Maintaining Digital Records: Permanent vs. Short Retention Periods

If you are effectively maintaining digital records, can you dispose of the original, hard copy documents?

Public entities have the authority to decide in which medium they will maintain their records and can create schedules that divide a records series’ retention period based on storage location or media type. For example, a public entity’s record retention schedule could require it to “maintain the paper version of a record until it is scanned and quality control checked, then dispose; retain electronic version for 10 years.” 

However, if records are required to be maintained permanently, public entities are discouraged from maintaining solely in a digital format. The Ohio History Connection has issued a statement on maintaining digitally imaged records permanently which states its recommendation that any digitally imaged records of permanent value also be maintained in either paper or microfilm format. There are several reasons for this recommendation because the technology surrounding electronic records are in a continuous state of change. Any record in electronic format cannot be considered stable and capable of remaining reliable, authentic, and accessible over any long-term or permanent retention period.

The Ohio Electronic Records Committee has also put together several resources that provide information on the requirements, guidelines, and best practices for digital document imaging projects. You can view these resources here: Document Imaging – Ohio Electronic Records Committee (ohioerc.org).

Data as Record: Managing Data within Information Systems

There is so much talk these days about data. Data security. Data privacy. Data classification. Big data. But there isn’t much consideration about data as records. How does “data” fit into the Ohio public records laws and records retention and disposition processes? Are records and data really separate and distinct from one another?

After struggling with these questions in regards to the retention and disposition all of the data sitting in countless information systems, I set out to logically work my way through the questions. First, is data a record? Using the definition of “record” in Ohio Revised Code 149.011 (G) I determined that:
• Data is stored on a fixed medium
• Data is created, sent or received by a public institution
• Data documents functions and activities of the public office
My conclusion is that data, when grouped together and used for a purpose, make records. Data collected for the same purposes, therefore, can be grouped into record series for the application of retention and disposition.

The Ohio Electronic Records Committee [ohioerc.org] recently posted a tip-sheet on Database Records Retention and Disposition [ohioerc.org], created to walk through the concept of records within databases / information systems, which includes the following sections:
• How are database or information systems records defined?
• How long must database or information system records be kept?
• Is it acceptable to keep database or information systems records indefinitely?
• Changing or decommissioning database or information system software
• Procuring new database or information system

This tip sheet will not only give an overview of these concepts, but it can be used to justify including the records manager in conversations throughout the lifecycle of the information system due to their vital role as manager of the records therein. For assistance in responding to public records requests when the requested public records are contained in a database, please see Guidelines for Databases as Public Records.

Pari J. Swift, University Records Manager, The Ohio State University


Fall Online Training Coming!

Mark Your Calendars! The Ohio Electronic Records Committee is tentatively planning an online training for November 4th, 2022 concerning records management best practices in the remote work environment. Records management and educating your offices about record retention requirements is more important than ever when considering the potential of records being handled outside of your office setting as well as how new technology, like Microsoft Teams and Zoom, may introduce new record retention complexities.

Additionally, the OhioERC would like to hear from you regarding what future trainings you would like to see offered from our group. Please fill out the following poll for us to collect your feedback:

For OERC's next training module, what topic would be of greatest interest to you?
34 votes · 34 answers

As always too, please go to our Trainings/Events page to see our interactive training modules and past presentations.