Last year, our university implemented a new procedure for documenting in-office records destruction. As the one year benchmark approaches, I have been thinking about our organizational approach to documenting records destruction, especially in a decentralized environment.
Procedures for documenting records destruction may depend on state laws, regulations, and institutional polices. For some organizations, declaring that employees are following records policies, including those requiring records destruction, may be enough to adequately “document” the destruction of records. However, our university requires approvals for all records destruction. The mandate for the records management program comes directly from the Board of Trustees and states that it is the responsibility of the Director of the University Archives and Historical Collections to approve the destruction of the “records of the official activities of University officers and offices”.[i]
In the current records environment, this policy has been difficult to enforce. Although records destruction has long been documented by a well-established protocol for records stored with the Archives, many of the records created at the university are never transferred or stored with the Archives; nor are they required to be. Instead, the records are housed with the originating office. Records may be retained in office for a variety of reasons, including lack of knowledge about the university’s records management program, desire to keep control of records, lack of personnel resources needed to pack and transfer records, and the nature of our highly decentralized organizational structure, which lacks a central authority to enforce policy. With a large number of offices containing university records spread out across the institution, actual records destruction has been difficult to document. In fact, until last year, the Archives did not have a consistent method in place to document in-office records destruction. Still, regardless of the location of the records, both the Director of the University Archives and the appropriate department representative are responsible for signing off on all records destruction.
To address this issue, a procedure was implemented in April 2015 to document in-office records destruction using a new form. This In-Office Records Destruction (IORD) form was designed to be a simple, easy-to-use method to document what records the office intends to destroy, regardless of whether they are in paper or electronic format. The IORD form is then signed by both an office representative and the Director of the Archives, which gives the office approval to destroy the records.
This new destruction procedure is a good way to strengthen the foundation of the records management program while working within the university’s decentralized administrative environment. When the form was designed, it was clearly stated that the primary goal was to facilitate and document records destruction, not impede it. It was important for the Archives to develop a workable solution that would actually be used by the university community, and end-user adoption of the form has been steady.
For the first year of implementation, during which the IORD form was actively advertised for about six months through both records management classes and the Archives website, use statistics have been better than expected. Because the procedure requires the department or office to initiate the form, it was not expected that departments would instantaneously adopt the form. However, experienced records management users have sought out the form; as a result, in-office destruction of over 130 cubic feet of records has been successfully documented. Additionally, the Archives has seen use of the form increase when it is mentioned as part of other records management outreach activities, including in-person consultations and training sessions. This indicates that there is a use for the form on campus and that employees simply may not be aware of the destruction procedure. Thus, the Archives has additional outreach activities planned for the next year, and the hope is that use of the form will double over the next few years due to increased records management outreach and education.
Records management outreach has been and will be crucial to the success of the IORD form, as this procedure still relies a great deal on the knowledge and actions of the employee. The IORD form requires departments to verify that there is no pending litigation or legal holds affecting the records. The procedure also assumes that employees will follow through with records destruction once the form is signed and returned to them. This means that the Archives must continue to pursue outreach opportunities to better educate the university community on the importance of following records management practices. Despite this concern, the new method of records destruction successfully documents for both the departments and the University Archives that records are being destroyed in compliance with university policy, even if those records are never transferred to the Archives.
It is expected that the destruction procedure will need to be updated in the future. While the IORD form has generally been easy to use for the offices, the Archives does plan to provide further guidance by updating the form’s instructions and filming a short video that can be used to show employees how to complete the form. Additionally, though the form is currently processed in paper format, the design is simple enough that it could be easily converted to an electronic format if the Archives ever decided to move to a paperless records management environment.
No strategy for documenting records destruction is foolproof. However, even in a highly decentralized environment, the new destruction procedure provides the university with a standard method for both documenting records destruction and ensuring that offices are complying with university regulations.
[i] Policy Manual of the Michigan State University Board of Trustees, Policy No. 02-12-01.