Have you ever wondered about the correct retention procedures and policies regarding your organization’s financial records and other documentation? What documents can be disposed of and when? What are best practices regarding record retention? This article will address these questions.
How is a Record Defined?
Per the County Record’s Manual, a record is defined as “any papers, dockets, books, maps photographs, or other documentary materials, regardless of physical form or characteristics, made or received in any office of county government in pursuance of law or in connection with transactions of public business in the exercise of its legitimate functions and the discharge of its responsibilities.” Records can be stored in both paper and/or electronic format. The County Records Manual defines a security preservation file as “a copy of an electronic record that is stored in a secure manner so that it cannot be accessed except by a limited number of authorized users and only when no other copy of the document will suffice.”
What are the Procedures for Record Destruction?
At the County Level….
- Follow the schedules of timelines and procedures listed in the County Records Manual.
- Obtain written consent from the Pennsylvania Historical and Museum Commission (PHMC) for permission to destroy records scheduled for permanent retention or for destroying records not listed in the schedule.
- Notify the PHMC of your intent to keep any permanent records in electronic format
- Maintain a log of individual disposition actions. Disposition actions are each action that destroys a record.
At the Municipal Level…
- Declare your intent to follow the Municipal Records Schedule. This is the schedule that denotes how long each type of record is required to be kept and is included in the Municipal Records Manual.
- Approve each individual act of disposition by resolution of the governing body.
- Also obtain written consent from PHMC in either of the following cases:
-Destruction or transfer of original, permanently valuable records
-Before destroying or transferring records not listed on the schedule or records created prior to 1910
What are Records that Cannot be Destroyed?
- Records subject to audit
-Keep until all audit findings have been resolved if the minimum retention period has passed.
- Records involved in litigation
-Keep until final disposition of the case.
- Federal and state statutes
How Should Permanent Records be Stored and Handled?
Permanent records can be stored in paper, microfilm, or electronic formats. Regardless of the format chosen, the records must be findable, retrievable and able to be rendered. Copies (a security preservation file, a backup copy, and access copy) of all permanent records should be kept on file. Procedures must be in place to ensure that any records that are destroyed are done in a secure and confidential way and in a manner that is irreversible. Governments must also not limit or hinder public access to records. Security measures should be in place to protect network access and physical access to documents. Procedures should also be in place for the protection of Confidential, Sensitive, Personally Identifiable Information (PII). For the preservation of records, procedures should be in place to ensure that records are not compromised during the migration or conversion of software systems and that links to original documents are successfully preserved.
How Should Electronic Records Be Managed?
- For permanently valuable electronic records, a paper copy or archival security microform copy is required to be kept.
-If it meets the definition of a record, it must be maintained.
-Storage in an e-mail messaging system does not meet the retention requirements for Counties.For Counties, e-mail messages that are considered to be permanently valuable can be stored as a paper printout of the message or as an archival security microform copy of the message.
-The Municipal Records Manual does consider storage of e-mail messages in an e-mail messaging system sufficient for record retention requirements.
- Maintain system documentation.
- Provide a means for authorized users to obtain information.
- Provide for the ability to exchange records on electronic media and allow for conversion/migration of files.
- Provide necessary maintenance to ensure usability of records.
- Maintain security of electronic records by:
-Managing proper authorized access.
-Maintaining a system that can be counted on for proper backup and recovery processes.
-Providing a system with safeguards in place to protect sensitive information such as Confidential, Sensitive, Personally Identifiable Information (PII)
-Preventing unauthorized alteration of documents.
-Ensuring the computer system plan has procedures in place for electronic records security
For the selection and maintenance of electronic storage media, it is recommended that:
-Records are stored in such a way that they can be retrieved in a timely and easy fashion.
-Records are stored in a usable format.
-Transferring requirements are documented.
-Backup of data is routinely performed.
-The following areas should be considered for your type/form of storage media:
1. Required retention period of the records
2. Maintenance that will be required on the storage media
3. Costs of storing and retrieving the records
4. Portability of the storage medium (i.e. will it run on equipment produced by different manufacturers) and can the information be migrated from this medium to another when it is outdated?)
How Should Records Placed on Optical Imaging and Data Storage Systems be Retained and Disposed of?
When considering the optical imaging and data storage system that would work best for your organization consider the following:
- Ability to maintain access
- Ensure preservation of records
- Provide for migration of records to other systems if necessary
- Ensure the identification of files is possible
- Ensure that the system can detect and correct errors
To protect the quality of the optical imaging and data storage system you should ensure the following:
- Maintenance on equipment is routinely performed.
- Scanning density is set at a level that records can be clearly viewed.
- Input quality is set to the most optimal image possible.
- Compression settings are set in a way that quality of the readability documents is not compromised.
- An index/directory of files is provided for all stored documents
- Technical documentation on the system is maintained.
- Consider the stability features of the optical media:
-Disk substrate composition (This is the material that comprises the disk and can be any of the following three materials.):
2. Tempered glass
-Protection and climate
Refer to our useful reference guide regarding the duration in years certain financial documentation should be retained:
The preceding article is an abstract from a seminar conducted by Levi Zielinski, CPA, Manager, from the 2017 Maher Duessel Government Update seminar. Please contact the presenter for additional information.