State Agency Records Destruction 101

No state government employee may destroy records without first obtaining the approval of the State Records Commission (SRC) (Code of Alabama 1975 §  41-13-21). The SRC determines which state government records have permanent value and which may be destroyed after specified periods of time.

The SRC authorizes destruction through state agency Records Disposition Authorities (RDAs). RDAs designate records as either temporary records, which may be destroyed after a specified retention period, or permanent records, which are preserved for future generations. State agencies may destroy temporary records after they have satisfied the minimum retention requirements prescribed by the RDA (and presuming no litigation or other hold is placed upon the records). The retention period is only a minimum; agencies may choose to maintain records for longer than the retention period. State agencies which have an approved RDA must document the destruction of both paper and electronic records and submit this documentation to the ADAH Records Management Section each year.

The ADAH provides on its website a template destruction form, entitled the “State Government Records Destruction Notice.” While all the required information in this form is mandatory, the format is flexible. State agencies may choose to create internal procedures for documenting destruction and may create their own forms. Whichever format agencies choose, they must capture the following information:

  • State agency name and department/division
  • Records Title as shown on RDA
  • Retention as shown on RDA
  • Inclusive dates
  • Date audited
  • Format
  • Volume
  • Total cubic feet (for paper records)
  • Total bytes (for electronic records)
  • Manner in which the records will be destroyed
  • Printed name, job title, and signature of authorizing official
  • Date signed

Documenting State Records Destruction  

Use a Records Disposition Authority

Consult your agency’s Records Disposition Authority (RDA) for retention requirements. The RDA lists the types of records your agency creates and the minimum amount of time the records must be maintained. Once the retention has been met, state agencies may (but are not obligated to) proceed with destruction.

Identify the record type(s) that you wish to destroy. Determine whether litigation or other holds prevent the destruction of otherwise eligible records. Then, document the following information in the State Government Records Destruction Notice or form of your choosing:

  • “Records Title as Shown on RDA”

Fill in the Records Title for each record type, which appear in bold in the RDA document section entitled “Records Disposition Requirements.”

  • “Retention as Shown on RDA”

Fill in the minimum retention as listed in the RDA document section entitled “Records Disposition Requirements” (for example, “Retain 3 years” or “Retain 2 years following audit”).  

  • “Inclusive Dates”

For each record type, include the earliest and latest dates that the records were created (for example, “1998,” “May-November 2019,” or “2000-2010”).

  • “Date Audited”

Some retentions are dependent on audit date. If the retention in the RDA mentions an audit date, identify when these records were made available for audit. If the retention does not mention an audit, write “N/A” for Not Applicable.

Note: Do not list your state agency’s most recent audit. Specify when the records were made available for audit. For example, consider a state agency that has been audited in 2010 and 2017. The agency is submitting a destruction notice that includes records with a minimum retention “Retain 2 years following audit” and which were created in 2008 and audited in 2010. The agency should write “2010” in this field, as this was the audit cycle in which the 2008 records were made available.

  • “Format”

The format or medium of the records (paper or electronic).   

  • “Volume”

The volume of the paper records being destroyed in cubic feet and/or electronic records being destroyed in bytes.

Paper Records

Paper RecordsList how many cubic feet are being
destroyed for each record type
1 Box of Copy Paper1 Cubic Foot
1 Banker’s Box2 Cubic Feet
1 Legal-Sized File Drawer2 Cubic Feet
Fifty 100 Foot 35mm Microfilm1 Cubic Foot
3×5 Cards, Ten 12″ Rows1 Cubic Foot
3 Large Bound Volumes1.5 Cubic Feet

Electronic Records

Electronic RecordsList how many bytes (B, KB, MB, GB, TB, or PB)
are being destroyed
1 Byte (B)8 Bits
1 Kilobyte (KB)1,024 Bytes
1 Megabyte (MB)1,024 Kilobytes
1 Gigabyte (GB)1,024 Megabytes
1 Terabyte (TB)1,024 Gigabytes
1 Petabyte (PB)1,024 Terabytes

Complete the Total Records Destroyed

Add up the total cubic feet and write the sum in the field entitled “For Paper Records: Total Cubic Feet.”

Add up the total bytes and write the sum in the field entitled “For Electronic Records: Total Bytes.”  

Complete the Signature Section

Ensure the appropriate authorizing official signs the notice. The notice may be signed electronically or may be printed and signed. Please remember to include the printed name and title of the authorizing official. All destruction must be reported to the Records Liaison so that they can document the destruction in the Annual RDA Implementation Report.

Destroy the Records

The SRC and LGRC do not stipulate how records should be destroyed; however, state agencies should ensure that the disposition method they use is appropriate for the records being destroyed. Records with confidential or sensitive content, such as financial information, personally identifiable information (PII), or personal health information (PHI), should be destroyed securely in a way that leaves records unreadable and unrecoverable. 

For Records Liaisons: Guide to Completing the Annual RDA Implementation Report

Each year (typically in October), the ADAH Records Management Section sends state agency Records Liaisons instructions for completing the Annual RDA Implementation Report. Records Liaisons must complete the report and submit all destruction documentation to Records Management staff by January 15th of the following year. 

Note: Failure to properly adhere to destruction procedures may result in an audit finding.

A Detailed Guide to the State Agency Records Disposition Authority (RDA) Revision Process

We spent the previous two weeks discussing the state agency Records Disposition Authority (RDA) revision process:

Once you have contacted Records Management staff, held an introductory meeting, and received a copy of the currently approved RDA in Microsoft Word from Records Management staff, you are ready to begin revising.

The Microsoft Word copy of the RDA will contain notations indicating which sections may be revised and which sections contain standardized, inalterable language.

Edit the document using Microsoft Word’s “Track Changes” feature.

The RDA contains three main sections. Read below for a detailed guide to revising each section.  

Section 1: Functional and Organizational Analysis

This section assesses the types of work your agency performs in the regular course of business.

Historical Context

This subsection should include an in-depth contextual description of the events leading to the agency’s establishment and the agency’s history, including, but not limited to, the following:

  • Origin and development of the profession in the state of Alabama
  • Specific legislation establishing the agency
  • Agency composition and organization over time, if different than at present
  • Specific executive orders, state legislation, and/or federal legislation affecting the agency, e.g. increasing or decreasing the scope of the agency’s work, restructuring the agency, etc.
  • Explanatory notes which define concepts or terms specific to the field/industry that the general public may not understand

Agency Organization

This subsection derives from the Code of Alabama 1975 and legislation. It should describe the agency’s current organization, including the structure of its board or executive branch, qualifications to serve, appointment procedures, meeting procedures, and term limits. This section also provides a brief overview of the agency’s departmental branches.

Agency Functions and Subfunctions

The agency function designation comes from a standard set of government functions and may not be altered.

The agency subfunctions may be revised to reflect the agency’s added or removed tasks. Subfunctions should be simple and concise. Records Management staff can help you articulate your agency’s subfunctions using a controlled vocabulary.

Common subfunctions include:

  • Educating
  • Enforcing
  • Investigating Complaints & Violations
  • Licensing
  • Promoting Public Awareness
  • Promulgating Rules & Regulations
  • Providing Services

Note: “Administering Internal Operations” is common to every RDA and includes records that all agencies produce. This subsection should not be altered.

Each subfunction title should be followed by a thorough description of the subfunction. These descriptions may include legislation that assigns or authorizes the agency to engage in a subfunction, the activities encompassed by the subfunction, and the procedures followed in pursuance of the subfunction. These descriptions provide context for Section 2, which describes the record types within each subfunction.

Section 2: Records Appraisal

This section consists of descriptions of all permanent records and select temporary records.

Temporary records should be listed and described if they require explanation in order to be understood clearly by agency staff and State Records Commissioners.

The section is divided into (1) temporary records descriptions, (2) permanent records descriptions, and (3) the permanent record list. Records are ordered by subfunction in the same order in which they appear in Section 3.

Descriptions may include the following, if appropriate:

  • Scope of materials included in the record series
  • Format of record series

Additionally, descriptions must include the following:

  • Description of record series
  • Retention/disposition requirement
  • For temporary records, a justification for the retention/disposition requirement
  • For permanent records, an explanation of how/why the record series is deemed historically significant, citing statute if appropriate

Note: ADAH staff will provide the “Bibliographic Titles” appearing at the end of each permanent record description.

If your agency no longer produces a record series in the RDA, the series should be listed in a subsection entitled “Records No Longer Created” so that the Commission knows why they are no longer present. 

The “Permanent Records List” at the end of Section 2 is a one-page list of all the permanent records created by the agency. Records are ordered by subfunction in the same order in which they appear in Section 3. Asterisks indicate permanent records that the agency will maintain on-site.

Many currently approved RDAs include the subsection “Agency Recordkeeping System” within Section 2. This subsection describes the agency’s paper and electronic filing practices. While this information is still necessary, Records Management staff will withdraw this subsection into a separate but joint document in order to protect the agency’s security and assets. The “Agency Recordkeeping System” will not be published online.

Section 3: Records Disposition Authority

This section provides retention periods for every record series, whether temporary or permanent. Permanent series are in all caps.

The retention requirement for each temporary record series depends on a variety of factors, including legislative and audit requirements and the record series’ foreseeable administrative and historical value. Records Management staff can provide guidance on a reasonable retention requirement.

Common language for temporary record retention requirements includes:

  • Retain [x] years.
  • Retain[x] years after [y]. 
  • Retain [x] years after the end of the fiscal year in which [y].
  • Retain [x] years after audit.
  • Retain until superseded.

“Explanation of Records Requirements” and “Requirements and Recommendations for Implementing the RDA” are both standard to all RDAs.

See “An Overview of the State Agency Records Disposition Authority (RDA) Revision Process” for next steps:

  • Return RDA Working Draft to Records Management Staff
  • Agency Leadership Reviews Final Draft
  • The State Records Commission Approves the RDA Revision

Contact Us

The state agency RDA is a complex document. Please feel free to reach out to Records Management staff with any questions at any point during the revision process using the contact information below:

An Overview of the State Agency Records Disposition Authority (RDA) Revision Process

Previously, we discussed how to determine if your state agency Records Disposition Authority (RDA) needs revising:

Many state agency RDAs have not been revised since the late 1990s or early 2000s. They often lack key components and may no longer be consistent with records law and/or best practice. Records Management staff view RDA revision as an opportunity to conduct a holistic review of your currently approved RDA and create an updated document that better serves your agency.

Depending on your agency’s size and the state of its RDA, revision requires a considerable time commitment on the part of both agency staff and Records Management staff.

Read below for an overview of what to expect during the RDA revision process.

Agency Contacts the ADAH Records Management Staff

Agencies seeking an RDA revision should contact Records Management staff to schedule an in-person introductory meeting or conference call. This meeting/call will introduce the parties involved and help define the scope of the RDA revision before beginning work on either end. Please be mindful that due to the time required to revise an RDA and the high demand for revisions, Records Management staff may be unable to undertake your agency’s revision immediately.

Note: Your agency will not be placed on the schedule to present an RDA revision until you contact Records Management staff.

Contact one of the following staff members to discuss RDA revision:

Agency Uses “Track Changes” to Revise a Working RDA

Agencies with more than twenty employees are strongly encouraged to work on the revision by committee.

Records Management staff will send your agency representative(s) a copy of the currently approved RDA in Microsoft Word. The Microsoft Word copy of the RDA will contain notations indicating which sections may be revised and which sections contain standardized, inalterable language. Records Management staff will describe in detail what agency commentary is needed depending on the revision scope. Agency representative(s) will edit the document using Microsoft Word’s “Track Changes” feature.

Agency Returns RDA Working Draft to Records Management Staff

Once you return the edited Microsoft Word copy of the RDA, Records Management staff will independently research trends, best practices, and developments in your agency’s field or industry to supplement suggested revisions.

Agency Leadership Reviews Final Draft

Records Management staff will provide a timeline for your agency’s leadership to conduct a final review of the revised RDA and will work collaboratively to produce a final draft is satisfactory to all parties.

The ADAH Director and State Records Commission chairman, Mr. Steve Murray, will review the final draft in advance of the State Records Commission meeting.

The State Records Commission Approves the RDA Revision

Records Management staff will present the RDA revision to the State Records Commission. While not required, agency representative(s) are requested to attend the meeting to clarify any questions which Commissioners may ask.

The Commission meets twice a year on the fourth Wednesday of April and October. Meetings are planned up to one and a half years in advance and cannot be rescheduled.

Agency Leadership and State Records Commission Chairman Sign the RDA

Following approval by the State Records Commission, both Mr. Steve Murray and the designated agency representative (usually a director or commissioner) must sign the RDA on its signature page.

The agency will retain one copy of a signed RDA on file, while the ADAH will retain another signed copy. The new RDA will be made available on the ADAH website. 

Agency Uses the Approved RDA

The agency uses the approved RDA to manage information, preserve permanent records, and dispose of temporary records that have met their designated retention requirements.

Agency officials may destroy records after satisfying the retention requirements set forth in the RDA, presuming no litigation or other hold is placed upon the records. They must document the destruction of both paper and electronic records.

Each state agency is required to submit an Annual RDA Implementation Report to the ADAH every year on January 15 for the previous fiscal year documenting records management, records destruction activities, and permanent records activities.

Coming Up

Stay tuned to the For the Record blog for a third and final post on the state agency RDA revision process:

  • A Detailed Guide to the State Agency Records Disposition Authority (RDA) Revision Process

Records Disposition Authority: Roadmap for Records Retention

Do you ever wonder why some records are kept for just a couple of years, while other records are kept for decades or even forever? Do you know where to find how long different types must be maintained? Let’s discuss a document that serves as a roadmap for state and local government records retention: the Records Disposition Authority (RDA).

An RDA is designed to help state and local governments manage their records more efficiently by identifying how long specific records should be kept, when records can be destroyed, and which records should be preserved permanently.

The Code of Alabama 1975 mandates that no state, county, municipal or other public official shall cause any state or local government records to be destroyed without first obtaining approval of the State and/ or Local Government Records Commissions (Code of Alabama 1975 § 41-13-21 through 23).

Public officials include not only elected officials, but any employees whose salaries are paid in whole or in part by Alabama taxpayers. The definition references the Code of Alabama 1975 § 36-12-1, which defines the phrase “public officer or servant” as, “in addition to the ordinary public offices, departments, commissions, bureaus and boards of the state and the public officers and servants of counties and municipalities, all persons whatsoever occupying positions in state institutions.”

Public officials from state agencies must obtain approval for records destruction from the State Records Commission, while public officials from local government agencies obtain approval from the Local Government Records Commission (Code of Alabama 1975 § 41-13-21 through 23).

In practice, authorization from the Commissions is provided in the form of retention schedules, called Records Disposition Authorities (RDAs). The RDAs describe the “disposition” of records (temporary or permanent) and stipulate minimum retentions of record types (ex. routine accounting records) after which destruction is authorized to take place.

Permanent records as identified in the RDA (ex. meeting minutes, annual reports) cannot be destroyed and must be preserved in perpetuity. State agencies may transmit permanent records which are no longer regularly referenced to the Alabama Department of Archives and History (ADAH) for permanent preservation. Local government agencies are generally responsible for maintaining permanent records in their communities to provide greater access among citizens.

Temporary records as identified in the RDA may be destroyed once their minimum retention periods have passed. State agencies may destroy temporary records without requesting preapproval from the Alabama Department of Archives and History; however, records liaisons must submit logs of records destroyed in the previous fiscal year as part of the Annual RDA Implementation Report.

Local government agencies must request preapproval from the Alabama Department of Archives and History each time records are to be destroyed. Destruction can only proceed once an agency has received a Letter of Eligibility authorizing destruction of the records. Our next blog entry will describe the Local Government Records Destruction Notice Process in more detail.

Records management staff have worked over the past twenty years to develop approximately 175 State Agency RDAs and 15 Local Government RDAs. State agency RDAs are highly specific and describe the records produced by a single agency in significant detail. Local government agency RDAs describe “classes” of local government organizations, such as “Law Enforcement Agencies” and “Municipalities.”

The RDA serves as the foundation of a records management program that helps state and local governments comply with state records laws, meet operational goals and objectives, document financial decisions and expenditures adequately, and promote transparency in government.

If your agency does not have an RDA, you should contact us at becky.hebert@archives.alabama.gov to start this process.

 

You Don’t Need to Keep It All: Start Decluttering Your Email

To the phrase “You don’t need to keep it all,” I often receive this common response: “I would need to hire an assistant full-time just to manage my email.” While storage may be relatively cheap, think about how long it takes your search engine to find an email among twenty thousand messages. The value of information lies in its accessibility.

How do you begin to declutter your email account? Start by deleting transient emails defined by records that are not essential in documenting agency activities. We previously discussed deleting unsolicited SPAM, distributed messages such as reminders about getting your flu shot, and reference copies in “First Steps to Better Email Management.”

Another example of types of emails that require no documentation for destruction include listserv messages. Set up rules to automatically sort these messages into a separate folder. Also, unsubscribe from groups or even promotional emails that you do not need.

Other types of email easily identified for deletion without documentation include transient records such as accepted/declined meeting requests and read receipts. Even items such as meeting arrangements can be placed in the calendar with the back and forth coordination emails being deleted.

To start finding these types of messages, arrange your emails by “from” which will allow you to select groups of emails and delete them with one click of a button. By arranging your account by sender, you can identify those individuals who do not send email related to the day-to-day operation of government. Some users only send you messages such as “Are you ready for lunch?” Delete emails from these senders in batches.

Email management is not saving all email forever. Spend as little as fifteen minutes every day before or after lunch. Deleting transient emails will help you identify those messages that document your important work in government and will build your confidence as you take additional steps to declutter your account.