Chapter 17 – Records Management
The University of Iowa is required by law to develop internal rules for the economical, efficient, and systematic management of its records. Accordingly, the University has established the following Records Management Policy and Records Management Program and Retention Schedule to maintain, protect, and retain or dispose of records in accordance with legal, historical, and reference needs. As such, this policy implements the requirements of the Iowa Administrative Procedure Act (Iowa Code 17A) and Board of Regents Rules (Iowa Administrative Code 10).
Records are the property of the state and shall not be mutilated, destroyed, removed, or disposed of, except as provided by law, rule, or policy. Records should be archived or disposed of in accordance with University disposal requirements after the retention period, subject to the exceptions stated in this policy regarding retention for audit and litigation purposes. All University of Iowa faculty and staff have responsibility for identifying and retaining records in accordance with established records retention criteria (outlined in the Records Management Program and Retention Schedule).
The University of Iowa Secretary, appointed annually by the Board of Regents, State of Iowa, according to the Iowa Code 262.9, or designee, in consultation with other University administrators as appropriate, shall have the authority and duty to implement, administer, and update this policy as necessary.
Records are anything containing information which is made, produced, executed, or received in connection with the transactions and official activities of the University or executed in the conduct of University business, including research, teaching, service, and administration. Examples include documents, books, paper, electronic records, photographs, videos, sound recordings, databases, and other data compilations that are used for multiple purposes, or other material, regardless of physical form or characteristics.
Records can be divided into two categories: 1) Official, and 2) Transitory/Convenience.
- "Official records" are:
- records having the legally recognized and judicially enforceable quality of establishing some fact, policy, or institutional position or decision.
- the single official copy of a document maintained on file by an administrative unit of the University which is usually, but not always, the original.
- subject to the records retention requirements included in the Records Management Program and Retention Schedule.
- "Transitory/convenience records" are:
- duplicate copies of official records.
- extra copies of documents or records created or preserved for convenient access and/or for reference, including computer backups and duplicate computer files. (See University of Iowa IT Backup and Recovery Policy for specifics on electronic record backup.)
- miscellaneous correspondence without official significance.
- versions or drafts of reports, memos, word processing files, letters, messages, or communication (electronic or otherwise) that are used to develop a final official document.
- records that do not carry a requirement for retention and should be destroyed when they cease to be useful (using secure destruction methods if they contain confidential information).
Either official or transitory/convenience records may contain confidential information. Confidential information is information of various sorts that the University receives and holds confidential unless otherwise ordered by a court, by the lawful custodian of the records or by another person duly authorized to release such information. Examples include: student records, medical records, personnel records, etc. (See Iowa Code 22.7, Confidential Records.) University faculty and staff should determine if records contain confidential information when conducting an inventory of departmental records and maintain and dispose of them accordingly.
Either official or transitory/convenience records may also contain vital information. Vital information is considered essential for the operations of a department (and/or the University) and includes information that may prevent a department from incurring serious liability or risk, or that would be extremely costly to replace. In the event of a disaster, this information, if destroyed, would make it difficult for a department to conduct normal business activities. University faculty and staff should determine if records contain vital information and maintain and dispose of them accordingly.
Any record, official or transitory/convenience, may be considered a public record; however, not all public records are subject to release (see University of Iowa Public Records page or Iowa Code 22.7).
The Records Management Program and Retention Schedule are designed to assure that official records will be preserved appropriately while providing economy and efficiency in the creation, organization, maintenance, use, and disposition of records.
- Procedures dealing with records of transactions of the official business of the institution, including design, handling, maintenance, filing, storage, and security.
- Procedures dealing with utilization of space, equipment, and supplies.
- Schedules for retention of official records, and the form in which they are to be retained, either in offices or archives. University of Iowa records retention criteria require that all official records, as defined above, be maintained for a minimum of five years, ten years, or permanently, based on the requirements of the record type. If the legal retention requirement for a specific official record type is anything other than 5 years, 10 years, or permanent, the assigned retention requirement will round up to 5 years, 10 years, or permanent, to meet University policy requirements. Exceptions to these retention requirements must be approved by the Records Management Committee.
- Schedules for destruction of official records and the method to be used.
- Standards for reproduction of records.
"Disposal" refers to the disposal of the record whether by physical destruction or transfer to the University Archives at the end of its retention period.
- Official records shall not be destroyed or otherwise disposed of by any University faculty or staff except as outlined in the Records Management Program and Retention Schedule.
- Transitory/convenience records may be destroyed at the discretion of the user, assuring the secure destruction of confidential information. Transitory/convenience records that may have historical or enduring value should be reviewed by the University Archivist before destruction.
- Exceptions to disposal of records:
- Any record in any form may not be disposed of by the holder if the holder is aware of any audit, litigation, public records request, claim, negotiation, open administrative review, or other action involving the record.
- Records must be maintained until all required audits and requests are satisfied and should be retained beyond the required retention period when there is a probability of litigation either involving records or requiring their use.
- If the University Office of the General Counsel has issued a litigation or legal hold, records relevant to the issue must be preserved until the hold has been released.