Records Disposition Procedures

For more assistance in implementing Records Management at the University, see the following records management website: Records Management Advice and Guides.

Purpose

These Procedures will establish a consistent process for the retention and Disposition of University Records according to the Record Classification and Retention Schedule.

Definitions

For the purposes of these Procedures the following definitions apply: 

 “Disposition” means the final retention action carried out on a Record. This may include destruction, deletion, secure destruction or deletion, or transfer for archival review or to a third party.

“Disposition Authority” means a position responsible for authorizing Disposition of University Records as delegated by the Record Authority.

“Official Copy” means the copy of a University Record designated in local Procedures to satisfy the University’s retention requirements where multiple copies exist.

“Record Authority” means the position designated in the RCRS as having authority over a particular Records Series.

 “Record” means any record of information however recorded, whether by electronic means, in print form, on film or otherwise.

“Records Classification and Retention Schedule” or “RCRS” means a comprehensive list of all of the types of Records produced or received by the University. The RCRS groups Records into Records Series and provides rules for each including a Retention Period, an appropriate level of protection, Disposition method, and a citation to applicable legislation or regulations.

“Records Hold” means a written notice to suspend Disposition for designated records. A Records Hold may be authorized by General Counsel for legal reasons or by the Record Authority for unanticipated operational or audit needs.

“Records Series” means a classification of Records that are related by the function and activity they support. All Records in a Records Series are subject to the same Retention Period, active and inactive storage period, Disposition method and legislative and regulatory requirements.

“Responsible Unit” means the unit that must ensure that Official Copies are retained for the full duration of their Retention Period and Disposition occurs. This may be a named unit, or any unit that creates it if multiple units have responsibility for a Records Series.

“Retention Period” means the length of time Records in a Records Series must be retained before Disposition.

“Retention Trigger” means the event that triggers the Retention Period to start counting down.

“Transitory Copy” means an exact duplicate of the content of an Official Copy.

“Transitory Record” means any Record other than a University Record that has only short term value. Transitory Records may include:

1. Announcements and notices of a general nature.
2. Drafts.
3. Transitory Copies of University Records.
4. Printouts of databases where the University Record resides in the database.

“University Record” means a fixed unit of information in any format that documents a transaction, decision or relationship made by the University. It has continuing value in the future to complete further work, to provide evidence, to serve as institutional memory of obligations, responsibilities, decisions and actions, or to document the unique character and history of the institution.

Scope and Authority

These Procedures apply to the retention and Disposition of all University Records. Disposition of Transitory Records is governed by the Records Management Policy.

The Record Authority for each Records Series is defined in the Records Classification and Retention Schedule. The Records Management Policy assigns authority for Disposition of University Records to the Record Authority. This authority may be delegated to one or more Disposition Authorities who will authorize and manage Disposition on their behalf.

The Disposition Authority is a supervisory role, with authority to:

1. Establish local Procedures or processes for organizing Records and tracking Retention Periods. These local procedures or processes should take into account work functions, and the repositories that house their records, whether physical or information systems.
2. Identify Official Copies of University Records and ensure that Transitory Copies are destroyed prior to the end of the Retention Period.
3. Authorize Disposition of University Records to be carried out in accordance with these Procedures and assign a delegate to carry out the Disposition process.
4. Report any operational or regulatory changes that may affect recordkeeping to the University Secretary delegate.
5. Ensure that completed Disposition Authorization Forms are submitted to the University Secretary delegate.

All University employees, faculty, staff, volunteers and members of the Board of Governors will ensure that any University Records in their care or control are stored in an Approved Repository that is subject to the retention rules in the RCRS and that any Transitory Copies are destroyed prior to the end of the Retention Period of the University Records in question.

The Office of the University Secretary will assign a delegate to monitor and administer the ongoing retention and Disposition of Transitory and University Records. This position will:

1. Create guidelines for organizing Records and tracking Retention Periods in the various repositories in use at the University.
2. Maintain submitted Disposition Authorization Forms and supporting documents as a University Record of Disposition.
3. Evaluate operational and regulatory changes reported by Responsible Units and determine whether these changes necessitate a review or modification of all or part of the Records Classification and Retention Schedule in accordance with the Policy Framework.
4. Provide training and support to Responsible Units to ensure the consistent application of these Procedures and the Records Classification and Retention Schedule.

The University Secretary and General Counsel, or successor thereof, is the Policy Owner of the Records Management Policy and is responsible for overseeing the implementation, administration and interpretation of its associated Procedures and directives.

Procedures

The Official Copy of a University Record must be retained for the full duration of its Retention Period as defined in the RCRS. Once the Retention Period of a University Record has expired, it is eligible for Disposition. The Retention Period begins to count down only after the Retention Trigger defined in the RCRS has occurred.

Disposition Process

1. Responsible Units must evaluate their holdings of University Records to compile a list of eligible Records at least once per year. The list may be created manually using the Disposition Authorization Form, or by an automated system.
2. The list of eligible Records must include, at a minimum, the:
   1. Record Series of eligible Records;
   2. File descriptions and date range within each Record Series;
   3. Retention Trigger date for eligible Records.
   4. The date when Records became eligible for Disposition.
3. All copies of Records on the list must be gathered together and verified to ensure that no ineligible Records have been mistakenly collected.
4. The Disposition Authority will authorize Disposition using the Disposition Authorization Form. In doing so, the Disposition Authority certifies that:
   1. There are no legal or operational Records Holds or FIPPA access to information requests that affect eligible Records.
   2. There are no unanticipated operational or audit needs regarding eligible Records.
5. Any eligible Records that are subject to a legal or operational Records Hold, FIPPA access to information request or unanticipated operational or audit needs, must be removed from the list and must not undergo Disposition.
6. During the Disposition process, Transitory Copies should be reviewed. Any Transitory Copies that are no longer needed should be destroyed.
7. Disposition will be applied according to the Disposition method in the Records Classification and Retention Schedule.

Proof of Disposition

1. Proof of Disposition must be created or obtained to document that Disposition was carried out as intended.
2. For paper Records this will be:
   1. A transfer receipt;
   2. A certificate of destruction from a third-party record destruction vendor;
   3. Or a form certifying that an employee carried out the destruction.
3. For electronic Records this will be:
   1. A system-generated log;
   2. Or a form certifying that Disposition was carried out.
4. The Disposition Authorization Form, list of eligible Records, and proof of Disposition will be forwarded electronically to the University Secretary Delegate for retention.

Organizing Records

1. If there are duplicate copies of a University Record in multiple locations, formats or systems, designate a single Official Copy for retention. Transitory Copies may be destroyed when no longer needed and must not be retained longer than the Official Copy. Transitory Copies containing confidential or personal information require secure destruction.
2. Any documents or files in a folder should be from the same Records Series, with the same Retention Trigger date. This will allow Retention Periods to be tracked and Disposition to be applied at the file or folder level, not the document level.
3. When the Retention Trigger is met a file or folder must be cut off and rendered inactive. At the end of each year, files with a year-end Retention Trigger must be cut off and a new file or folder created. Any material that is still in progress may be transferred to the new file or folder.

Records Hold

1. The General Counsel will issue a written Records Hold where there is actual or potential legal dispute, litigation or other legal matter, identifying Records related to the matter. The Records Hold will remain in effect until rescinded in writing.
2. If there is unanticipated operational or audit need for Records, the Record Authority may issue a written Records Hold. A Records Hold will identify the affected Records and Records Series, and include an anticipated end date.
3. Copies of Records Holds will be sent to:
   1. Record Authorities
   2. Disposition Authorities
   3. Responsible Unit(s)
   4. System administrators of involved systems
   5. University Secretary Delegate
   6. Any other necessary personnel
4. Upon being notified of a Records Hold, Responsible Units will suspend all Disposition of affected Records immediately. Records Holds will remain in effect until rescinded in writing.
5. Records Series requiring repeated operational or audit Records Holds will be evaluated by the University Secretary Delegate to determine if their Retention Period continues to meet the University’s operational needs, or if a revision is required.

Revisions to the RCRS

1. As part of the Disposition Authorization Form, units will report on any changes or anticipated changes to recordkeeping requirements. Changes may include:
   1. Changes to legislation or regulations that will affect recordkeeping.
   2. New guidance from professional or accreditation bodies that will affect recordkeeping.
   3. Changes to information systems used in recordkeeping.
   4. Changes to responsibility for recordkeeping (new programs, transfer of responsibility between units, etc.)
2. For any regulatory or operational changes, units should identify the: 
   1. Records Series that may require modification.
   2. Nature of the modification (i.e. change to Retention Period, citation, scope notes, etc.)
3. Reported operational or compliance changes will be evaluated by the University Secretary Delegate to determine whether to initiate a review of existing Records Series or the creation of new Records Series in accordance with the University's Policy Framework. 

Disposition Method

1. The Disposition Method for each Records Series is included in the Records Classification and Retention Schedule.
2. Secure Destruction
   Records containing sensitive or confidential information or personal information require Secure Destruction. Secure Destruction maintains security throughout the destruction process and renders the Record unrecoverable. Secure Destruction services may be contracted from third-party service providers, including cross-cut shredding, pulping or incineration.
3. If the Disposition method for Eligible Records is Destruction, a designated person must witness either:
   1. The secure destruction of the Eligible Records;
   2. Or the removal of Eligible Records for destruction by a service provider.
4. Transfer to third parties
   Compliance obligations may dictate that Records be transferred to the custody and control of a third party. These transfers must be governed by a written agreement. Transfer to a contracted Records storage facility where the University retains ownership of the Records is a method of storage, not a method of Disposition.
5. Archives
   University Records deemed to have historical value will be identified in the RCRS for transfer to the University's Archives as their method of Disposition. These transfers must be governed by a written agreement. Records transferred to the University's Archives will remain accessible to the Responsible Unit and may be subject to a FIPPA Access to Information request.

Monitoring and review

These Procedures will be reviewed every three years. The University Secretary delegate is responsible to monitor and review these Procedures.

Relevant legislation

Freedom of Information and Protection of Privacy Act, RSO 1990, c F.31

Related policies, procedures & documents

Records Management Policy

Records Classification and Retention Schedule 

Disposition Authorization Form

Document Imaging Policy

Access to Information and Protection of Privacy Policy