ROLE OF UNIVERSITY EMPLOYEE

Every employee within the University performs records management. University employees are responsible for knowing what a public record is and how to secure, retain and dispose of it in accordance with state and federal law and statutes.

University employees are responsible for knowing how to complete the proper records management forms and processes necessary for security, retention, and disposition.

ROLE OF UNIVERSITY DIVISIONS/DEPARTMENT RECORDS MANAGEMENT

Division/Department units must handle all records under their control in accordance with the requirements of Policy # (pending) and are responsible for ensuring that University records under their control are retained, secured and disposed of in accordance with University policy, as well as state and federal law. 

Each department or division will designate a records contact to facilitate records management in conjunction with the University RMLO. Responsibilities of the records contact in relation to records management will include, but is not limited to facilitating the maintenance, security, and review of records. The records contact must maintain an accurate inventory of active, inactive and disposed records. Regular disposition of records will include coordination with University RMLO for proper disposition, transfer, or archiving of records which have met their retention period.

ROLE OF RECORDS MANAGEMENT LIAISON OFFICER (RMLO)

The primary purpose of the Records Management Liaison Officer (RMLO) and the Records Management Department is to provide guidance and assistance to University personnel in establishing records and information management and in managing the public records and information they create and use.

Specifically, the RMLO will establish and coordinate records scheduling and disposition in accordance with department reported records inventories. Establish new records retention schedules as needed with the Florida Division of Library and Information Services to ensure the appropriate retention and/or disposition of records.

The RMLO will provide University departments and individuals with training and assistance in the areas of compliance with state laws, regulations, and policies. The RMLO will also assist with records retention and disposition, storage, security, identification of vital records, records preservation and associated services.

The RMLO will report annually to the Florida Division of Library and Information Services regarding the University’s compliance with records management statutes and rules.

All documents, papers, letters, maps, books, tapes, photographs, films, sound recordings, data processing software, or other material, regardless of the physical form, characteristics, or means of transmission, made or received pursuant to law or ordinance or in connection with the transaction of official business by any agency.

After preparing the inventory list, determine the appropriate destruction date of each series of records. If any records have met their retention requirement, follow the disposition procedures in this manual.

The University utilizes both the General Records Schedule GS1-SL for State and Local Government Agencies and the General Records Schedule GS5 for Universities and Community Colleges. For records not covered under these retention schedules, the University RMLO may request an Individual Record Schedule from the Florida Division of Library and Information Services. Your department may also be subject to federal, agency, or professional guidelines.

All of these retention schedules establish the minimum length of time a record series must be maintained. University departments are required to dispose of records when they have met retention period requirements unless the department can demonstrate a need to keep records due to an active litigation, public records request, accreditation standards, fiscal support, or records needed in support of audits or administrative need.

When the retention requirement has been met for records, the department (with assistance from the RMLO) will determine how to dispose of those records. A decision will be made as to whether a disposition approval form is required.

A Disposition Approval Form is NOT required for:

1) Record copies with a retention designation of OSA (obsolete, superseded or administrative value is lost) such as:

1. Administrative Support Records – GS1 – SL #3
2. Drafts and Working Papers – GS1 – SL #242
3. Mailing Lists – GS1 – SL # 29
4. Operational and Statistical Report Records – GS1- SL#124
5. Staff Administration Records – GS1 – SL #371
6. Transitory Messages – GS1 – SL #146
7. Course and Program Records – GS5 #50
8. ID records : No fee Paid - GS 5 #67
9. Procedures Manual – GS 5 #22
10. Student Profile Analysis – GS5 #32

2) Duplicate copies with a retention period of OSA (obsolete, superseded or administrative value is lost)

Please note this lists only the most common records. Refer to the applicable state retention schedule or the University RMLO for more detailed information.

If documents do not need a disposition form, you may recycle or shred those documents, but if the documents contain confidential or sensitive information they must be shredded, regardless of whether a disposition form is required or not. This is a partial list of sensitive and/or confidential information:

• Sensitive information:

• UIN numbers
• Payroll information
• ID Records
• Evaluations

• Confidential information:

• Social Security numbers
• Medical information
• Legal information
• FERPA (Ref. FGCU Policy 3.006) student education records
• Financial, loan info
• Bank account numbers, includes checks (original & copies)
• Credit card information
• Security and Emergency plans

The University RMLO will provide shredding services as needed.

For disposition of all records that aren’t designated as OSA, a records disposition form must be completed.

After the records disposition form has been completed, forward to the University RMLO for review and approval. The RMLO will provide assistance in determining the best method of disposal.

We have a university contract with Secure On-Site Shredding (SOS) providing monthly shredding service, giving you several options for your shredding needs:

Option 1: Utilize the campus shredding deposit bins for shredding needs of one box or less

Option 2: Request a departmental shredding bin for temporary or permanent use

Option 3: Participate in the university periodic records purge

These bins are intended for shredding jobs of one 12 x 15 box or less.

Shredding deposit bins are placed in a few select locations on campus to provide departments the ability to deposit documents for shredding in a securely locked container any day of the year. If your documents do not require a disposition form, you do not need approval to place documents in the bins. If your documents require a disposition form, follow these steps:

1. Complete a Records Disposition Form
2. Send Records Disposition Form to Ruth Rodrigues, University Records Management Liaison Officer, for review and approval.
3. Upon receipt of the RMLO approved form, you may place your documents in one of the shredding deposit bins on campus. These are currently located in McTarnaghan Hall, Room 138 and in the Student Union, Room 145.
4. Note the date of deposit in Column “G” on the Records Disposition Form and return to Ruth Rodrigues, University Records Management Liaison Officer for final processing.
5. When the documents are shredded, the RMLO will certify the destruction and return the completed form to the department for filing in your records system.

Option 2: Request a departmental shredding bin

Departmental shredding bins may be requested for departmental use on a temporary or permanent basis. Bins come in three sizes:

32-gallon console - holds approximately 4 cubic ft, or three 12 x 15 boxes

64-gallon container - holds approximately 9 cubic ft, or five 12 x 15 boxes

94-gallon container – holds approximately 12 cubic ft, or eight 12 x 15 boxes

  

1. Contact University Records Management Liaison Officer Ruth Rodrigues to request a shredding bin.
2. Shredding bin will be placed in your department location, on a temporary or permanent basis. Bins will be emptied and shredded once per month, if you have a department bin that hasn’t been utilized during the current month, please notify your RMLO at least one week prior to scheduled pickup to avoid unnecessary charges.
3. If a records disposition approval is not required, you may place your documents in your department bin without approval.
4. If records disposition approval is required, complete a Records Disposition Form and send to Ruth Rodrigues, University RMLO.
5. Upon receipt of the approved form, you may place your documents in your department bin.
6. Note the date of deposit in Column “G” on the Records Disposition Form and return to Ruth Rodrigues, University RMLO for final processing.
7. When the documents are shredded, the RMLO will certify the destruction and return the completed form to the department for filing in your records system.
8. The RMLO will send an invoice for your department charges, shown at the following rates: Shredding Cost
9. Chargebacks will be posted to your account after your approval of invoice.

Option 3: University periodic records purge

Campus periodic records shredding will be scheduled annually, a university announcement will be sent approximately 1 month prior to the scheduled shredding date.

1. Complete a Records Disposition Form if required. If a records disposition approval is not required, send an e-mail request to the University RMLO indicating size and number of boxes you would like to shred.
2. Send Records Disposition Form to Ruth Rodrigues, University RMLO for review and approval. Note on the form that you wish to participate in the periodic university records purge.
3. RMLO will review and return signed form to you for reference, along with a notification of the purge date and any additional instructions. The RMLO may provide options for shredding that will provide for faster disposal of your records if available.
4. After the documents are shredded, the RMLO will return a copy of the final form to the department for filing in your records system.
5. The RMLO will send an invoice for your department charges at the rates listed on the Records Management Website. http://www.fgcu.edu/RecordsManagement/
6. Chargebacks will be posted to your account after your approval of invoice.

Upon request, your University RMLO will coordinate destruction of your electronics shredding requirements, including DVDs, CDs, VHS tapes, jump drives, etc.

1. Complete a Records Disposition form.
2. Send Records Disposition form to Ruth Rodrigues, University RMLO, for approval.
3. RMLO will review and return signed form to you, with instructions for delivering media to the RMLO office for pickup by Secure On-Site Shredding Services.
4. You will be sent an estimate for the shredding charges prior to shredding.
5. After confirmation of shredding, RMLO will complete the Records disposition form certifying that media was destroyed.
6. Copy of records disposition form returned to your department, along with invoice for shredding services.
7. Chargebacks will be posted to your account after approval of invoice.

Under the Florida Public Records Law, the University must make its records accessible to the general public upon request. When a request is made, oral (in person or via telephone) or written, we must respond promptly and responsibly. While we must be aware that the law provides penalties for public employees who deny access to public records without legal basis, we must be equally aware that if we disclose any information that is protected by law from public disclosure, the person whose records have been disclosed improperly may take us to court. Therefore, it is advised that the following procedures be strictly followed when responding to a request for public records. Reference Florida Statute 119.01 for the Public Records Act and FGCU Policy 3.021 on E-Mail Policy.

ALL FGCU public records requests made verbally or in writing should be directed to the following:

General Counsel Vee Leonard -- for requests made by attorneys engaged in pending or imminent litigation against the University

- OR -

University Spokesperson/Chief of Staff Susan Evans -- for requests made by members of the media or general public.

They will:

• review the request if in writing, or discuss the request with the person seeking the information if it is a verbal request;
• determine the University’s obligation under Chapter 119, F.S.
• contact FGCU individuals who possess needed data and/or other information;
• assess the estimated length of time for compilation of information, and communicate this to the person making the request;
• assess any charges to be incurred for duplicating or extraordinary data requests as defined by Florida Statute, and communicate this in advance to the individual making the request;
• comprehensively review all materials supplied by one or more FGCU departments;
• redact information designated as confidential under Chapter 119, F.S. and the Family Educational Rights and Privacy Act (FERPA), and
• provide the individual with copies of the requested public record(s), as well as the statutory citation for any exemptions claimed, and share this information as applicable with the president and other administrators.

DO NOT RESPOND TO OR HANDLE A PUBLIC RECORDS REQUEST YOURSELF. You must contact the General Counsel’s office or University Spokeperson’s office for further instructions.

Archival Records: are those records determined to have long-term historical, research or other continuing value. Archival records are often referred to as historical records, but their value can be historical, administrative, legal or financial. (State of Florida, The Basics of Records Management Handbook, 2009)

Confidential: refers to public records that have been identified in the Florida Statutes as confidential. The information in these records is not subject to inspection by the public and may be released only to the persons and entities designated in the statute.

(State of Florida, The Basics of Records Management Handbook, 2009)

Destruction: the result of actions taken to ensure that media cannot be reused as originally intended and that information is virtually impossible to recover or prohibitively expensive. (NIST 800-88)

Disposition: “Final actions taken with regard to public records that have met all retention requirements and are no longer needed for current government business as indicated in General Records Schedules or Records Retention Schedules. Disposition may include either destruction of public records or transfer of public records to the custody of another public agency such as the Florida State Archives or a local government archives or records repository.” (Rule 1B-24.001(3)(c), F.A.C.)

Duplicate Records: are reproductions of record (master) copies, prepared simultaneously or separately, which are designated as not being the official copy. (State of Florida, The Basics of Records Management Handbook, 2009)

OSA Records: are records with a retention of “retain until obsolete, superseded or administrative value is lost” (Rule 1B-24.003. F.A.C.)

Public Records: are those as defined in Section 119.011, F.S., (12): "Public records" means all documents, papers, letters, maps, books, tapes, photographs, films, sound recordings, data processing software, or other material, regardless of the physical form, characteristics, or means of transmission, made or received pursuant to law or ordinance or in connection with the transaction of official business by any agency. and include records that are designated by statute as confidential or exempt from public disclosure.

Record copy: is specifically designated by the custodian as the official record. (Rule 1B-24.001(3)(j), F.A.C.)

Records Inventory: the systematic categorization of records in an agency conducted to develop or identify appropriate retention schedules for the agency’s records. (State of Florida, The Basics of Records Management Handbook, 2009)

Records Management Liaison Officer (RMLO): the individual designated by the agency who serves as a contact person to the Division of Library and Information Services and is assigned records management responsibilities by the Custodian. This individual is responsible for developing the agency's records management program, and coordinating University records scheduling and disposition. (State of Florida, The Basics of Records Management Handbook, 2009)

Record Series: is a group of related public records arranged under a single filing arrangement or kept together as a unit (physically or intellectually) because they consist of the same form, relate to the same subject or function, result from the same activity, document a specific type of transaction, or have some other relationship arising from their creation, receipt, or use. A record series might contain records in a variety of forms and formats that document a particular program, function, or activity of the agency. (Rule 1B-24.001, Florida Administrative Code)

Records Retention Schedule: identifies records and establishes minimum periods of time for which the record must be retained based on the records administrative, fiscal, legal, and historical values. (State of Florida, The Basics of Records Management Handbook, 2009)

Security Controls: the management, operational, and technical controls (i.e., safeguards or countermeasures) prescribed for an information system to protect the confidentiality, integrity, and availability of the system and its information. ( From FIPS Publication 199)

"Sensitive,": for purposes of defining agency-produced software that is sensitive, means only those portions of data processing software, including the specifications and documentation, which are used to: (Section 119.011, F.S.)

• Collect, process, store, and retrieve information that is exempt from Section 119.07(1);
• Collect, process, store, and retrieve financial management information of the agency, such as payroll and accounting records; or
• Control and direct access authorizations and security measures for automated systems.

Transfer custody: Change of custody, ownership, and/or responsibility for records. Source: Information and Documentation - Records Management - Part 1: General (ISO 15489:2001) [10].

Vital Records: are those that are essential to the continuation of operations in an agency in the event of a disaster or emergency. (State of Florida, The Basics of Records Management Handbook, 2009)

Calendar year – Jan. 1 thru Dec. 31

If a record has “3 calendar years” retention, the disposition eligibility date would be 3 years after the end of the calendar year of the last record in the series. Example: You have records dated Apr 2006 – Oct 2010, with 3 calendar years retention period, at end of calendar year 2009 destroy Apr thru Dec 2006 records only.

Fiscal year: FGCU’s fiscal year is from July 1 – June 30

If a record has “3 fiscal years” retention, the disposition date would be 3 years after the end of the fiscal year of the last record in the series. Example: You have records dated Apr 2006 – Oct 2010, with 3 fiscal years retention period, on July 1, 2009, destroy Apr 2006 thru June 2006 records only.

If your department follows a different fiscal year, please notify RMLO the fiscal year and governing authority.

Months or days

Examples: 3 months; 90 days: Last date in record series is April 15, 2009, add 90 days or 3 months, so destruction eligibility date would be on July 15, 2009. No need to wait until end of month or end of year.

OSA

Retain until obsolete, superseded, or administrative value is lost.

With this retention, a record is eligible for disposition whenever it is no longer of any use or value to the agency. The retention could vary from less than one day to any length of time thereafter.

Triggering event 

Records become eligible for disposition upon or after a specific triggering event.

Examples:

• 5 yrs after student transfers or withdraws
• Retain for life of the structure.
• 3 anniversary years after final action.

Calculating Eligibility Dates

Example: Let’s say that the ending date for a specific record series is 7/31/2007. When are these records eligible for disposition under different retention period types?

Retention Period Date to start counting Add # of years Date eligible for disposition

3 anniversary years 7/31/2007 +3 = 7/31/2010

3 fiscal years (FGCU) 7/1/2008 +3 = 7/1/2011

3 calendar years 1/1/2008 +3 = 1/1/2011

Remember that even though your records may be filed according to one type of “year” – the state retention schedule “year” is what must be followed.

Example: Admissions keeps a file by academic year for administrative purposes. However, the retention period is by calendar year. Disposition and/or destruction must be based on calendar year.