Section 4: General Practices for Managing Electronic Records
Anchor: #i1036476Official Records Versus Non-Records
An important records management practice is to determine what is an official record versus a non-record, such as drafts or convenience copies. It is a vital principle to understand the difference and to identify electronic content in concert with a file plan.
Anchor: #i1036491Electronic Official Records
Per Section Government Code Chapter 441 “Title 4. Executive Branch, Subtitle D. History, Culture, and Education, Subchapter A, Texas State Library and Archives Commission”. Electronic Official Records:
- Anchor: #IFPBISPV
- Any state record may be created or stored electronically in accordance with standards and procedures adopted as administrative rules of the commission. Anchor: #YXWFKWAH
- Certified output from electronically digitized images or other electronic data compilations created and stored in accordance with the rules of the commission shall be accepted as original state records by any court or administrative agency of this state unless barred by a federal law, regulation, or rule of court. Anchor: #FQQNGSPV
- Certified output from electronically digitized images or other data compilations created before September 1, 1997, in accordance with any applicable prior law shall be accepted as original state records or, in the absence of an applicable prior law, at the discretion of the court or administrative agency.
Official records may be created and maintained electronically without ever being produced in hard copy. It is important to determine the final content of the official electronic record and to institute procedures to dispose of working copies, drafts, and duplicates when the final official record is complete. Because of the ease with which electronic records can be copied and shared, the presence of convenience copies represents a vulnerability to the agency.
Official records that are kept electronically are to be retained for the required retention period in a secure manner that prevents the alteration of the record in its original form with supporting metadata.
Anchor: #i1036541Non-Records (Drafts and Convenience Copies)
CAUTION: Convenience or “information” copies are duplicates of an official record. They are not subject to retention requirements and may be destroyed without formality when they are no longer needed. Convenience copies retained beyond the retention period approved for the official record may become the official record by default and remain subject to legal and open records demands.
Anchor: #i1036560Retaining Electronic Records
Chapter 9, File Management discusses procedures for managing files in all media. It is not recommended to use local shared drives or desktop workstations to retain official records as this practice exposes records to potential loss when employees leave, or when equipment or software is upgraded.
An Enterprise Content Management (ECM) system or other systems of records are the preferred medium for retaining electronic records. OnBase is an Enterprise Content Management system that provides records retention functionality.
It is important to document the records management procedures for all official records regardless of the media (electronic/physical) in written standard operating procedures.
Anchor: #i1036585Using Offline Media
Portable offline media such as external hard drives, USBs, flash drives, memory sticks/cards, PC Cards, CDs, DVDs, Blue Rays, M-Discs, or magnetic tapes should only be used to retain records that have a short retention requirement, as equipment or software replacements may render the media obsolete or unusable. File Plans should reflect offline media storage devices maintained and their locations.
It is recommended that offline media be organized by record series (or closely related) that have the same destruction date. Records Custodians should have access to offline media. Routine back up media is not an acceptable process for retaining official records. Official records being retained on portable media for retention are to be kept on that media dedicated to that purpose only.
Electronic storage media must have an external label or an index that includes:
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- Name or other identifier of the organizational unit responsible for the records. Anchor: #VWMXSSRO
- Descriptive title of the contents. Anchor: #APKJTUDP
- Dates of creation and authorized disposition date. Anchor: #EYFQLGCD
- Security classification. Anchor: #IEMRDIUO
- Identification of the software (to include specific application if appropriate) and hardware used. Anchor: #STNECOTU
- Operating system title and version.
Maintaining Offline Media
No storage media will last forever. Lifespan depends on environmental factors, usage rates, wear and tear, component quality, and manufacturing of the device. Below are the data storage lifespans for specific media types.
|
External Device |
Life Expectancy Optimum Environmental Conditions |
|---|---|
|
CDs, DVDs |
Between 2 and 5 Years |
|
Blue Rays |
Between 5 and 10 Years |
|
M-Discs |
Too new to be determined, but > CDs/DVDs/Blue Rays |
|
Hard Drives |
Between 3-5 Years |
|
Magnetic Tape |
10 – 20 Years |
|
Other Flash Storage (USB, SD Cards, Solid State Devices) |
Memory does not degrade because of age, but rather the number of write cycles. |
Offices retaining electronic official records must establish a routine schedule for recopying records maintained on offline media periodically to ensure that no information is lost.
- Anchor: #FWTMBBXP
- Official records on more durable media should be inspected and recopied on a regular interval if they are retained for more than two years or if the media is frequently used to access the records. Most department records have a retention period shorter than five years. Anchor: #EPNKVUVU
- Offices maintaining electronic records on offline media must have a migration strategy in place to ensure the availability, integrity, and usability of the electronic records across hardware and software changes until the expiration of its retention period. Anchor: #IOFDEGMK
- Keep electronic media away from sources of electromagnetic radiation such as magnets and motors. Anchor: #MVINKESP
- Protect external data stored from environmental factors. Keep USBs, flash drives, memory sticks/cards, PC Cards, CDs, DVDs, Blue Ray, M-Disc, or magnetic tapes in a clean space with dust protection and out of direct sun-light. Avoid touching the surface of storage media; skin oils can interfere with their ability to store data. Anchor: #MPBFHRTJ
- Maintain proper temperature and humidity. A climate-controlled office environment usually suffices. Ideally, magnetic tapes should be kept in 65°F to 75°F temperature and 30% to 50% relative humidity. Optical data storage media (Platters, CDs, DVDs, Blue Rays and M-Discs) are more environmentally tolerant, requiring 14°F to 122°F temperature and 10% to 90% relative humidity.
Department offices retaining official records are subject to Texas Administrative Code 13TAC§6.94 “Minimum Requirements for all Electronic State Records” describes specific standards and procedures related to the maintenance of storage media for electronic records, and data tape libraries, storage facilities, and standards for optical media used to store electronic records as digital images.
Anchor: #i1036819Protecting Record Integrity
It is essential to ensure that official records are not changed, damaged, or destroyed before their retention period has expired. Extra care is necessary when relying on an electronic record keeping system. Electronic records must be maintained in a usable format until their authorized disposal date and must be secured from inadvertent alteration or deletion.
Steps for protecting record integrity include the following:
- Anchor: #VHXUWSNT
- Identifying the Office of Primary Responsibility for specific electronic records. Anchor: #WNDOBXPE
- Limiting the official records to only those who require access. Anchor: #BCWRVNBN
- Identifying the level of access required for the records (read-only, modify or full rights) will protect the integrity of the record.