Retention schedules and research records: Necessary challenges

This post is the second in a series on research data management presented by the Records Management Roundtable. 

Submitted on behalf of Anita Vannucci, Records Manager at Emory University.

In the fall of 2015, I began a review and update to the research data portion of my institution’s retention schedule. The catalyst for this work came from a campus task force looking at the evolution of research data at academic institutions and anticipating increased interest following the February 2013 White House Office of Science and Technology Policy memo. One recommendation the task force made was to revise the retention schedule.

The 30 series retention schedule was last updated in 2008, long before my arrival. Several challenges became clear when I started my review. Some series were based on federal statutes that had been repealed, or cited code that had no clear connection to the series. Some “series” were actually record types. For clinical records, a records series existed for each stage of research (Phase I, Phase II, Phase III, Phase IV) rather than a single series based on the point the research closed.

I began researching federal and state code, best practices, and the policies of peer institutions. Federal guidance varied from agency to agency, so many of the institutions I surveyed relied on contract language, rather than a centralized retention schedule, to set requirements.

Another challenge was identifying a focus group of subject matter experts. In fiscal year 2015, my institution received 2,923 sponsored awards. While I spoke to people doing research and managing the information created from it, it was impossible to get a representative sample, so I chose to talk to their central monitoring department, the Office of Compliance. It was Compliance who helped me solidify the information I’d gathered into concrete series based on four types of research: behavioral, treatment, FDA-regulated, and non-FDA regulated. Unfortunately, the retention requirements aren’t as straight forward as that finite group of series would lead you to believe.

I began meeting monthly with the deputy chief compliance officer, working through my draft of the schedule. He provided feedback and insight along the way, while I learned about everything from the differences between dangerous drugs and controlled substances to retention requirements around sealed versus non-sealed sponsored study contracts. In the process, we tackled two major challenges:

  1. Can we create big buckets? Risk analysis is a big part of creating a big bucket schedule. We discussed when keeping information longer than required through a simplified schedule posed a greater risk than the value gained by making the schedule easier to use. For example, alleged misconduct investigations involving federally-funded research must be retained for seven years. There’s more flexibility around privately funded research, so in instances where a complaint is determined to be unfounded, there was a desire to dispose of the information sooner. By keeping misconduct investigations of privately-funded research according to the federally-funded requirements, we’d lose the ability to destroy unfounded complaints and retain spurious or potentially libelous information longer than necessary. We decided to settle this issue on a series-by-series basis after considering the volume of records involved and potential risk for each series.
  2. How simple can we make the retention requirement? Retention periods set out in code are rarely simple. (Take a look at 21 CFR 58.195 if you don’t believe me.) We discussed the value of using those retention periods word-for-word versus simplifying and risking the loss of nuances. In this instance, making the schedule user friendly won out. We decided to simplify the language but also link to each citation.

The schedule isn’t quite done yet, but it will be ready to go in time for the launch of a new fiscal year and a new round of awards.

Anita Vannucci

Records Manager

Emory University

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Research data management and University records management: Collaborative crossroads

This post is the first in a series on research data management presented by the Records Management Roundtable. 

One service area of the University Library System (ULS) I was not initially expecting to become involved with when I became University Records Manager at the University of Pittsburgh was research data management (RDM). However, my participation with a ULS specialist track focused on RDM quickly made it clear that this domain is one that records managers throughout higher education should be tuned into.

Research records and data output from various projects, studies, and trials are both created and managed by departments and disciplines across Universities in huge quantities. While RDM may conjure visions of statistical tables, sprawling spreadsheets, and raw computational models, research output is more often a hybrid of record types. Lab notebooks, clinical information and waivers, computational displays, large data sets, XML exports, artifacts, audio-visual materials, proprietary software output, field notes, and grant and administrative materials vary by discipline and format. Thus, records management is a clear fit with other RDM pursuits.

The ULS “tracks”, or groups of specialists, are charged with specific areas of responsibility, such as instructional design or scholarly communications. The ULS’s RDM track evolved out of a working group and over the past year began forming a three-tiered service delivery model for providing RDM resources and outreach to the University research community. Consisting of digital scholarship specialists, a metadata librarian, an archivist, several liaison librarians, and myself, the RDM track’s goal is to provide guidance, resources, and instruction to researchers on how to best manage their records and data throughout the research lifecycle.

The RDM track has tailored resources surrounding some of the following topics: how to create a data management plan using DMPTool; understanding funder mandates; describing your data; choosing sustainable formats; locating data and disciplinary repositories; and open data sharing. Discussion is often framed by communicating the importance of RDM in terms of time, resources, funding agency and publisher mandates, and research integrity.

Service and outreach are conveyed through resources including a Libguide, website, and FAQS which outline service topics; consultations with faculty to better understand their needs; training sessions for ULS staff, academic departments, and research groups; advertisements throughout campus to promote said services; and a series of instructional modules focused on a specific facet of RDM, such as research records and data retention, freely available on the ULS RDM Libguide.

My involvement with the RDM track has raised important questions: where do research records and data management fit into a higher education RM program? Certainly records management principles and policies apply to research records and data. Although somewhat dated, Pitt maintains a Guidelines for Managing Research Data policy on record, in addition to general and financial retention schedules that loosely address such record types.  Furthermore, as a “state-related” University, most research conducted at the University is not subject to state or federal open record laws.

The question of just how effective records management outreach to the research community can be arises. Departments, research groups, and principle investigators often keep their research output close to the chest (read: attribution), storing it on personal websites, databases, external hard drives, or in departmental or personal storage. Management issues, migration and preservation challenges, and open data conundrums crop up. Additionally, the adoption of enterprise software like Electronic Lab Notebooks only increase issues of ownership, management, and preservation of University research content.

Researchers are advised to consider records management at all stages of the research lifecycle:

  • What types and formats of research records will be created?
  • How, and who, will manage those records throughout the course of the project?
  • Is electronic research output being generated in proprietary systems?
  • How can this data be migrated?
  • What are the applicable research records retention periods?
  • What University records retention policies should I be aware of?
  • Where will I deposit research records following the end of my study?
  • How will I preserve these records over time?

The RDM track’s mission provides the perfect platform for spotlighting how records management practices can and should positively support research data management in the research community at Pitt. As the RDM track moves forward with faculty consultations this summer, I’m interested to learn the ways (and formats) in which researchers are creating records, where they are being stored, what oversight and policies are governing their work, and how they perceive University records management affecting their workflows.

I’ll be working to determine the volume of research records – along with type and importance –that departments and research teams store at the University’s off-site storage vendor, examining how and when content should be exported from ELN’s and deposited or stored elsewhere, and potentially attempting to embed myself with a research group for a term to understand their methods, workflows, and records management considerations.

Records managers in higher education should definitely be engaged with the research community at their respective institutions. However, with limited time and resources (there is one of me!), it’s often difficult to consistently and successfully engage stakeholders. Finding collaborative commonalities with other service providers and information professionals, like the RDM track, is one way to make a records management program more visible to the research community.

Alex J. Toner

University Records Manager

University of Pittsburgh

Research Data Managment: A Scheduled Series

Research records and data output are proliferating at institutions of higher education around the world. What implications does this have for records management programs? How can university records managers and archivists position themselves as effective resources for the research community? What about the retention of and access to the research record themselves?

The Records Management Roundtable hopes to foster a dialogue on the topic through a series of research data management themed posts. Over the next four weeks The Schedule will feature posts describing collaborative efforts to address research data management, resources and outreach initiatives, incorporating research records into a retention schedule, and the question of faculty research as a public record.

We encourage comments on the posts as well as further discussion at the upcoming SAA annual conference in Atlanta. Finally, if you’re involved in research data management at your institution, we would love to hear about it on The Schedule!

– Records Management Roundtable

Getting Started on Records Scheduling

There was a post on SAA’s College and University Archives listserv (subscriber only, sorry) this week about a problem that is all too common in many of our institutions: The Archives is expected to keep *everything* and is not given sufficient guidance/resources to do so. The author of this post was new to SAA and wanted to see some examples of what schedules people are using for both permanent and temporary records, to give him, at least, some guidance on how to start managing the mess he inherited. Seems reasonable!

Lots of good advice and examples followed, including at least one person suggesting that this was an opportunity to advocate for more storage space! My own response, which I’m adapting for this post, is more along the lines of the famous aphorism: “Give a man a fire and he’s warm for a day; light a man on fire and he’s warm for the rest of his life.” (Wait… that’s not right. Apologies to the late great Terry Pratchett.) In other words, what should people be *thinking* about when they think about building out new records schedules?

Well, there could be (and are) whole courses on this topic. There are, in fact, proposed post series on this topic on this very blog. So this post is not so much a “comprehensive schedule-building how-to” as a “things to consider as you get started”. Even that could be way longer than I would like, so I’m going to try to shorten further by using bullet points. Ready? Follow me after the jump…

Continue reading “Getting Started on Records Scheduling”

Work Halting on Records Management Functions Thesaurus

Work is being officially suspended on the Records Management Roundtable’s functions and activities thesaurus, whose goal was to provide a vocabulary for use by records managers and archivists when classifying and describing records.

Members of the Roundtable’s leadership started work on the thesaurus in 2008, and work has been sporadic since then. However, the project has repeatedly failed to generate enough community support to sustain the effort. The past seven years have shown that creating and maintaining a thesaurus requires more organized effort than the roundtable has been able to sustain.

Records managers and archivists who need or want a controlled vocabulary for functions already have several to choose from. Getty Research’s Art & Architecture Thesaurus, for example, contains a functions hierarchy that “includes descriptors for activities relating to the manipulation of data, the collecting of objects, human communication, economics, business, law, and government, as well as other professional activities.” As another example, archivists and records managers working in higher education might find the Thesaurus for use in College and University Archives useful when describing their records.

It is not clear who would be the likely users of a functions thesaurus created and managed by the roundtable, nor have any specific use cases been identified in which such a thesaurus would be preferable to any of the thesauruses and vocabularies that are already developed and in use.

Therefore, the functions thesaurus project is being officially suspended until such time as (a) compelling use cases can be identified and (b) a critical core group of RMRT members who are invested in the thesaurus’ success can commit significant time to its completion and maintenance.

Archiving Email: RMRT, ERS join forces for next Virtual Hangout

Please join the Society of American Archivists’ Records Management Roundtable (RMRT) and Electronic Records Section (ERS) for Archiving Email: Two Innovative Projects the next installment of our Virtual Hangouts series, airing Thursday, April 10th at 1 pm EDT.

Lynda Schmitz Fuhrig, Electronic Records Archivist at the Smithsonian Institution Archives, and Ben Bromley, Roger Christman, and Susan Gray Page from the Library of Virginia will be discussing two innovative email preservation and access projects.

Schmitz Fuhrig will give an overview of The Collaborative Electronic Records Project (CERP), a collaboration with the Rockefeller Archive Center to develop, test, and share technology to preserve email.

Bromley, Christman, and Page will discuss The Kaine Email Archiving Project @ LVA, which focuses on processing the approximately 1.3 million email records received from the administration of Governor Timothy M. Kaine, and making the identified public records searchable and viewable to users.

We’ll start with an overview of both projects, and then dive into a moderated question and answer session.

As always, we’ll be accepting questions for our speakers from you. If you have a question or topic for discussion please leave it as a comment on this post.

Archiving Email will be broadcast live via the RMRT’s YouTube channel. We’ll also update The Schedule with links to the archived YouTube video.

View past Hangouts here.

 

For your consideration: Become an SAA Mentor

Recently, SAA put out a call for participants in its Mentoring Program, which matches new and experienced archivists to help form mentorship and advising relationships between archivists at various levels of professional experience. Jackie Dooley also talked a bit about the mentoring program in a post on Off the Record. I’ll go ahead and provide some additional links back to both sites, because I think this program is very important. As an archivist/records manager who is not that far away from being a new archivist himself, I remember quite vividly how bewildering navigating professional networks, conferences, workshops, etc. can be, and although I myself never had a formal mentorship set up by SAA, I think I would have benefited greatly from having someone to show me the ropes.

In particular, I think it’s really important for members of this roundtable to offer their services as a mentor, because we represent not just a different facet of archives work but potentially an entirely different profession. I know that when I was in graduate school, I didn’t even consider records management as a career until I just happened to take an elective on it, and my guess is that there are many archivists-in-training who are similarly unaware of why records management is important and of what kinds of opportunities it can afford them. If nothing else, being in a position to talk to mentees about the interaction between Archives and Records Management is helpful for opening discussions about records continuum, appraisal from a different perspective, and other aspects of the profession that might not occur to students and young professionals at first glance.

(Note also that the RMRT has a supplementary mentor program, which operates in conjunction with the main SAA one– we maintain a separate database, however, both to help match specifically to records managers and to allow us to create links between potential mentees and records managers who are not necessarily part of SAA. If you are interested in being added to that list, please email me directly: houstobn AT uwm DOT edu.)

Welcome, for real this time

On behalf of the Steering Committee of SAA’s Records Management Roundtable, welcome to The Schedule. Our hope is to make this your one-stop shop (sort of, see below) for learning about what the RMRT is doing for you (and hopefully getting you all to contribute to the conversation). This blog has been a long time in the making, and I am very excited that we are getting it off the ground.

Now, we are about a decade behind on the blogosphere movement, but it’s New To Us (TM), so there are still probably a lot of questions that you all have about this. I’ll try to answer the obvious ones below; if you have others, please leave them in the comments.

Why a blog? Why now?

The Steering Committee has been trying to improve communications with the RMRT general membership for a while now, with varying levels of success. The survey we sent out in the wake of SAA 2012 in San Diego was one attempt at this, as is our new policy of posting the minutes of our monthly steering committee teleconferences. The newsletter and the listserv are also, of course, key elements in our communication strategy. Ultimately, though, all of those communication channels are not quite… right. The listserv seems a bit impersonal and inactive; the survey and meeting minutes are extremely one-sided; the newsletter is, by its very nature, non-timely.

What we want to do with the blog is open up a more organic conversation about what we’re up to and what we can share from the world of Records Management. We are planning to update this regularly and actively solicit guest posts or topics that our readers would like to see us write about. We’re encouraging commenting if you have something to add, or think we’re off base, or whatever. The point is to have a regular communications channel where the barrier to participation is relaxed, at least somewhat.

Does this mean the newsletter is going away? The microsite? The listserv?

In order: No, no, and we couldn’t even if we wanted to. Each of these existing communications tools is going to be sticking around, but the purpose of each will change somewhat:

  • The Microsite is going to be our document/information repository for the foreseeable future. Here you will be able to find our annual reports, our bylaws, information on our steering committee members, meeting minutes, and any publications we are putting out for review or use.
  • The Newsletter will be for our longform pieces, such as the chair’s year-in-review report or in-depth interviews or case studies. As implied by Lorette Weldon’s most recent call for submissions, we want people to think of this as a place to talk at length about their innovations in archives and records management– not quite the cachet of a scholarly journal, obviously, but works in progress and preliminary results, perhaps. Think Archival Outlook levels of discussion of theory and practice.
  • The Listserv will be for the day-to-day stuff that isn’t worth a whole blog post to write about– job ads, records management in the news, calls for endorsements, etc. Of course, if you just have a question for the membership or that you want to get a number of perspectives for, you’re welcome to keep using it that way– this is just referring to how the steering committee is going to use it going forward.

What is the schedule of The Schedule?

I see what you did there. Our current plan is to update at least once a week, with different members of the steering committee in a rotation to write about something in their particular bailiwick. You can find a preliminary schedule for the next month or so in our February meeting minutes. Of course, if something strikes our fancy when it’s not our turn to write, we won’t let our schedule stop us– this is just to keep us honest and avoid content deserts.

I’m doing something really cool with records management (or read a cool new records book, attended an interesting conference, etc.), but I don’t want to wait until the newsletter comes out. Can I write a guest post for the blog?

Of course! Please send us an email with your post idea– we’d love to hear from you!

Anything else I should know about this blog?

If you’re new to blogs, there are a couple of ways to follow it so you don’t have to keep refreshing the site for updates. Way #1 is to click the “Follow” button on the right there– you’ll get an email notification when there’s a new post. Way #2 is to input this URL into your Feed Reader of choice (I like Google Reader), and most readers will automatically extract the RSS feed from WordPress sites for you (which is good, since there’s no Feed URL in sight on this template).

Happy reading! I must now scurry off and complete my presentation for next Friday (see below for details).