Managing Paper Records

Answer these questions to determine if records can be destroyed 

Are they:

• No longer needed for business purposes?

• At or past their required retention period under the adopted retention schedule?

• Not subject to any legal holds or other regulatory requirements for maintenance?

If all the above answers are yes, the records can be destroyed. For paper files or documents, this is most commonly done by shredding. 

• Chapter 6 of the Records Management Manual covers all the details of Record Disposal/Disposition process. 

• This includes how to complete the required Certificate of Records Disposal form, DR 5041.

Determining if records are past required retention

How do you know if a record is past its required retention period and can be destroyed?  Every division is required under the Department's Records Management Policy, AOD-004, to have one or more records custodians assigned to manage their records throughout the record's lifecycle. As part of this, divisions must have current retention schedules for their own records based on the State's adopted Records Retention Schedule, maintained by State Archives.

These division retention schedules are captured as SA-194 forms. Every division or unit should have an SA-194 that lists all of its record classifications and their associated retention periods. These retention schedules apply regardless of how the record is stored (i.e. electronic, paper, microfilm, digital image, audio or video recording, etc.) All current  Departmental SA-194s are posted on the State Archives website. If you have questions about the SA-194s for your division, contact the Director of Records Management.

Completing a Certificate of Records Disposal form

When you are ready to destroy any records, including paper files, you need to complete a Certificate of Records Disposal form, DR 5041, documenting the details of the destruction of the records. Division staff completes this form, signed off on by the division's records custodian, and submitted to the Director of Records Management for approval and signature. The Director of Records Management then submits the approved form and additional documentation to State Archives, which maintains the record of destruction.

Shredding services

DOR contracts with an NAID® AAA certified vendor for secure destruction services of paper documents. The service provides secure locked bins for office areas, regular weekly or monthly destruction, cross-cut shredding, chain of custody logs, and a certificate of destruction for each visit. Each of DOR’s main buildings/locations should have this shred service already in place. Secure destruction services must be used to destroy all paper documents and paper records that contain or may contain sensitive data or personally identifiable information (satellite offices must have an office cross-cut shredder available that is appropriate for the volume of documents to be shredded). Secure destruction services are also utilized for records stored on microfilm, microfiche, and digital media such as CD, DVD, cassette, portable drives, etc.

If your division has a large volume of shredding, you can set up a one-time additional pick-up or short-term use of additional bins with the shredding provider through your building's shred service coordinator. Shredding at the Pierce Building is managed by Mail Services. Contact Mark Holloman for more information.

Resources

• RMM - Chapter 6 - Record Disposal/Disposition and Completing the Certificate of Records Disposal Forms

• DR 5041 - Certificate of Records Disposal form

• State Archives' Adopted State Retention Schedule for State Agencies

• Division Specific Retention Schedules (SA-194s)

• Division-level Records Custodians and Delegates

• DOR's Director of Records Management, Anissa Hollingshead

• For shredding services at Pierce: Materials Handler in Mail Services Mark Holloman

In many instances, digitizing existing paper records for longer-term retention can make sense. Particularly as office space is reduced and more employees are working remotely, digital files can offer advantages in flexible storage and access. However, it is also critical to remember that digitization requires more than just a scanner and storage drive. 

A well-thought-out plan is essential to ensuring digital records remain useful and accessible and are kept in compliance with all relevant policies and regulations.

Questions to ask when planning starts

These are some essential considerations that need to be incorporated into any plans for digitization BEFORE any work starts. The only thing worse than a mystery box of unidentified files is a mystery digital file of unidentified information. Digitizing does not provide order and context where none existed before records or papers were scanned.

1. Are the records still needed?

   • If the records are past the period they must be maintained under their adopted retention schedule, and aren't otherwise needed for business or legal reasons, they should be destroyed instead of digitized.

2. How long do these records need to be kept? 

   •  Will the records need to be maintained for at least a minimum amount of time to make the investment in this process worthwhile? 

   • If the records must be kept longer term or permanently, is there a sufficient plan in place to ensure they can be kept in a nonproprietary system with the ongoing capability to migrate them to the next generation(s) of technology?

3. What kind of data is included in the records? 

   • This includes whether the records include any sensitive data types, such as PII, CJIS information, FTI, or DMV information, all commonly found at DOR.

4. Who needs to be able to access the records?

   • Which team members need access?  

   • Is there a need for team members across the department to access the information? Anyone outside of DOR?

   • Any storage locations need to be accessible to those needing access to the information, as well as the ability to manage or control access if necessary, including specifically if the type of included data requires access limits.  Access must also not be dependent on a specific individual.

5. What is the volume of the records?

6. How are the records currently organized?

7. Where will the digitized records be maintained? 

   • This will be dependent on a number of different factors to be considered, including:

     •  Who needs to have access to them;

     • What type of data is in the records, and what kind of security requirements are associated with that data;

     • What storage locations are available to your division - this may be Google Shared Drives, Network Drives, or possibly a document management system - the type of storage location needs to be compatible with both the security required for the data and the reliability and risks associated with the location relative to the type of information. Sometimes, scanned information can also be imported directly into a system such as DRIVES or GENTAX for maintenance.

8. What resources are available for digitization and maintaining digital files?

   • Digitizing involves time and resources, including potential funding needs.

   • What funding is available for this effort for both the scanning/digitization work itself?

   • Is there any internal capacity and equipment to complete digitization in full or part?

   • Are there other digitization resources already utilized by the division or department that could be potentially utilized? For example, IDS scans for DOR in some instances.

   • Is using an outside vendor potentially an option? There are numerous commercial scanning/digitization vendors.

   • Do you have a clearly identified storage location that is not dependent upon a single individual or role to maintain or locate files?

   • Do you have an established digital file structure or the ability to create one to maintain these files?

   • What kind of work needs to be done to determine appropriate file names and associated meta data and who can do that work?

Starting digitization

1. How will digitization be done? 

• Deciding whether in-house resources will be used, versus other State resources or potentially outside vendors 

• While this decision may seem to be largely driven by resource considerations, don't forget other factors as well. For instance, considering what kind of quality control will be employed after scanning and before the paper records are disposed of is critical. The longer the records need to be maintained and the more significant they are legally and to business operations, the more important quality control is. Some vendors will check every page for clear scans, while others may do no QC. The price usually varies accordingly so be clear when evaluating any quotes what is and is not included.

• What kind of preparation, sorting, combining, etc. is expected from the individual(s) or vendor doing scanning? 

• Where will the file names applied as part of digitization come from?

2. What kind of file structure will be used for storing the digitized materials? 

• This includes where the files will be kept, how they will be organized (i.e. a directory of folders, subfolders, etc.), how the files will be named, and how properly named files will be placed in the appropriate identified structure upon digitization.

•  Retention is also a critical part of file structure. Consideration should be given to how the required retention of the records from their adopted retention schedules could be incorporated into the development and implementation of this structure to ensure records are kept for the time they are required to be, and then destroyed. 

3. What metadata will be identified and applied to each file? 

• Answering this question also includes incorporating into the digitization plan who will identify the metadata, at what point, and how it will be applied as part of the process. These considerations are essential to ensuring usable digital records are created and maintained.

Resources

• RMM Chapter 4 - Record Storage, Filing Plan, Securing, and Tracking: Electronic Records

• Information on Scanning Services through IDS

If there is not space within current office locations, off-site storage may be an option. There may be other DOR facilities that could be utilized for storing some paper files. Any storage location needs to be secure, with reasonable levels of climate control and protection for paper materials to ensure their integrity is not compromised. There are also third party services that provide off site storage. Regardless of the option considered, it is important to fully document all records and where they are located to ensure ease of access when required.

Resources

• RMM Chapter 3 - Record Storage, Labeling, Filing, Securing, and Tracking: Physical Records