessary, that it is kept for as long as required, and that it is destroyed when no longer of use.
- Is there any particular time I should set aside to clear out my old papers and electronic file space?
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Ideally, records management should become part of your School's or Division's day-to-day working environment. Where this is not possible, you may find that a scheduled termly or annual exercise of sorting and clearing out old records helps to keep your office and electronic file space in good order. In summer 2010, the Governance Office organiseda Records Management Week in which staff were encouraged to spend some time sorting and assessing their old records and destroying what is no longer required, either because it is a transitory or a duplicate record of no further use or because it is a master record which should no longer be retained (or should be transferred to the University Archives) under the terms of the Master Records Retention Schedule. Feedback was generally positive about this initiative and another Records Management Week is planned for 2011.
- How should I handle my emails?
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Emails created for the purpose of University business should be considered as a formal means of communication, just like a letter on headed University paper, and therefore as potentially important master records. There is no reason to handle emails in a different manner to other electronic or paper records - depending on their content, some emails will be transitory records of no long-term value, some will be duplicate records solely for your own short-to-medium-term use and information, while others will be master records which you, as the records owner, should maintain in accordance with the Master Records Retention Schedule. Some Schools or Divisions might already have processes in place whereby emails of significant importance are printed out and placed on a paper file. This practice is quite acceptable and, in such cases, the paper printout should be deemed the official master record and the email itself merely a duplicate. The University's Communications Division has produced some general Guidance on the Use of Email.
- How should entries within databases be handled in terms of records keeping?
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The central University database managed by Business Information Systems is controlled using certain protocols and staff should not attempt to delete individual entries based on the Master Records Retention Schedule. However, locally-maintained databases (such as those created in MS Access or large Excel sheets) should, as far as possible, be regularly weeded to delete old entries in accordance with the Schedule.
Example: A log of low-level complaints is maintained in an Access database by a Professional Services Division. The appropriate retention period for master records relating to such complaints is set out in the Schedule and the records owner should weed their database accordingly, just as they would destroy paper and electronic master records relating to those complaints at the conclusion of the retention period listed.
- I'm a committee Secretary - what should I do with the agendas, papers and minutes of meetings?
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Committee papers are an essential record of the University's business as they detail the planning, approval and implementation of its strategies, policies, and procedures - both academic and non-academic. Committee Secretaries are responsible for maintaining the master record copies of committee agendas, papers and minutes. These should be retained by the Secretary until the retention period has elapsed as listed in the 'Governance' section of the Master Records Retention Schedule. Thereafter, please refer to the Master Records Retention Schedule for guidance on what to do with your specific committee's papers.
Example: Committee agendas, papers and minutes of the University's Statutory Bodies and most other University-wide committees should be transferred to the University of Sussex Collection in the Library where they will be kept in perpetuity as an enduring record of the University's conduct. However, for some committees, such as Student Disciplinary or Academic Misconduct Panels, this would be both inappropriate and unnecessary and the formal report of the Panel's decision and any supporting papers should be destroyed six years after the closure of the case.
- How is a student's main paper file handled?
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A student's paper file typically starts out in the Admissions Office before being sent to the relevant School Office just before the student arrives. It should be returned to the Student Systems Office in the Central Administration upon graduation or departure, where it will be kept for a further six years before being confidentially destroyed. The student's core electronic record is kept in perpetuity for the purposes of confirming attendance and generating transcripts on request.
- What should I do with students' coursework and examination scripts?
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All work submitted for assessment towards undergraduate or taught postgraduate degree programmes should be retained in Schools for one year after the student has graduated (to allow for any appeals procedures and so on to be concluded) before being confidentially destroyed. Such work includes examination scripts, submitted essays or projects, undergraduate dissertations and Masters-level theses. For some degree programmes, especially those where external professional accreditation is necessary, there may be a requirement imposed by the accrediting body to keep some or all of the students' work for a longer period. Theses submitted for research degrees (MPhil, PhD, etc.) are handled a little differently. Students working towards a research degree will be given guidance on where they should lodge finished hard and/or electronic copies of their successful thesis. Staff should consult the appropriate regulations and handbooks to read the current guidance (please note that variations from the standard procedure may exist for BSMS and IDS theses).
- My School or Division uses an archive room to store old papers - how does this relate to the 'University Archives' mentioned in the Schedule?
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A distinction needs to be drawn between the everyday use of the word 'archive' and the formal term 'University Archives' that features in the Master Records Retention Schedule. In records management terms, informal 'archives' maintained locally (or even off-site) by Schools or Professional Services Divisions are instead known as collections of 'semi-current records'. This means that they are being stored in order to comply with legal requirements or for reference purposes but are due for destruction at a specified date in the future. For the purposes of the Schedule, then, they do not form part of the formal University Archives and are still being retained within the School or Professional Services Division even if physically they are deposited within an archive room, cupboard or off-site storage facility and only accessed occasionally.
Example: Invoices and related financial records are retained centrally in an archive room in Sussex House for six years from the end of the financial year to which they relate, and then confidentially destroyed. Similarly, legal documents such as contracts or litigation records are kept securely in a central strong-room for a certain number of years after their termination according to the Schedule before being confidentially disposed of. These records may casually be denoted as 'archived' but they do not form part of the formal University Archives because they are not due for permanent preservation.
The term 'University Archives', by contrast, is reserved for master records that are to be retained in perpetuity by the University. There are, in fact, relatively few master records that fall into this category.
Example: Examples of records listed in the Master Records Retention Schedule for transfer to the formal University Archives for permanent preservation include official publications, high-level strategies, agreed policies, and important committee minutes.
- What is the 'Archival Review Process' mentioned in the Master Records Retention Schedule and who carries this out?
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This process involves a professional assessment of those records for which, at the end of their retention period within a School or Professional Services Division, the Schedule does not set out a straightforward action of destruction or permanent archiving. For most classes of master record, it is clear that they should be either destroyed or archived at the end of their normal retention period within the School or Division. For some, though, the long-term value or utility of the records will require consideration by the Governance Office and Special Collections staff from the University Library, with input from the records owner. The process will ensure that any records deemed essential for an ongoing business need are not destroyed too quickly. It is also important that records are kept where they are pertinent to a particularly important development in the life or workings of the institution.
Example: Most committee papers for School-level committees may be destroyed once their retention periods have elapsed. But if a School-level committee has been discussing something especially significant in the long-term (e.g. the introduction of an innovative set of new programmes into the academic portfolio) this might give the papers more lasting value, meaning that they should be retained in perpetuity rather than destroyed. The Archival Review Process enables the University to identify such records and act accordingly.
- I see from the Records Management Policy that the Governance Office oversees records management practices across the University and can conduct spot checks. What does this entail?
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The Governance Office has produced a Procedural Note [PDF 16.93KB] on its general oversight and spot check functions under section 3.3 of the Records Management Policy.
- How should I best arrange and maintain my electronic records and filing systems in order to aid compliance with the Records Management Policy and Master Records Retention Schedule?
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Different Schools and Divisions may already have fixed systems in place to govern the organisation of electronic records and you should make sure that you fit in with these in order to help colleagues locate, use and where necessary destroy any records that they need in the course of their business. Remember that while you may have written the document, spreadsheet or presentation, once created it becomes a University-wide resource and colleagues may need to access or amend it in your absence. If no prevailing organisationalsystems are in place for the School's or Division's electronic records, then you might like to consider organising your files into shared drives wherever appropriate. These should be clearly labelled and arranged according to the type of business being carried out (e.g. committees or examinations or finances) rather than the names of the people who predominantly work on different aspects of the School's or Division's activities. Such labelling should proceedon the basis that someone new to the office could sensibly locatewhat they need so try to avoid acronyms or unusual terminology wherever possible. Once this 'top layer' of folder labelling is complete you could date-order folders containing individual records - this will be highly beneficial when it comes to applying theMaster Records Retention Schedule to the work you actually carry out. There may also be occasions where some folders should be maintained in a confidential way (such as those containing appraisal information or other employment-related records) and for these you could consider password protection or other means of storage. For obvious reasons, try to avoid duplication - if a colleague has a folder containing one type of record, then use that same folder rather than creating a new one for yourself.
- I am a line manager in a School or Division. What should I tell new staff about records management matters?
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Wherever possible, when inducting new staff you should explain to them the importance of good records management and alert them to the provisions of the Records Management Policy and Master Records Retention Schedule, both ofwhich apply to all staff. It is a good idea to highlight in particular the importance of not retaining duplicate records, of maintaining electronic records in a systematic way so that others may understand and access them, and of using the Master Records RetentionSchedule to ensure that those records that do require retention are kept for as long as necessary. Usually a 'records management induction' should form part of any introductory conversations about the work carried out in the School or Division and the processes to be followed. Managers across the University should as far as possiblealso alert existing staff to the institution's records management policies and procedures as individuals may currently be operating outside of these guidelines - team meetings (or equivalent) would be a good opportunity to do this.
- I still need some specific help and guidance - who should I contact?
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The Governance Office is responsible for providing University-wide guidance on records management matters. Please check the Records Management Policy, the Master Records Retention Schedule, and the records and information management pages on the University website (including the questions on this page) to see if your query is answered there. If you are unable to find an answer, please contact the Data Protection Officer (dpo@sussex.ac.uk).
