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