Virginia Public Records Management Manual

Contents

1. Introduction
2. File Management
3. Records Emergency and Recovery Planning
4. Records Retention and Disposition Schedules
5. Records Surveys
6. Electronic Records
7. Reformatting Records
8. Records Destruction
9. Records Preservation
10. Records Storage
11. The State Records Center (SRC)
12. Archives Transfer Procedures
13. Microform Transfer Procedures
14. The Role of Government Records Services at the Library of Virginia
15. Records Audits

1. Welcome and Introduction

Welcome to the Virginia Public Records Management Manual!

This page will guide government employees, particularly Records Officers designated for each agency or locality on how to appropriately identify, store, manage, and dispose of public records. This guide makes certain assumptions that the reader is a public employee of the Commonwealth and has some basic familiarity with the records of their office; however, no specialized knowledge of records management is presumed. If you are a citizen of the Commonwealth or a curious resident of another state, please understand that this is meant to inform Virginia's government employees on generalized best practices for records management. It may not accurately describe individual practices for a given agency.

If you have any questions about records management matters, you should contact your assigned records management analyst at the Library of Virginia. Our staff is here to help you!

Authority

The Virginia Public Records Act (VPRA) § 42.1-76 et seq. "…establishes a single body of law applicable to all public officers and employees to ensure that the procedures used to manage and preserve public records will be uniform throughout the commonwealth." § 42.1-79 vests the authority for records management in the Library of Virginia.

A records management program is implemented to:

• Ensure government actions are documented.
• Allow for open and public access to information for appropriate periods of time, while still safeguarding privacy and confidentiality.
• Enable citizens to judge the conduct of the government by providing administrative, fiscal, and legal accountability.
• Provide authority for public agencies to destroy records which no longer have active value.

Following sound records management practices is good business. Appropriately documenting the activities of public agencies is a keystone of transparent and accountable government.

In addition to the VPRA, the following statutes relate to public records management:

• Freedom of Information Act (FOIA) § 2.2-3700 et seq.
• Government Data Collection and Dissemination Practices Act § 2.2-3800 et seq.
• Copies of Originals as Evidence § 8.01-391

Records Management Objectives

Records management is the economical and effective administrative process for managing information and ensuring access throughout its life cycle, from creation through active primary use, possible secondary uses, and ultimately to final disposition: destruction or, for a small percentage of records with permanent legal or historical value, archival preservation.

To create and maintain an effective records management program, each government entity must:

• Designate at least one records officer through submission of the Records Officer Designation and Responsibilities (RM-25 Form).
• Follow Library of Virginia–approved records retention and disposition schedules, and aid in the creation and revision of same when needed.
• Develop records management policies and procedures.
• Implement filing, indexing, and security systems so that records are accessible by appropriate staff, protected against unauthorized access, and/or retrievable for FOIA, discovery, or audit as necessary.
• Develop a records emergency response plan to protect and recover all records.
• Identify and protect essential records.
• Identify and preserve permanent records.
• Store inactive records in a cost-effective and secure location.
• Destroy nonpermanent records at the end of their retention period and document that destruction through submission of a Certificate of Records Destruction (RM-3 Form).
  • If nonpermanent records are stored at the State Records Center (SRC), use the SRC RM-3 Form.

Benefits

An effective records management program will:

• Identify and protect essential records.
• Improve transparency of government.
• Optimize use of storage space and reduce liability by destroying records that have reached the end of their retention.
• Increase the efficiency of office operations through faster, more secure, and more accurate access to records.

What Is a Public Record?

The VPRA defines a public record as:

...information that documents a transaction or activity by or with any public officer, agency or employee of an agency. Regardless of physical form or characteristic, the recorded information is a public record if it is produced, collected, received or retained in pursuance of law or in connection with the transaction of public business. The medium upon which such information is recorded has no bearing on the determination of whether the recording is a public record.

Code of Virginia § 42.1-77

Public records, except for those exempt under the Virginia Freedom of Information Act (FOIA), must be available for access throughout their retention periods per Code of Virginia § 2.2-3700 et seq. A record that is considered FOIA-exempt is not exempt from the requirements of the VPRA. Records containing confidential information are still public records.

Designating a Records Officer

The VPRA § 42.1-85 states that each agency and political subdivision "shall designate as many as appropriate, but at least one, records officer to serve as a liaison to the Library of Virginia for the purposes of implementing and overseeing a records management program, and coordinating legal disposition, including destruction of obsolete records."

The person or persons who will serve as records officer(s) is officially assigned by mailing or emailing the Records Officer Designation and Responsibilities (RM-25 Form) to your assigned records management analyst.

The designated records officer (RO) acts as the liaison between the Library of Virginia and the agency for records management purposes. The RO should have the support of senior/executive management and should retain a position of influence within the agency or locality. The duties of the RO will require a substantial time commitment.

The employee designated as RO must have the time and the ability to:

• Manage an agency-wide records management program to include the storage, retrieval, retention, and disposition of public records, regardless of format.
• Create agency-specific procedures which provide direction on complying with these mandated records management functions, and regularly educate staff on these procedures.
• Identify essential and archival records and ensure that those records are properly maintained, protected, and accessible.
• Coordinate the development of a records emergency response plan for the protection/recovery of records in the event of a disaster.
• Maintain contact with our records analysis staff to ensure that their retention schedules and policies are appropriate and up to date.

These responsibilities must be clearly outlined and reflected in the records officer’s job description or employee work profile, and sufficient time in their established work schedule should be devoted to fulfilling these responsibilities.

Starting and Maintaining a Successful Records Management Program

Follow these steps to establish and maintain a successful records management program:

1.) Identify and establish a records management team.

Identify the person(s) who will serve as records officer (RO) and lead the records management program. Complete the Records Officer Designation and Responsibilities (RM-25 Form) and submit it to the Records Analysis Section (RAS) at the Library of Virginia. Have senior management display support by announcing this appointment to all staff. Management should send a clear message that cooperation and compliance are expected from everyone.

Selecting records coordinators may be helpful for larger agencies or localities. These coordinators act as liaisons to divisions within the organization and aid the RO, and are internal appointments with no paperwork necessary. If someone on staff needs to enter boxes into ShelfLife for storage at the State Records Center (SRC), then a Records Technician Access Authorization (RM-26 Form) must be submitted formally designating that person as an authorized ShelfLife user.

2.) Develop records management policies and procedures.

Develop records management policies and procedures specific to the organization and disseminate them to staff along with references to online Library-approved retention schedules. Adherence to internal policies and procedures fosters accountability, credibility, and consistency within a records management program. To aid ROs with this task, we provide information on creating records management policy and procedures. Included are a policy template and guidance for developing procedures.

3.) Train staff members on records management practices.

Regularly educate and train fellow employees. Keeping to a regular schedule to train new staff and refresh the memories of existing staff is critical to keeping the agency as a whole educated and in compliance. We provide a variety of educational resources on the Records Management website, including a resources page dedicated to topics such as social media, records destruction, and how to use the Virginia Records Officer Listserv (VA-ROL). Also available are Digital Imaging Guidelines, Email Management Guidelines, and Electronic Records Guidelines. We also maintain a YouTube channel devoted to training videos on topics such as the Virginia Public Records Act, transferring archival records, and filling out the Certificate of Records Destruction (RM-3 Form).

4.) Create a records disaster plan.

Create and distribute a disaster/emergency plan for protecting and preserving records. We provide access to the Intergovernmental Preparedness for Essential Records (IPER) Project. The IPER coursework is designed to help prepare state and local governments to protect records before, during, and after disasters and other emergencies and aid in the creation of a response plan.

5.) Review your program.

Conduct regular reviews of retention schedules and your records management program, including a disaster/emergency plan critique. If necessary, contact the Records Analysis Section to update retention schedules or transfer records to the State Records Center or Archives.

Our records analysts are available to provide in-person and virtual records management training to agencies and localities. A minimum of 25 participants is required for a records management analyst to travel for an in-person training. In-person trainings must be scheduled well in advance of an analyst's arrival. Contact your agency’s assigned records management analyst for more information about training.

Delivery of Records to Successor

At the end of a records custodian's term of office, appointment, or employment, all records should be turned over to his/her successor. In the event that there is no successor, such as when an agency ceases to exist by an act of the General Assembly, all records should be transferred to the Library of Virginia per Code of Virginia § 42.1-88.

2. File Management

File management is the process of determining how files will be arranged, categorized, accessed, and stored in all formats. All files should have some form of arrangement, regardless of their format. This includes records in paper, digital, and electronic formats. Good file management requires consistency, simplicity, and flexibility. When developing a filing system, you should involve individuals who work directly with those records to ensure everyone is on the same page. Once developed, you should create policies and procedures for the filing system and file management practices and schedule regular training sessions with staff members.

Engaging in file management allows you to:

• Have a systematic approach to managing your records.
• Implement cost-effective practices to store and retrieve records.
• Decrease time to identify records for disposal and retrieval.
• Better control of records with special security or access requirements.
• Reduce or eliminate recordkeeping redundancy.

When developing a filing system, all record types and their locations should be identified, which includes addressing electronic management systems and network drives being used to store records. Policies and procedures created for file management should be incorporated into your broader records management policy.

Filing Practices

You should attempt to make filing practices applicable across all formats. If your office maintains both paper and electronic systems, we recommend using the same filing schemes for all records that belong to the same records series.

The most common arrangement methods are alphabetical, numerical, or alphanumeric. The file arrangement should be based on how the records will be retrieved and the cutoff specified in the records retention and disposition schedule for that particular series.

Alphabetical Filing

There are two types of alphabetical filing:

1. Topical filing arranges files in straight alphabetical order, such as subject correspondence arranged from A to Z, based on the name of the subject.
2. Classified filing arranges related documents under a major subheading, such as customer-complaint correspondence filed under the general heading of customer relations.

Advantages of alphabetical filing:

• Avoids the need for an index.
• Simple filing and easy browsing.

Disadvantages of alphabetical filing:

• Increased risk of misfiling.
• Retrieval problems due to name changes.
• Increased inefficiency with large systems.
• Ease with which unauthorized persons can locate records.

Numerical Filing

Numerical filing typically looks like filing records by file number, Social Security number, date, or patient or case number.

Advantages of numerical filing include:

• Quicker comprehension of numerical sequences over alphabetical.
• Ability to add new files without disturbing existing arrangement.
• Easy identification of misfiled or out-of-sequence numbers.

Disadvantages of numerical filing are:

• Necessity of an index since it is an indirect arrangement.
• Possibility of transposing numbers when files are created.

Alphanumeric Filing

An alphanumeric arrangement uses a combination of numeric digits and letters to create a flexible filing system. An index is required to use the system effectively.

Subjects may be substituted by using alphabetical or numerical codes, such as ADM-001 (Administrative Files, Director’s Correspondence) and ADM-002 (Administrative Files, Assistant Director’s correspondence).

Advantages of alphanumerical filing:

• Eliminates the need for long titles.
• Use of code system increases file security.

Disadvantages of alphanumerical filing:

• Necessity of an index.
• Must train users on how to use the codes and index.

Network Drives

Files on network drives must be managed according to established filing schemes just like paper records. Logical folder hierarchies and appropriate naming conventions for electronic files must be established and used consistently. Creating folders based on series found on the records retention and disposition schedules will help with file retrieval and disposal.

Filing Cutoffs

The file cutoff is a break or stop in the filing of a current records series, based on a predetermined date or event. To simplify storage and purging, filing schemes should be chosen based on which type of cutoff is stated on an approved records retention and disposition schedule.

Date Cutoffs are specified dates after which a new group of file folders is created for the same series. The file cutoff date keeps records of the same time frame together. Many state agencies and localities use the end of the fiscal or calendar year as a cutoff date. Colleges and universities may use the end of the academic year.

Event Cutoffs result in "continuous filing". Some files cannot be cut off by date. Instead, individual files are removed from the series after a specified event.

Indexes

An index is a list used to determine file location. Alphanumeric and numeric systems may require an index, but alphabetical systems do not. Most indexes have headings and subheadings listed alphabetically. The heading is the main class or title of records and the subheading lists records that are derived from or related to the main heading.

Tracking Paper Files

When a paper file is retrieved, a charge-out card should be inserted in the location where the file was removed. This can be as simple as using a folder or another noticeably large paper product as your placeholder. Automated tracking systems, with the use of barcode wands, can expedite the check-in and check-out process for large filing systems, and can generate reports that show what files were requested and by whom.

File Plans

To improve your organization of and control over your records, we encourage you to create a file plan for your office. A file plan is a targeted document that specifies the records created and managed within an agency. As our retention and disposition schedules can be broad, it’s a good idea to create a file plan to show links between an office's records and the schedules.

Designing a File Plan

A good file plan will provide an overview of all records kept by a particular agency or a specific department, division, or office. A file plan can be useful in identifying the retention schedules and/or records series that are used within your office.

1. Conduct a records inventory.
   • In order to create a file plan, you must know what records are created and maintained within your office/agency.
   • The inventory will identify how the files are named and filed.
   • Refer to Chapter 5, Records Inventory and Records Survey, to learn more about facilitating an inventory of your records.
2. Organize records based on the our retention and disposition schedules.
   • Create a spreadsheet with the following elements:
     • Record Name
     • Description of Record
     • Location
     • Format Type
     • Point of Contact (optional)
     • Retention Schedule Name and #
     • Record Series Name and #
     • Retention Period
     • Confidential or Non-Confidential Disposition
3. Periodically update the file plan.
   • Our retention schedules can change periodically throughout the year.
   • Assess and update your agency’s file plan based on any updates made to the retention schedules your agency uses.

Tip: In your file plan, have a tab that provides clarity or a further explanation of the records series descriptions.

3. Records Emergency and Recovery Planning

Responsibilities for Planning

It is each government entity's responsibility to develop a records emergency plan, also known as a disaster plan, to use in the event of a disaster or other emergency. Records emergencies do not always rise to the level of “disasters”, and are not always weather-related. They can range from leaking pipes or a small mold outbreak to a hurricane or building-wide fire. Generally, records emergencies include anything that would interrupt business processes or the facility's structural instability.

When planning for a records emergency, you should first assess potential disasters that could impact your office, giving more consideration to common natural disasters in your area. For example, if your region is prone to flooding, your emergency efforts should have include detailed methods for handling this type of disaster.

In addition to creating a natural disaster assessment, you should conduct routine evaluations of records storage spaces. Physical storage spaces are encouraged to be observed to identify signs of damage including leakages and pest infestations. By taking a systematic approach to plan for records emergencies, you'll cut down on recovery time.

We encourage a proactive approach towards managing your records and recommend developing and maintaining a Continuity of Operations Plan (COOP) and a Records Emergency Action Plan (REAP). Further guidance on developing these plans are provided below.

Continuity of Operations Plan (COOP)

The federal government and the Commonwealth of Virginia both use an emergency preparedness tool known as the Commonwealth of Virginia Emergency Operations Plan (COVEOP). Executive Order 41 (2019), requires each state agency to implement a COOP to assist in handling disasters and emergencies. The Virginia Department of Emergency Management (VDEM) is responsible for providing information and tools for plan preparation and execution. Resources for local and regional entities are also available on the VDEM website. Records officers and managers need to know whether their agency has a COOP in place and which officials in their agency are responsible for producing and maintaining it. COOPs contain some, but not all, of the same information needed in a Records Emergency Action Plan (REAP), so working with COOP coordinators can greatly reduce redundancy.

Records Emergency Action Plan (REAP)

A COOP must be accompanied by a Records Emergency Action Plan (REAP) that is devoted to the protection and recovery of all records. A COOP and a REAP overlap in the protection of your essential records. Developing and practicing a REAP reduces the possibility that personnel will feel overwhelmed or unprepared if a disaster occurs.

The REAP should:

• List contact information for all personnel, commercial disaster recovery vendors, and emergency services.
• Detail instructions for minor and major weather-related disasters that may affect your geographic area, as well as man-made issues such as leaking pipes, arson, or structural instability.
• Prioritize records to be salvaged first, starting with those that are essential to continuing operations.
• Be disseminated and practiced with appropriate personnel on a regular basis.
• Be reviewed and updated yearly.

Identifying and Protecting Essential Records

A critical component of both a COOP and a REAP is an essential records template. Essential records are the records that an agency needs in order to fulfill its mission-critical functions. Much like an individual needs certain records to prove their identity or to conduct business, government offices also have records that are necessary to operate and to provide essential services. When essential records are lost or damaged, an agency may experience unplanned expenditures, lost revenue, lost information and efficiency, and disruption of operation, all of which can increase the potential for litigation.

Examples of essential records:

• COOP and REAP plans
• Personnel records
• Tax records
• Payroll records
• Active contracts
• Agency and departmental policies
• Emergency contact information
• Insurance records

Note: While some records, such as board minutes, are historically significant, they may not be considered essential for business continuity or to provide services to citizens.

Essential records are best protected through duplication and/or off-site storage. Duplication of information can involve photocopying, scanning, or microfilming information that may be needed to re-establish operations after a records emergency. Duplicate records should be stored away from the office, in another building, or out of the geographical area while remaining accessible in a timely manner. If your essential records are stored in the same place, you should take extra precautions to protect them. If an essential record is in an electronic format, then the hardware or software used to create the record must be protected or arrangements must be made to obtain compatible hardware and software in the event of a records emergency. Whenever original formats of essential records are updated, be sure to update the duplicate as well.

Your COOP and REAP should be reviewed and updated periodically to ensure all essential records are accounted for and information is up-to-date and accurate. In the review process, appropriate staff should be made aware of any proposed updates.

Responsibility for Recovery

Planning for records recovery is just as critical as preparing for records emergencies. When developing records recovery efforts in the agency’s REAP, the following components should be considered:

• Salvaging Records: Your REAP can document salvaging practices that will be performed internally in the event of an emergency. Explicit details can be listed for salvaging different record types such as paper, photographs, and books. Additionally, you can use a vendor to provide salvaging services. We recommend that you identify a vendor(s) that will provide appropriate aid in recovery efforts. Carefully consider the types of records you produce and the recovery options offered by vendors.
  • Tip: Build a rapport with the potential vendor(s) to verify if their services are appropriate. Consult with others in your field to gain better insight into the vendor’s services.
• Conservation: Finding a qualified conservator to evaluate the severity of your records disaster can greatly improve recovery time. A conservator can provide suggestions based on best practices to salvage your damaged records.

For additional guidance on creating a template for identifying essential records, complete the Essential Records Course.

4. Records Retention and Disposition Schedules

Records retention and disposition schedules, also called “retention schedules” or “schedules”, are the Library of Virginia–approved documents which list descriptions of records that are grouped by common function, the length of time they must be kept, and the required method of destruction. Retention schedules reflect the length of time that records have historical, administrative, legal, or fiscal value.

When creating a retention schedule, participants review records' use and informational value and research regulations that may govern retention. The Virginia Public Records Act (VPRA) authorizes the Library of Virginia, through the Records Analysis Services (RAS) Section, to produce retention schedules that govern the records of all state agencies, localities, and regional entities. The creation and updating of retention schedules are done in collaboration with designated records officers and appropriate records management staff.

A retention schedule establishes a systematic method of controlling a record from its creation to its final disposition. Retention schedules are not merely suggestions. Records cannot be destroyed before the stated period, nor can they be retained longer than the stated period unless they are involved in an investigation, litigation, audit, or request for records pursuant to the Virginia Freedom of Information Act (FOIA). For records containing personally identifiable information (PII) created after July 1, 2006, Virginia law requires they be destroyed within six months of their retention's expiration. All government offices must follow the approved schedules. If the schedules are not followed, you risk violating the Code of Virginia § 42.1-86.1.

Following the state's records retention and disposition schedules is the most important part of a records management plan. Retention schedules should be reviewed regularly to ensure that they remain complete and accurate. Questions and concerns about retention schedules should be directed to your assigned records management analyst.

Benefits of a Retention Schedule

By following a retention schedule, you:

• Ensure that you're complying with the Virginia Public Records Act (VPRA).
• Ensure records that are needed for legal, fiscal, or administrative purposes will not be destroyed prematurely.
• Ensure that you are legally destroying records that are no longer useful.
• Reduce storage space and save costs by retaining only records that are identified as useful.
• Understand when records may be destroyed, transferred to inactive storage, or transferred to permanent storage.
• Ensure the preservation of records with historical value.
• Make reformatting decisions more easily.
• Gain information for an essential records protection plan.
• Understand the privacy status of a given records series.

Creating and Updating General Schedules

General schedules (GS) describe records that all government entities have in common, such as fiscal, administrative, and personnel records. Most agency and locality records will be covered under the general schedules. General schedules are reviewed regularly and all updates are announced on the Virginia Records Officer Listserv (VA-ROL).

Below is the process for creating and revising a general schedule:

1. Call for a Focus Group
   • We will first call for focus group volunteers on the Virginia Records Officer Listserv (VA-ROL). This focus group is led by a records management analyst, who gathers and coordinates the group. The group is responsible for reviewing the current schedule (if one exists), and noting any needed changes, additions, and deletions.
   • If creating a new schedule, the focus group is responsible for researching current needs, including government legislative codes, and offering new series for inclusion. Changes and additions are negotiated as necessary and inserted into subsequent drafts.
2. Collaboration and Review
   • A general schedule review may take several months and require multiple meetings as well as between-meeting email exchanges among the group. Participants are also expected to have between-meeting conversations with staff in their office so that they come prepared to answer questions and engage in meaningful conversations about the schedule at each focus group meeting.
3. Finalization
   • A final draft of the schedule will be made available for wider review on VA-ROL before it is submitted for approval.
   • The schedule is presented and approved by the Records Oversight Committee (ROC).
   • The approval of the schedule is announced via VA-ROL.

Creating and Updating Specific Schedules

A specific schedule applies to records that are unique to a particular state agency’s operations and are referred to as agency-specific schedules. The agency-specific schedules identify records that the agency produces, collects, receives, or retains in carrying out its special functions. Localities do not require specific schedules since record types created in one locality may also be created in any other locality.

A schedule that is more than 10 years old usually does not accurately reflect current business operations. State agencies should review their specific schedules annually and submit suggestions for changes, creation, and deletions to their assigned records management analyst.

Below is the process for creating and revising an agency-specific schedule:

1. Submission of a Records Survey
   • A Records Survey (RM-19 Form) is used to gather information on individual records series that should be listed on an agency-specific schedule in addition to making changes to an existing series on a specific schedule.
   • The agency is responsible for submitting the RM-19 Form to their assigned records management analyst.
2. Records Management Analyst Review and Composition of Draft
   • Once the records management analyst has reviewed the RM-19 Form, a draft of the retention schedule is composed based on the information provided.
   • The agency will review the draft for accuracy.
3. Finalization
   • The schedule is presented and approved by the Records Oversight Committee.
   • The approval of the schedule is announced to the state agency via email to the agency’s Records Officer and the submitter of the RM-19 Form.

Making the Schedule Legal

After the records management analyst completes or revises a retention schedule with assistance from the focus group (general schedules) or the submitter of the RM-19 Forms (specific schedules), it is reviewed by Library staff members through the Pre-Records Oversight Committee process (Pre-ROC).

Once the draft schedule is edited, pre-approved, and any resulting questions are answered, the final draft is put before the Records Oversight Committee (ROC) at the Library of Virginia. ROC members include the State Archivist, all records management analysts, as well as processing and public service archivists. Records officers with a vested interest in any schedule being presented at ROC are welcome to attend.

If the draft schedule is approved by ROC, the schedule will need to be signed by the necessary officials. General schedules must be signed by the State Archivist. Specific schedules must be signed by the agency head, the respective agency records officer, and the State Archivist. Once the appropriate signatures are obtained, the schedule becomes active and is the legal documentation for the retention and disposition of records.

Using the Retention Schedules

Always ensure that you are using the most recent version of a records retention and disposition schedule as retention schedules are updated regularly. To avoid using outdated and obsolete schedules, you should view the online, live versions available on the our website.

Helpful tips:

• Whenever possible, classify your records under an appropriate records series at the time of creation or filing.
• Avoid downloading and/or printing a retention schedule. Instead, bookmark the webpage of the list of schedules to your web browser.

Finding a Records Series

Searchable databases for locality general schedules and state general schedules are available to help you find records series. When using the databases, refer to the schedule with the series number of interest for the most accurate series description and retention information. The databases only provide a snippet from the series description while the schedule itself contains it in its entirety.

Records Oversight Committee (ROC) Meeting

The following list includes each item that appears on all our retention and disposition schedules:

• Signature of the State Archivist, indicating that the schedule is authorized
• Signatures of the Records Officer and Agency Head (specific schedules only)
• Schedule number
• Schedule title (general schedules only)
• Name of organization (specific schedules only)
• Name of department and sub-department, if appropriate (specific schedules only)
• Effective date
• Records series title
• Record series description
• Legal citations regarding retention requirements, if appropriate
• Retention period and cutoff event for each record series
• Method of records disposal or preservation for each records series

Currently, there are various schedule formats in use. The new formatted schedule separates the retention and disposition statements, while the old format combines them. An effort to convert all schedules to the new format is underway. All old format general and specific schedule updates must comply with the new format. No piecemeal updates of old-format schedules will occur.

5. Records Inventory and Records Survey

To establish an effective and comprehensive records management program, you must account for all records that are created and managed, and ensure that the records are included on a records retention and disposition schedule. You can do this using two data different collection tools: the Records Locator Inventory (RM-20 Form) and the Records Survey (RM-19 Form).

Records Inventory

The purpose of a records inventory or comprehensive survey is to identify and quantify all records created or maintained by your agency. The Records Locator Inventory (RM-20 Form) is used to collect information about your records including type, date range, format, volume, storage location, and applicable schedule and series numbers. The RM-20 Form should be used to inventory all documents, both records and non-records, regardless of format or location.

The inventory is not intended to be an individual folder or document-item list, but rather an examination of groups of similar or related records referred to as a records series. Staff familiar with the creation and maintenance of the records should complete the inventory form in conjunction with the designated records officer. The information gathered during the inventory process will assist in the creation of records management policies and procedures, the compilation of a list of essential records, and the identification of any records not currently covered by an existing retention and disposition schedule. The inventory has two versions: the RM-20 for Word and the RM-20 for Excel. The Excel version is more easily sorted.

Tip: The records officer should assign records liaisons for each department to take departmental inventories.

Records Survey (RM-19 Form) for State Agencies

State agencies can create specific retention schedules to cover records that only their agency produces, collects, receives, or maintains. During a records inventory, state agencies may identify records unique to their agency that are not currently covered by an existing general or agency-specific retention schedule.

To create, update, or revise a specific records retention and disposition schedule, a state agency must complete a Records Survey (RM-19 Form) that identifies and describes each series of public records it creates and maintains. The RM-19 Form is used to identify the purpose, function, contents, and format(s) of each series. In completing the form, records officers will also identify whether these are essential records, any restrictions on access, applicable laws and regulations, and a file cutoff event, as well as provide recommendations for retention and disposition.

The Records Survey Process

Records officers should contact their assigned records management analyst for advice prior to starting the records survey process and ensure they are using the most recent online version of the form. The form must be completed in Microsoft Word and submitted electronically. We highly recommend that one or two draft forms be submitted to an analyst for review and feedback before proceeding.

There are several ways to complete the RM-19 Form:

1. Records officers can complete the RM-19 Form in consultation with staff members who are familiar with the creation, maintenance, and use of the records.
2. Staff and records liaisons can complete the forms themselves after receiving training from the records officer.
3. You can use records management contractors which will visit each department, gather information about an office’s function and records, and complete the survey forms themselves. Note: These services can be costly.

For more information on the scheduling process, see Chapter 4 (Records Retention and Disposition Schedules).

Evaluating Records for the Records Survey

The retention period for records is based on the value of the information. When evaluating a records series to determine retention, consider the length of time records must be kept for administrative, fiscal, legal, and regulatory requirements, as well as historical purposes.

Retention considerations include:

• Administrative Value
  • These records are necessary for the day-to-day operations of an office, to conduct current or future business functions, or to document the establishment of policy or operations. Examples include correspondence, studies, and reports.
• Fiscal Value
  • These records document an office’s fiscal responsibilities, such as the receipt, payment, transfer, adjustment, or encumbrance of public funds. Most financial records usually lose value once an audit has been approved. Certain series may be governed by regulations beyond an audit, however, such as federal rules or contract language. Examples include invoices, receipts, and purchase orders.
• Legal Value
  • These records have a mandated retention by statute or regulation. Determine the legal value of records with assistance from legal counsel. Examples include leases, deeds, student records, medical records, and court case files.
• Historic Value
  • While only a small percentage of the volume of records in an organization have permanent value, those that do are especially significant as they document the history of the government or community; contain important information about persons, places, or events; or are valuable because of age or rarity, such as records of the 18th and 19th centuries. Examples include minutes, policies, agency histories, ordinances, land records, and annual reports.

6. Electronic Records

Although electronic records pose their own unique challenges, digital public records must be scheduled, maintained, and disposed of just like paper records. According to the Virginia Public Records Act (VPRA) in the Code of Virginia § 42.1-85, an agency must:

ensur[e] that its public records are preserved, maintained, and accessible throughout their lifecycle, including converting and migrating electronic records as often as necessary so that information is not lost due to hardware, software, or media obsolescence or deterioration.

You must ensure that you are able to find, open, and read all files over the lifetime of the record. Policies, practices, and systems for the management of electronic records must be fully integrated into existing records management programs. This chapter provides a brief overview on managing electronic records throughout their life cycle. More detailed guidance can be found in the Library of Virginia’s Electronic Records Guidelines (ERG).

Storage Media

While electronic records are often thought of as “less physical” than paper records, this is not necessarily the case. Storage media consist of the physical components on which data is stored. To determine which storage medium is best, start by analyzing the current and projected volume of stored records, along with any associated metadata. Also take into consideration data access and security requirements.

Online Storage

Records are available for immediate access and retrieval, and this option provides for the fastest access and regular integrity checks. Online storage devices include mainframe storage and online servers.

Off-line Storage

Records are stored on removable media such as external drives, magnetic tape, or individual optical disks. Because human intervention is necessary, this option provides the slowest access.

Nearline Storage

Records are stored on media such as optical disks in jukeboxes or tapes in automated libraries or using specialized server arrangements such as Storage Area Networks (SAN) or Networked Attached Storage (NAS). Nearline storage provides faster data access than off-line storage at a lower cost than online storage.

Storage Recommendations

We recommend online or nearline storage options for vital, long-term, or archival records. Public records should not be kept on desktop computers. All public records should be on network drives that are routinely backed up. The advantages of online and nearline storage include large storage capacities and the opportunity for data replication.

Off-line storage devices are not recommended for record copies of essential, long-term, or archival records, as they are less likely to be routinely accessed and are often overlooked when systems are upgraded, and electronic records are migrated to new formats. Off-line storage is a recommended approach for backups or security copies, as the records can be stored off-site.

All storage media have finite lifespans that are dependent on a number of factors, including manufacturing quality, age and condition before recording, handling, maintenance, frequency of access, and storage conditions. Before purchasing storage, evaluate the following:

• Cost: Consider not only the initial monetary outlay, but also the costs associated with maintaining the media as well as converting and migrating stored records.
• Expansion: Media should accommodate not only the current storage needs but allow for substantial growth.
• Longevity: Evaluate the media life span to determine how often migration/conversion will be necessary.
• Speed of access: Some types of records require quick access, while others do not.
• Stability: Assess the potential for damage and rate of expected deterioration.

File Formats

File format longevity is a central concern. Using an untried or uncommon file format is a gamble. At worst, the format becomes obsolete, and you are unable to access your records. At best, you’ll have to either convert or migrate your records earlier than anticipated. Ask yourself honestly: Are your records a bet you want to lose?

So, how do you tell what format your files are in? The software in which a file is created usually has a default format, often indicated by a file name suffix or extension. Proprietary file formats, such as PSD, WMV, and DOC are controlled and supported by just one software developer. Without that developer, those file formats become obsolete. It’s important to carefully evaluate which proprietary formats your office uses and to consider weighing the risks of using such software. How long have these formats been around? Is usage of the format widespread? What is the financial cost associated with accessing proprietary file formats?

Proprietary file formats aren’t the only formats in existence. Open file formats are supported by more than one developer and can be readily accessed by various software systems, and, as such, are the preferred method for long-term preservation and use of electronic records.

Examples include:

• ASCII: American Standard Code for Information Interchange captures data but loses structure.
• RTF: Rich-Text Format is ASCII with additional functionality that retains structure. It is a Microsoft format but is compatible with several word-processing programs.
• PDF: Portable Document Format “is a file format for representing documents in a manner independent of the application software, hardware, and operating system used to create them and of the output device on which they are to be displayed or printed.” It was created by Adobe, Inc., but became an open standard in 2008, published by the International Organization for Standardization as ISO 32000-1:2008. (Adobe Systems Incorporated, PDF Reference, Sixth edition, version 1.23, Nov 2006, p. 33.)
• PDF/A: Portable Document Format for Archiving is a file format based on PDF, that "provides a mechanism for representing electronic documents in a manner that preserves their visual appearance over time, independent of the tools and systems used for creating, storing or rendering the files." (ISO 19005-1)
• XML: eXtensible Markup Language is a standard for word-processing documents, presentations, and spreadsheets that can be implemented by multiple applications on multiple platforms. (ISO 29500)

Migration and Conversion

The most common approach to preserving electronic records involves a combination of two techniques: migration and conversion.

Migration is the process of moving files to new media (also known as "refreshing") or computer platforms in order to maintain value. Conversion entails changing files from one format to another and may involve moving from a proprietary format to a nonproprietary one. To avoid losing data and metadata, perform a test migration or conversion to determine the viability of continuing the process. When properly planned and executed, the migration and conversion approach probably represents the easiest and most cost-effective way to preserve electronic records.

There are three basic types of loss that may occur during conversion or migration:

• Data: Loss of data jeopardizes the reliability, accuracy, and integrity of the record.
• Appearance: Loss of structure or layout may be detrimental to understanding the record.
• Relationships: Loss of connecting metadata, spreadsheet cell formulas, or database tables may affect the ability to understand the data as a whole.

7. Reformatting Records

Reformatting from paper to another medium is often viewed as a means of saving space and increasing access, but it may not be the most effective or least expensive solution to a record-keeping problem. Before implementing a reformatting plan, ensure that all records past their retention period, as well as all unnecessary non-records, have been destroyed according to retention schedules, and explore alternatives such as using a records center for storage.

When to Reformat

Records should not be reformatted solely for space-saving purposes. An analysis of the records should be completed before any final decision is made. The best candidates for reformatting will have a combination of the following factors:

• Are historic or otherwise valuable and in bad physical condition
• Have a high retrieval rate
• Are needed by multiple users simultaneously
• Are needed at multiple locations
• Have important research value
• Are oversized and bulky
• Need to be stored separately for security reasons
• Incorporate daily business processes

Reformatting Options

Nowadays, the most common reformatting option is electronic imaging. In the past, microfilming was another popular choice for reformatting records. Each option has advantages and disadvantages depending on the application and anticipated use of the records.

Microform

Microform, including microfilm and microfiche, is a reliable storage format for records with a long-term or permanent retention and low level of access. It requires that an indexing and quality control system be developed. The Library of Virginia establishes microfilming standards, which are available in the Virginia Administrative Code (17VAC15-20-10 et seq.) and the Guidelines for Microfilming Public Records.

Computer Output Microfilm (COM) is a conversion of electronic information to microfilm. COM is one option for those with significant volumes of electronic data requiring long-term storage. The Library of Virginia establishes COM standards, which are available in the Virginia Administrative Code (17VAC15-50-10 et seq.).

Advantages:

• Reduces need for physical space
• Reduces wear and tear on originals
• Recommended for long-term preservation
• Does not require computer software or hardware to view
• Standards have been established

Disadvantages:

• Increasing lack of user familiarity
• Image quality degenerates in copying
• Limited to minimal access points
• Reader machines are expensive and large
• Does not allow for full-text searching

Paper

Photocopying records provides access copies while eliminating excessive handling of originals. Photocopies will need to be reproduced over time, however, and too much photocopying degrades the original. This option is best for historic records.

Advantages:

• Reduces wear and tear on originals
• Does not require special technology aside from photocopier
• Inexpensive

Disadvantages:

• Increases need for physical space
• Excessive deterioration of original
• Results in image degradation

Electronic

It is legal to reformat records to an electronic format, but any technical drawings and blueprints should be reproducible to scale. Saving records electronically requires that an organization be able to find, open, and read a record over the full length of its retention period. This requires that indexing, quality control, and migration systems/plans be developed.

Advantages:

• Reduces need for physical space
• Reduces wear and tear on originals
• Facilitates indexing, searching, and retrieval
• Allows for multiple access points
• Recreates high-quality user copies with minimal image degradation

Disadvantages:

• Requires software or hardware to access
• Requires continuous monitoring and eventual or periodic migration and conversion
• Faces software and hardware obsolescence
• Necessitates time-consuming metadata creation
• Standards are not universally accepted
• Modification or corruption are potential authentication issues

Legality of Reformatted Records

Both the Code of Virginia (§ 8.01-391) and federal laws recognize the legal status of copies made from various sources, including electronic data. The law of evidence allows accurate and authenticated copies produced from originals to be admissible as evidence.

Authenticated records require written policies and procedures that formally document their recording, storage, or reproduction. A list of users and their access privileges should be maintained and audited regularly. Additionally, you should keep audit trails documenting who scanned or edited images and when this occurred.

Destroying Originals After Reformatting

After records are reformatted, inspected, and approved according to established standards, the originals may be destroyed, unless specifically prohibited by law, because they are then considered copies. The reformatted version would then be considered the official copy of record.

The best practice is to document, through written procedures, the point at which this version becomes the record. A Certificate of Records Destruction (RM-3 Form) is not created for the destruction of copies or other non-records. However, any original records with permanent retention or records created before 1913 must be offered in writing to the Library of Virginia before the destruction of the originals. Also, any non-records that contain privacy-protected or confidential information must be confidentially destroyed, even though the destruction should not be reported.

8. Destruction of Public Records

Appropriate destruction of public records is one of the essential duties of all public agencies under the Virginia Public Records Act. It is also a cornerstone of a transparent and accountable government. Destruction of records at the end of their retention period should be a regular, predictable part of the flow of business: the more integrated the destruction process is to an agency’s functions, the more defensible position an agency assumes if ever called to account for why it does or does not possess given records.

The vast majority (97% or more) of all public records are considered nonpermanent by schedule and thus eventually will reach the end of their defined lifetime and must be destroyed. Per the Code of Virginia § 42.1-86.1, all public records shall be destroyed in a timely manner after the end of their schedule-defined retention period.

The schedule will designate whether the record must be destroyed confidentially or if non-confidential destruction is sufficient. 

• Confidential destruction requires a method such as shredding, burning, dedicated electronic file erasure, physical destruction of storage media, or the like in such a manner that the record cannot be reconstituted.
• Non-confidential destruction may also be securely destroyed by shredding, etc., at the discretion of the agency, but it is not required. Records with this disposition method can be recycled or taken to a landfill.

Code of Virginia § 42.1-86.1 also specifically requires that the destruction of public records be documented and reported to the Library of Virginia via the Certificate of Records Destruction (RM-3 Form).  The correct form should be chosen according to the circumstances: if the records are stored at the State Records Center (SRC), the SRC-specific form should be used. Otherwise (the more common scenario) the standard version should be used. Detailed instructions for how to complete the form, including video walkthroughs for the standard form, are available on the Forms page.

An RM-3 Form is required only when destroying public records that are the copy of record. A copy of record may be an original, a reformatted version, or another secondary instance of the record, but it must be designated by the agency as the copy of record. The destruction of materials that are not public records, such as duplicates, personal items, or reference material, must not be reported on an RM-3 Form.

Destruction and Reformatting

After records are reformatted, inspected, and approved according to established standards or guidelines, the originals may be destroyed because they are then considered duplicates. The reformatted version becomes the official copy of a record. We do not require a Certificate of Records Destruction (RM-3 Form) for duplicates. However, any original records with permanent retention or records created before 1912 should be offered in writing to the Library prior to the destruction of the originals. When the reformatted records have reached the end of the retention period, an RM-3 Form must be submitted documenting the destruction.

Destruction Hold

The Code-defined exceptions to destroying records in accordance with a retention schedule occur when the records are subject to audit, pending or active litigation, investigations, or request for records pursuant to the Virginia Freedom of Information Act. If records are placed on hold, the retention period does not change. When the hold is lifted, the retention period picks up as if the hold never occurred. Therefore, if a retention period expires while a record is on hold, the record should be destroyed immediately after the hold is lifted.

Destruction holds may also occur during schedule reviews and updates. Once the newest schedule has been approved and is active, the destruction process remains the same.

Determining the Date of Destruction

Ensure that you are using the most recent version of the correct records retention and disposition schedule. Retention schedules change and are updated on a regular basis. The online versions available on our website are the official, up-to-date retention schedules and must be used when preparing records for destruction. If you cannot locate a given record on a retention schedule, it cannot be destroyed. Please contact your records analyst for more guidance. 

Tips for calculating destruction dates:

• In reading a retention schedule, note the column titled “Scheduled Retention.” This column will feature both a retention period (usually in years) and a cutoff event (such as “after end of state fiscal year” or “after superseded, obsolete, or rescinded”). The cutoff event defines when the “destruction clock” should start. That is, if the retention statement reads “3 years after end of state fiscal year” then the clock starts at the end of that given fiscal year, and the record is eligible for destruction three years after that event. 

	Year Created	Retention Time	Retention Count	Destruction Date
Calendar Year	1986	10 years	1987, 1988, 1989, 1990, 1991, 1992, 1993, 1994, 1995, 1996	1/1/1997
Fiscal Year	FY2000	3 years	FY2001 (7/1/2000-6/30/2001) FY2002 (7/1/2001-6/30/2002) FY2003 (7/1/2002-6/30/2003)	7/1/2003
School Year	SY2009	1 year	SY2010 (9/1/2009-8/31-2010)	9/1/2010
Birth Year	1/1/1995	21 years	1996, 1997, 1998, 1999, 2000, 2001...	1/2/2016

9. Records Preservation

Preservation is the act of stabilizing storage environments and records in order to ensure the continued existence, accessibility, and authenticity of the records over time. Preservation should not be confused with conservation or restoration, which involves the repair or stabilization of an item through chemical or physical treatment to ensure its continued existence in its original format or form. The following are general recommendations and guidelines for preservation. Specific needs may be better addressed by a professional records preservation consultant.

Environmental Conditions

Key factors in preserving records include safety, security, stability of temperature and humidity levels, fire detection and suppression, and disaster prevention. A site survey is recommended for any area that houses or may house long-term or permanent records.

Temperature and humidity

Maintaining a stable environment is important since fluctuations in temperature and humidity pose more of a threat to records than steady, but less-than-ideal temperatures. Stable temperatures around 68° F and a relative humidity of 35 to 50 percent are acceptable for storage areas that must house records in both paper and electronic formats.

Fire and smoke detection

Smoke detectors, fire alarms connected to a 24-hour monitoring station, and appropriate fire-suppression systems provide a good line of defense against records destruction by fire. A well-trained staff and close communication with fire department personnel enhance fire safety.

Coordinate with facilities staff to understand what type of fire suppression system your building has implemented. In the event that the system is triggered, it is important for disaster recovery to know what method of fire retardation was used. Common fire suppression systems include foam, wet pipe sprinklers, dry pipe sprinklers, and deluge sprinklers, among others.

Vulnerable storage locations and security

Avoid storing records in attics and basements where they may be susceptible to water leaks, pests, and sunlight or ultraviolet rays. Care should be taken in the placement of permanent records for safety and access. The “Storage Boxes and Shelving” guidelines found in Chapter 10 (Records Storage) are applicable for preserving permanent records. Permanent, historic, and essential records have special storage considerations. Ideally, these records are stored in a secure fire-rated vault or, if appropriate, in the Archives at the Library of Virginia.

Oftentimes, records are relegated to less-than-ideal locations. In these cases, we must be adaptable. For storage areas with window access, ensure that windows are properly sealed and locked, and investigate purchasing UV blocking window film. For spaces that are rarely visited, schedule a walkthrough at least once a month to ensure the area is stable – meaning there are no water leaks, critters taking up residence, or no mold growth on your records. Finally, invest in locks to the doors of all storage spaces housing sensitive or permanent records. The last thing you need is for your storage room to turn into a break room!

Permanent Paper Preservation

The following guidelines are the gold standard for creating, handling, and storing permanent records:

• Records should be created using acid-free, alkaline-buffered paper and should be stored or housed in acid-free folders and boxes. Buffering paper neutralizes acidity.
• Never use adhesive tape to repair archival or permanent records. It deteriorates over time, and the adhesive discolors and darkens the paper to which it was attached.
• Use only rustproof paper clips.
• Remove all other fasteners, such as rubber bands, grommets, and staples.
• Because folds and creases can weaken paper, unfold materials and arrange for flat storage. To avoid further damage, do not unfold fragile documents that have been folded for many years. Consult with a paper conservator for guidance.
• Papers with a high level of acidity, such as newspapers, should be reformatted to preserve the information.

Photographs

Photographs are among the most engaging historical records, but they can present unique challenges. Photographs are physically and chemically more complex than paper materials. To extend the life of photographs:

• Hold prints and negatives by the edges in order to avoid touching the emulsion surface.
• Avoid using tape, metal clips, rubber bands, or adhesives.
• Avoid using ballpoint and felt-tip pens for identification purposes. Instead, use a soft pencil on the back of mat pictures with acid- and lignin-free materials.
• Color will not last, so copy important photographs in black and white.
• Framing can be destructive to photographs if done incorrectly. High-quality frame shops should know the standards and procedures recommended for framing.

Bound Volumes

Bound volumes, such as books, are composed of a variety of materials and can require complex preservation measures. Regular handling and improper storage also causes harm. To slow down the deterioration process:

• Make sure that space is available between volumes. Crowding can cause damage, especially during retrieval.
• Hold the book on either side of the spine to pull it off the shelf. Do not hook a finger over the top of the spine and pull.
• Use flat bookmarks. Never leave a bookmark in a volume permanently.
• Avoid placing heavy items in or on a volume.
• Avoid using metal paper clips, holding a volume together with rubber bands, and turning down the edges of pages.
• Do not use a volume as a surface for writing.
• Photocopying volumes is discouraged, but if a volume can withstand photocopying, do not press the spine against the copier.

Electronic Records

If a record is maintained in an electronic format, then conversion and migration of the data may be necessary to maintain the record through its full retention period. Long-term storage of records held in electronic formats presents numerous challenges. Bear in mind that electronic media stored in a vault does not have the same heat tolerance as paper. It’s easy to forget that electronic records are just as physical as paper records. Just because it’s digital doesn’t mean it can’t degrade!

Consider the following when storing records in an electronic format:

• Media life span depends on factors such as storage conditions and daily use. Avoid excessive use and handling (e.g., saving and accessing long-term files more often than necessary) as well as storage spaces that lack proper climate control.
• Media begin deteriorating from the date of manufacture, not the date of recording. Do not buy large quantities of media. Buy it only as needed.
• Consider the maintenance of hardware devices that allow access to the data. Even under the best of conditions, hardware becomes obsolete, parts are difficult to locate, and service for the equipment becomes limited.
• Software may be superseded or become obsolete, at which point it may no longer be supported by the developer. Plan to upgrade and migrate data as necessary.

10. Records Storage

Records management personnel must be mindful of maintaining proper storage conditions and creating procedures for the storage and use of records in every stage of their life cycle.

Environmental and Security Concerns

Storage areas should conform to certain environmental and security conditions. Ideal environmental conditions include specific temperature and humidity limits and the presence of appropriate fire suppression systems. Environmental factors are described in the “Environmental Conditions” section of Chapter 9 (Records Preservation).

Records should be stored, whenever practical, in a secure area with controlled and documented access for personnel. Security is especially important for the storage of confidential or privacy-protected records. The same security considerations should be given to the storage and use of electronic records as well.

Storage System Integrity

An efficient record storage system will include written procedures for storing, retrieving, using and refiling records. Specific procedures should also be created if a program or index is used to track records. Training should be provided to personnel to ensure compliance with all procedures. Use checkout controls for records removed from the storage area to ensure accurate tracking and proper refiling. Periodically review the storage program as needs may change over time.

Storage Boxes and Shelving

Storage boxes should:

• Be uniform in size.
• Be made of acid-free material if storing permanent/long-term records. Less expensive non-acid-free storage boxes can be used for nonpermanent records storage.

Shelving units should:

• Be sized to ensure that the weight of the loaded shelves does not exceed the floor-load capacity.
• Be sturdy enough to hold boxes loaded with as much as 50 pounds.
• Have bottom shelves at least three inches off the floor to help prevent damage from flooding.
• Provide sufficient space for the boxes to be pulled off the shelves easily.
• Be anchored to the floor where possible.
• Ideally, be placed so that they do not touch any walls, but especially outside walls.
• Be accessible by a sturdy and size-appropriate ladder, as needed.

Packing and Stacking Boxes

Pack records properly so that they can be safely and efficiently placed on shelves. When packing and stacking boxes:

• Keep records in the original file folders when placing in boxes unless the records are permanent. Permanent records should be placed in acid-free folders and boxes.
• Do not pack boxes tightly, since this could impede file removal. Allow for up to an inch of space to remain in the box after packing.
• Consider larger records and materials such as maps and drawings that will have special handling, packing, and shelving needs.
• Place infrequently accessed records on the top or bottom shelves.
• Neither records nor boxes should be in contact with a wall or floor.

Centralized Storage Facility

If a series of records is referenced more than once per month, it is generally considered active. Active records should be kept within, or in close proximity to, the office. Records that are used less frequently are considered inactive and are eligible for off-site or centralized storage. If storing inactive records with either a commercial service provider or the State Records Center (SRC) is not feasible, then government entities need to identify a reliable, secure, and lower-cost area to store these records in-house. Maintaining a centralized records storage facility encourages efficient operations by saving valuable office space and combining departmental resources. Creation or use of a centralized records storage facility should be endorsed by the agency or locality's governing official or body, and written procedures should be clearly communicated to staff.

11. State Records Center Transfers and Services

The State Records Center (SRC) houses inactive, nonpermanent records for any government entity of the commonwealth in a secure and environmentally stable location. Per Code of Virginia §2.2-3704(J), records held at the SRC remain in the legal custody of the agency of origin. As such, access is restricted to the agency of origin.

The SRC facility also houses Imaging Services, which manages a security microform program, and the Archives Annex, which holds low-reference permanent records. There is also a reading room for viewing archival materials.

Eligibility for State Records Center Storage

Records that have not yet reached the end of their retention period but are rarely referenced are ideal candidates for storage in the SRC. Transferring records to the SRC frees up space in an office for more useful purposes. Often it is more economical to pay for off-site storage then it is to buy more file cabinets and pay office real estate prices.

The format of a record is considered in the short-term and long-term storage and accessibility of the information. Formats of records eligible for SRC storage include:

• Paper
• Microforms including microfiche, computer output microfiche (COM), and 16mm and 35mm reels
• Electronic, including CD/DVD, hard drives, and magnetic media

Electronic records stored on portable media within records center boxes may be transferred to the SRC; however, the SRC is responsible for maintaining only the conditions in which the media is stored, not the media itself, or the data contained on the media.

All records to be transferred must be listed on an approved general or specific records retention and disposition schedule. The SRC will not accept any records that:

• Are not on a records retention and disposition schedule
• Have reached the end of their retention period
• Are within six (6) months of reaching the end of their retention period
• Do not belong to an agency of the Commonwealth
• Are permanent
• Have an open-ended retention period, such as “destroy after no longer administratively useful"

Access and Ownership

Each agency retains ownership of its records while they are stored at the SRC. Access to the records is strictly controlled so that no individual, agency, or office may access records without specific authorization from the record owner. State Records Center staff members will only access records at the request of the owner and are required to sign a confidentiality agreement treating all information as classified. The confidentiality agreement also bars staff members from disclosing information in the records to unauthorized individuals.

Storage Fees and Service Charges

There is a monthly fee for storage of records at the SRC. This fee applies for any unit of records stored for any portion of the month, and includes accessioning, refiling, and removal of boxes from shelves at the end of the retention period. Additional fees apply for storage of odd-size records units, shredding, copying, emergency retrievals, and out-of-service-area pickups.

Note: The storage fee will be charged until records stored are destroyed by SRC staff members.

Transfer Procedures for Nonpermanent Records

1. Identify the appropriate schedule and series number. Records must be listed on an approved retention schedule, with a finite disposal date, to be eligible for transfer to and storage at the SRC.
2. Determine the volume of records. To prepare for packing and determine the correct number of boxes needed, estimate the cubic footage to be transferred. Refer to the Volume Estimation Table or simply approximate how many files will fit into a cubic-foot box (also known as a records center box, 15" x 12" x 10").
3. Order boxes. You can do this by clicking on the VDC Catalog button, typing "l-va" into the Description Box, and selecting Product 920050. Boxes sent to the State Records Center for file storage must be letter/legal size, heavy duty, 200-lb. test corrugated double-wall construction (at the minimum), with three-ply ends, removable top, and die-cut handholds cut into each end. Boxes must be interlocking with no staples or tape required for set up. Boxes must be able to hold 50 pounds. Boxes should be one cubic-foot size, with 15" x 12" x 10" internal dimensions.
4. Pack the boxes. Carefully pack boxes so that files and materials can be easily removed and replaced, leaving about one inch of free space. Materials must fit in the box without causing it to bulge, and lids must fit correctly. Do not place records in hanging file folders within the box and do not send damaged boxes, such as those that are crushed or have ripped handles. Boxes should weigh about 30 pounds or less. Files should be placed in the box in neat, logical order, as if they were in a file drawer. File names or numbers must be visible.
5. Enter box information into LVA ShelfLife (the Library’s records management software program). All State Records Center customers must have ShelfLife login credentials in order to transfer boxes. In order to receive login credentials, submit a Records Technician Authorization Form (RM-26 Form).
6. Label and bar code the boxes. Barcode numbers are automatically assigned to boxes created in ShelfLife, and those numbers are added to a label queue. Those labels should be printed on Avery 5523 2" x 4" weatherproof shipping labels. Apply the barcode labels to a 12" side of the box, in the bottom left-hand corner, approximately 1" from the bottom and 1" from the left side.
7. Request a pickup of boxes. Notify SRC staff by email that boxes are ready for transfer. In the content of the email, be sure to include the total number of boxes, the physical location of the boxes, including the floor and room number where boxes are located, and your complete contact information. An SRC staff member will call or email to arrange for a records pickup.
8. Assemble records for pickup. Only boxes entered into ShelfLife will be picked up by SRC staff. Agencies and localities outside the Richmond service area may contact the SRC for a records-pickup service quote or to arrange to have the records delivered to the SRC. All records pickups or deliveries must be scheduled. Note: SRC trucks can only pick up 200-250 boxes per one trip. Additional trips may need to be scheduled if you have more boxes.

Requesting Records

All boxes in storage at the SRC are searchable via ShelfLife. In order to request an individual file, rather than the entire box, the file information must be entered into ShelfLife along with the box information. After identifying the correct box or file, submit a request by completing and faxing the Records Center Retrieval Request (RM-18 Form) to (804) 236-3722. RM-18 Forms must be completed using a computer. For information regarding turnaround time, reach out to Matt Ball.

Returning Records

Call the SRC when ready to return records to the facility. Records will be picked up and returned to the appropriate place in the SRC. Customers outside the Richmond service area may use a preferred delivery company to return the records.

Destruction of Records at the SRC

Records stored at the SRC will not be destroyed without the agency’s written permission. You are responsible for tracking destruction eligibility for your stored records and for eventually completing the SRC Certificate of Records Destruction (srcRM-3 Form) to initiate the destruction process. SRC customers can expect to have their boxes within 6 months to a year of submitting the srcRM-3 Form. During this time, a fee will continue to be charged for stored records. Once the destruction has been completed and affirmed by SRC staff members, the form will be viewable on the Completed Form Dashboard.

SRC customers can identify boxes of records that are eligible or past due for destruction by logging into ShelfLife and following these step by step instructions.

The method of destruction depends on criteria specified in the records retention and disposition schedule. Those that are deemed confidential, private, or sensitive will be shredded for a fee by the SRC to ensure that the information is protected. Records not requiring confidential destruction are either picked up by a paper recycler or sent to a landfill. Any records may be confidentially destroyed by request of the records owner.

Confidential and non-confidential records destruction services are also available for government offices not using the SRC's storage services. The agency is responsible for filling out the srcRM-3 Form and then contacting the SRC to pick up the records.

Pest Eradication and Blast Freezing

Occasionally, records stored in poor conditions require the eradication of pests from the materials. The SRC’s pest eradication chamber is a custom-built blast freezer that freezes records at -40° F in order to destroy insects and vermin. The records then are gradually brought back to room temperature.

The chamber can also be used in an emergency to stabilize water-damaged records and stop the growth of mold until document restoration professionals can provide specialized treatment. The maximum load for emergency stabilization is 600 cubic feet of records. It is important to freeze water-damaged records within the first 48 to 72 hours to avoid an outbreak of mold. For help with a records emergency, contact your records management analyst.

12. Archival Transfer Procedures

Virginia public records with enduring administrative, fiscal, historical, or legal value are considered permanent. Records with enduring value provide evidence of the government's functions, decisions, programs, and policies and are used for reference and research. These records may be required permanent by Code, or may be identified during the retention scheduling process. Records with "enduring value" can mean those required by Code or those that people may be interested in 100 years into the future. Permanent disposition is indicated on the records retention and disposition schedules as either "Permanent, In Agency" or "Permanent, Archives".

Records with a disposition of "Permanent, Archives" may be transferred to the Archives at the Library of Virginia, where they will be permanently preserved and made accessible to researchers. Review appropriate general and specific records retention and disposition schedules to identify permanent records and determine which records are eligible for transfer to the Archives. Specific transfer procedures for boxing, labeling, and listing contents must be followed and archival records should be transferred on a regular basis to avoid large accumulations. Records officers should contact their assigned records analyst before beginning a transfer.

Caring for Archival Records during their Active Life Cycle

Prior to their eventual transfer to the Archives, permanent records require proper care and attention while used and stored in the agency or locality. Records should be clearly marked as permanent and be stored in secure areas with appropriate environmental conditions. For paper records, file names should be written directly on folders, rather than on adhesive labels, as these labels often fall off over time.

Preparing Records for Transfer

Use the Volume Equivalency Table to determine the number of boxes needed for your paper and/or microform transfer. Likewise, for electronic records, ascertain the amount to be transferred and determine best physical medium for transfer. With electronic records, determine the number of compact disks, the size of the external drive, and/or the number of files needed for records transfers. Specific guidance for transferring archival electronic records can be found within the Electronic Records Guidelines.

Paper records being transferred to the Archives require standard acid-free boxes (15" x 12" x 10"). This one-cubic-foot-size box will hold 14 inches of letter-size files or 11 inches of legal-size files. Boxes must be heavy duty, 200-lb. test corrugated double-wall construction (at the minimum), with three-ply ends, removable top, and die-cut handholds cut into each end. Boxes must have an interlocking structure, with no staples or tape used in their construction. Contact your records management analyst before preparing to transfer records that are odd-sized, such as maps or plats, or are in non-paper formats.

Pack files into boxes and/or save electronic records to external electronic media in the same order and hierarchy in which they are currently stored. Maintaining the original order of the files is an underlying principle of archival management and will accurately reflect the actual administrative use of the records.

When boxing permanent paper records:

• Pack files in acid-free boxes with different records series boxed separately.
• Place files upright in the box in the same logical order in which they were kept in the file drawer.
• Make sure file names or numbers are visible.
• Avoid over packing or under packing boxes to prevent damage to records. Carefully pack boxes so that files and materials can be easily removed and replaced, leaving about one inch of free space. Materials must fit without causing the box to bulge, and the lid must shut completely.
• Do not send damaged boxes, such as those that are crushed or have ripped handles or water damage.
• Boxes should weigh 30 pounds or less.

We handle a large amount of archival material, so it is crucial that the exterior of all boxes and containers be properly labeled.

When labeling:

• Do not put the label on the box lid.
• Label each box on the 12-inch side, or on the front of the CD, and include:
  • Name of the agency or locality
  • Administrative subdivision, if applicable
  • Records series title and dates
  • The range of contents, including the name or number of the first and last files
  • Box or CD number
• When possible, handwrite the label information directly on the box or electronic record container, rather than using adhesive labels.
• Number the boxes or electronic record containers consecutively for each transfer. Do not duplicate box numbers within a single records transfer.

Boxing and labeling requirements for archival microforms are found in Microform Transfer Procedures.

Archival Transfer Forms

Once the records have been boxed (or saved, for electronic records) and labeled, complete an Archival Transfer List and Receipt (ARC-1 Form), as seen under the "Transfer Archival Records" tab of the "Records Management Forms" page on our website. The ARC-1 Form provides a notice of intent to transfer, a receipt, and a descriptive list of boxes, compact disks, or USB drives to be transferred.

After filling out the ARC-1 Form, complete an Archival Transfer Folder List (ARC-2 Form), also located on the "Transfer Archival Records" tab. The ARC-2 Form is a separate and distinct document from the ARC-1 Form, which lists only the beginning and ending files in each box or compact disk. The ARC-2 Form is a detailed listing that accurately describes each folder in each box or on the external media. This form will act as a guide for our archivists, increasing understanding of and access to the records.

After completing both the ARC-1 and ARC-2 forms, send a copy of the forms to your assigned records management analyst for review and approval. Both forms must be completed and submitted together before a transfer will be scheduled. The analyst will return the approved versions. Keep copies of both forms to document the transfer.

Physical Transfer

After the transfer request is approved, one of our staff members will arrange to pick up the records. The original, signed ARC-1 Form must be provided at the time of the records pickup. After the transfer is complete, a copy of the ARC-1 Form that includes a unique accession number assigned by Archives staff will be provided to the records officer. Permanently retain the returned ARC-1 Form with the copy of the ARC-2 Form. The accession number on the ARC-1 form will be the easiest way to locate the records if they are needed in the future.

Accessing Records in the Archives

Unless restricted by law, public records housed in the Archives are available through the Library of Virginia reading rooms. Once state records have been transferred to the Archives for permanent retention they cannot be returned to the agency. To access records that have been transferred to the Archives, contact Archives Reference Services at archdesk@lva.virginia.gov.

13. Microform Transfer Procedures

The Imaging Services Section (ISS) at the Library of Virginia manages a microform-preservation program for the Library’s collection, as well as for permanent records of state agencies and political subdivisions. This program is offered free of charge for all permanent records stored on microforms, as well as for microform backups of permanent records. Nonpermanent records converted to microfilm are stored through the State Records Center (SRC) for a fee. ISS also offers advice on microform reformatting and storage to any government entity in accordance with the Virginia Public Records Act. Security microforms stored through this program are not used for reference purposes. Paper records at the Library of Virginia are not available for public use once they have been reformatted.

Caring for Microform Records

As part of good recordkeeping, microforms of permanent records should receive proper care and attention prior to their transfer to Imaging Services. They should be clearly labeled and kept in an orderly manner in clean and safe storage areas with appropriate environmental conditions. In keeping with preservation maintenance practices, these microforms should be stored in acid- and lignin-free microfilm boxes and individual microfiche envelopes.

Preparing to Transfer Microforms

In order to capture the most secure and accurate information about the records being transferred, follow Imaging Services' Microfilm Storage Guidelines. Transfers not meeting these requirements will be returned to the records custodian for correction or additional information.

1. Review retention schedules

Find the appropriate general and specific records retention and disposition schedule and locate the series for the records on microform. The schedule will indicate which records series have been listed for permanent retention and are eligible or required to be transferred to Imaging Services.

2. Order boxes and microfiche envelopes

All microfilm sent to the Library for storage must be placed in acid- and lignin-free boxes. This helps to ensure stable, long-term storage of the film. For microfiche, use acid- and lignin-free envelopes and fiche boxes. We will not accept containers that do not meet these requirements.

3. Pack boxes

Insert the microfiche into an individual acid- and lignin-free envelope by records series, volume/file number, and fiche number. Arrange and pack reels into boxes by records series, volume/file number, and reel number.

4. Label microfilm boxes

It is crucial that the exterior of all boxes be properly labeled to ensure that they are easily accessible. The minimum labeling required on a microfilm box must meet the requirements found in the guidelines.

5. Transfer lists and receipts

• Archival records: If the microforms that are being transferred contain permanent, archival records to be transferred to the Library of Virginia’s Archives as noted in the appropriate records retention and disposition schedule, they should be transferred following the normal procedures using the Archival Transfer List and Receipt (ARC-1 Form). Refer to Chapter 12 (Archival Transfer Procedures) for additional information.
• Permanent (non-archival) records: If the microforms are backup copies of permanent records being retained in the agency, then the Archival Microform Transfer List and Receipt (ARC-3 Form) must be used. That form, completed in the Word version provided on the website, must be emailed to your assigned records analyst for review prior to the transfer. After the agency has received the approved ARC-3 Form back from the analyst, the printed, signed form must be sent to Imaging Services with the transfer. A copy of the final ARC-3 Form will be provided to the records custodian after the microforms are inspected for adherence to the established standards and guidelines.

6. Physical transfer of microforms

There are several options for transferring microforms. If the microforms are part of a transfer of records going into the Library's Archives, the transfer logistics will be worked out with State Records Center (SRC) personnel. If the microforms are a backup of an agency’s permanent records, then the media should be transferred directly to Imaging Services, and can be sent by United Parcel Service, Federal Express, or any other courier service that provides shipment tracking and receipt. It can also be hand-delivered to the Library or scheduled for pickup by State Records Center personnel, if within SRC’s normal delivery area. Consult with your assigned analyst for details.

14. The Role of Government Records Services at the Library of Virginia

Under the guidance of the State Archivist and in accordance with the Virginia Public Records Act, the Library of Virginia’s Government Records Services (GRS) division supports the effective and economical management of state agency and political subdivision records.

Records Analysis Services (RAS)

Records management analysts are available to provide state and local government offices with consulting services for establishing and maintaining effective public records management programs. Analysts assist with managing records throughout their life cycle by developing retention schedules, addressing reformatting and preservation issues, and determining the proper methods of disposition for confidential and privacy-protected records.

RAS provides:

• Records retention and disposition schedules for all public records, regardless of format.
• Advice on implementing public records management programs.
• Training on records management topics, presented online and onsite. An audience of 25 or more is required for travel outside the Richmond metro area. Online training can be done for any number of participants.
• Records management guidelines, standards, and manuals.
• Assistance with records emergency planning through the Intergovernmental Preparedness for Essential Records (IPER) program.
• Assistance in identifying permanent and essential records.
• Assistance in identifying and transferring archival records to the Archives at the Library of Virginia.
• Assistance in identifying and transferring nonpermanent, inactive records to the State Records Center (SRC).
• Web content including publications, forms, training aids, and links to records management resources.

State Records Services

State Records Services is charged with the protection and preservation of the documentary heritage of official public records of state agencies determined to have enduring value, as well as promoting research through enhanced accessibility. State Records Services appraises, analyzes, arranges, and describes state agency records housed in the Archives. Accessioning archivists create and maintain the documentation for incoming records, receive and describe incoming collections, and assign records a permanent, unique accession or identification number. The division creates online catalog records and finding aids to enable access to the Archives’ materials.

Local Records Services

Local Records Services is responsible for the protection and preservation of local records determined to have enduring value, with an emphasis on records created by the Commonwealth’s circuit courts through the administration of the Circuit Court Records Preservation (CCRP) Program. The CCRP Program preserves and makes accessible the documentary heritage of Virginia's circuit courts. The statewide program of assistance and grants focuses on preserving the records of Virginia's 120 circuit court clerks' offices. Funding is generated from a fee on land transactions recorded in the clerks' offices. The program initiatives include funding preservation grants and managing the storage, processing, and reformatting of records transferred to the Archives.

15. Conducting Compliance Reviews (Audits)

A sound records management program must have a mechanism in place for internal auditing compliance. Policies and procedures are worthwhile only if they are followed and staff members are held accountable.

A compliance review, or audit, is an assessment of the processes that make up a system. Audits evaluate effectiveness and compliance, as well as help minimize risk. A records officer should set and follow a time frame for conducting regular reviews, such as every other year, for example.

Conducting a compliance review of records systems will help:

• Ensure compliance with the agency’s established directives, as well as state and federal laws and regulations.
• Ensure that records will be accepted as evidence in a court of law.
• Improve the agency’s performance and efficiency.
• Identify areas for improvement.
• Provide accountability to the citizens of the Commonwealth.

Establishing a Compliance Review Program

Compliance review success hinges on planning, execution, and results reporting. Successful records management audits should be highly structured, which will help ensure that:

• Responsibilities are defined
• Scope and methodology of the review are clear
• Resources are identified and available
• Disruption to services is minimized
• Findings are identified and communicated
• Necessary improvements are made

Determining Responsibility for Compliance Reviews

Responsibility for conducting compliance reviews will depend on several factors, including the type of review, the presence of external agencies with audit power, and the existence of an agency audit plan that includes assessment of records management practices.

Regardless of the type of compliance review undertaken or the entity undertaking it, it is important that the designated records officer is aware of and participates in the review.

Defining the Scope of a Compliance Review

Compliance reviews should focus on those areas where noncompliance poses the most pressing liability issues. Areas of potential risk include, for example, the inability to recover essential records from a disaster in order to resume operations, and the protection and disposition of confidential records.

The scope of the review should also include which areas of the records management program will be completely reviewed and which will be reviewed using sample testing. Records destruction practices, for example, may be sample tested to reveal whether there is evidence that the requirements are generally being met. Other areas that may require more thorough examination include records storage and the safety of confidential records. Time constraints and record volume will directly affect sample sizes and the choice between the use of sample testing and a more complete examination.

Compliance Review Components

A sound compliance review should answer the following questions

Are records management responsibilities clearly documented?

The compliance review should holistically assess the effectiveness of an agency’s records management program. A successful program will have the following:

• Records officer appointed by the agency head with documentation on file with the Library.
• A records management policy that encompasses all records, regardless of format.
• Procedures for managing records at all levels of the organization.

Are records management education and training provided regularly?

All individuals within an agency are responsible for managing their records and all staff should be aware of the Virginia Public Records Act (VPRA) and what constitutes a public record. Ensuring compliance across an agency requires regular training on the principles of records management using the agency’s policy and procedures. The education of senior management is especially important since their support is crucial to a successful program, given their power to effect agency wide change.

Is the records inventory up to date?

At its most basic level, a records inventory identifies all records series, as well as their storage locations and format(s). All records created and maintained by the agency and their accompanying scheduled destruction dates should be noted in the inventory using the Library of Virginia–approved records retention and disposition schedules as guidance.

Are all the records that are created/maintained relevant to business practices and captured using the appropriate system?

The compliance review should check that the agency’s policies and procedures cover the creation, management, and secure storage of information, as well as whether those policies and procedures are being followed.  Records should be necessary for agency business; agency resources should not be expended to retain superfluous records (unsolicited sales pitches, spam, etc.).

Are records stored properly?

Storage facility conditions and security controls should be studied for potential risks. Current measures to protect records from water and fire damage, proper control of access, and other security threats should be evaluated.

Are records disposed of properly?

The review should examine records disposal procedures and evaluate compliance with current Library-approved records retention and disposition schedules. Submission of properly completed Certificates of Records Destruction (RM-3 Forms) should also be reviewed.

Are electronic records being managed properly?

Systems and processes for accessing, maintaining, storing, and transferring electronic records should be evaluated in order to ensure their integrity and authenticity.

Are records securely managed?

Records containing confidential information must be managed in a secure manner and disposed of properly as required by the Virginia Public Records Act (VPRA) and other state and federal regulations. Ensuring that all records are authentic and legally admissible is fundamental to a records management program. This portion of the compliance review should focus on security controls within electronic, paper, and any other media-based systems. The compliance review should discover whether confidentiality has been breached or put at risk through the deliberate misuse of systems or because of weak, nonexistent, or poorly applied procedures.

Reporting Compliance Review Findings

Compliance review findings should be reported to the appropriate managers for action. Information learned from the compliance review, including possible better practices, should be communicated throughout the agency. Any changes made as a result of a compliance review should be clearly communicated to staff and senior management and, if necessary, incorporated into the agency’s records management policy and procedures.