For PDF see Guidance on Review of Records for Disposal Purposes

Context

Review is chosen as the disposal action for records within a series when it is not clear, at the time of creation and closure, how long they may continue to be of value.

Every year, a quantity of closed records will become liable for disposal actions, having come to the end of the retention period assigned to them in the Records Retention Schedules.

Where records are liable for Review, they must be inspected to determine whether

• They are of no further business, legal, audit, or historic value (see below), and so may now be destroyed/deleted
• They are of historic value, or of indefinite business value, eg, for precedent purposes, and so may be reclassified as archives
• They are still of business, legal, audit, or reference value, and so should be retained for a further retention period and reviewed again thereafter

It is important that records are not retained indefinitely ‘just in case’. There must be documented reasons for extending retention, signed and approved by relevant staff.

Purpose

This procedure details the steps to be taken when assessing records at the end of their retention period with a disposal action of review.

Procedure

Step 1: Assess the Ongoing Value of the Record

Questions to ask when assessing value and deciding what to keep on Review:

1. Do you still need the records to carry out business in your area? (Eg, files still consulted)
2. Is there a legal or audit requirement to continue to retain the records? (eg, new legislation)
3. Are the records still needed as evidence of how a decision or policy was made, eg, if challenged in court, or for public accountability? (a published policy or report, once properly approved, may obviate the need to keep related records on an ongoing basis)
4. Are the records of clear and significant precedent value? (eg, for dealing with similar situations in the future which are likely to arise)
5. Are the records needed to protect the legal rights and interests of the University or of individuals? (eg, property rights)
6. Are the records of research or historical interest? (eg, relating to a major new partnership. The University Archivist plays a role in Review for archival purposes: see below)

If you answer yes to any of questions 1-3, the file should be retained for further review, to occur at the termination of a second retention period. This second period will generally be the same as the first period as applied under the Schedule, unless new legislation or policy requires longer or permanent retention.

If you answer yes to any of questions 4-6, the files should generally be designated as being of archival value, and prepared for transfer to archives (see below)

Step 2: Document the Decision

Complete the standard Records Review Form as part of the review process, and retain for record purposes. While the head of each Functional Area (UMT member) is ultimately accountable for records management in their area, it is the manager in each school/dept/unit who is responsible for compliance locally, and who is to sign the Records Review Form.

Staff may be delegated responsibility for carrying out the Review and noting the reasons for keeping or destroying the records, for the guidance of the manager.

The University Archivist is to counter-sign the form to approve where records are re-classified as archives.

If you have queries on the re-classification of records for destruction/deletion on review, you may contact the University Archives (archives@ucc.ie).

Step 3: Implement the Decision

There are three possible outcomes to the review.  The records are to be:

1. Destroyed or deleted;
2. Reclassified as archives; or
3. Retained for a further period at the end of which they will be reviewed again.

If the records are to be destroyed or deleted then follow the records destruction procedure.

If the records are to be reclassified as archives then follow the transfer to archives procedure.

If the records are to be retained for a further period, the basic retention period set out in the RRS will generally be the period of time applied before the records are liable for a second Review.  Where records are Reviewed a second time and it is judged that they may not be destroyed/deleted, they will generally be re-classified as archives at that point, unless there are clear grounds for not doing so, as advised by the University Archivist.