Records Management Program Procedures

7 Records management compliance

7.1 COMPLIANCE

Records management compliance means adherence to the records management policies of the university and the rules and guidance set forth within the university records retention schedule. Policies may be found on the website for the Office of General Counsel. It is the responsibility of all university personnel to understand and follow these policies.

Measurement of compliance with the records management policies of the university and the university records retention schedule is measured through the use of audits. The idea here is not necessarily to set up punitive situations, but rather to understand how units work with these structures and ways to make that work more efficient, secure, cost-effective, and beneficial to the university as a whole. Legal and regulatory requirements should be included within the records retention schedule beforehand, so compliance with the schedule is interpreted to mean compliance with those requirements. Other university units – in particular the Office of General Counsel, Internal Audit, and the Research Office – also may choose to apply additional metrics to measure recordkeeping compliance for specific areas of concern as may be appropriate; this may occur within or outside the UARM records management audit process.

7.2 AUDITS

Formerly, records management audits were conducted by UARM staff on an annual basis. Audits now are conducted on an ad hoc basis. Audits are intended to measure compliance with the unit’s records retention schedule and to discuss any modifications to that schedule that may be necessary.

When a unit is scheduled for a records management audit, it will be notified in writing sixty days prior to the intended date of the audit. A UARM staff member will meet with the unit’s records management contact and any other unit staff believed necessary to participate in the audit, especially for large units where recordkeeping activities are distributed among a number of personnel. The UARM representative will review the applicable records retention schedule and assess the unit’s responses for compliance with that schedule. If changes or modifications are necessary to the schedule, they may be discussed during the audit; however, it is not required that those actions be confined only to the audit process. Outstanding destruction and release memoranda also will be reviewed.

Compliance information may be supplied to university administration as needed or appropriate.