Handbook of Business Procedures

20.6.6. ELECTRONIC RECORDS

A. Introduction

Records created, managed, or retained in electronic formats or automated systems as master records at The University of Texas at Austin or by a private contractor to the university must be retained and disposed of in accordance with The University of Texas at Austin Records Retention Schedule (UTRRS) and university policy. State law regarding electronic records requires that they are individually identifiable and retrievable for their entire retention period and then for as long as they are retained. Backup tapes cannot be considered a method of retaining records unless the backup tape is indexed for individual record retrieval.

B. Master Records Retained in Electronic Format at the Enterprise Level

All departments of the university use enterprise automated systems, such as *DEFINE, Workday, and the Image Retrieval System (IRS), which create or store records electronically. For records maintained at the enterprise level, departments have a responsibility to ensure the integrity of the data entered and the quality of the imaged records. The business owners of these systems are responsible for setting standards and requirements for records or support documentation created in them or submitted/uploaded to them. Enterprise systems retain master records for at least as long as required by all federal and state regulations regarding electronic records.

C. Digitizing Paper Records to be Retained Electronically

A department may choose to image records or use recordkeeping programs at the departmental level. For records maintained electronically at the department level, each department has a responsibility to follow federal and state regulations regarding electronic records. For detailed instructions on meeting required standards for imaging, refer to the Digitized Master Records Acknowledgment. Departments that choose to manage electronic or imaged records must include a signed copy of the acknowledgment in the department’s records management plan.

A department that is considering imaging records must weigh the feasibility of implementing a system that meets:

• format standards
• retrievability standards
• security requirements

Measures must be taken to ensure the ongoing integrity and readability of the records for as long as they are retained:

• A sample of the imaged records must be reviewed annually to ensure continued integrity, readability, and retrievability of the records
• The means — software and hardware — to read and retrieve the records must be maintained
• Plans for conversion or migration must be in place in case changes in technology require that the records be transferred to a new format or system

D. Managing Departmental Electronic Records

Departments are responsible for applying retention to electronic records. Where such functionality is available, systems can be set to notify department records managers when records are eligible for destruction. Master electronic records cannot be deleted or destroyed without an approved request to dispose of records. 

There are several approved repositories for departments to store electronic records. 

• SharePoint
• UTBox
• OneDrive
• Department Servers
• Outlook
• Documentum

E. Annual Disposition Agreements for Master Records

Annual authorization for the recurring disposition of electronic records is available after consulting with Records and Information Management Services (RIMS). Annual authorization allows departments and data stewards to dispose of records in a specified UT Item series throughout the year. Disposition can be either manual or automated deletion. The requirement for the ability to suspend and reinstate automated deletions for legal holds is part of the authorization agreement. Notification for review and renewal of the authorization is issued annually by RIMS. Contact RIMS for consultation about an annual disposition agreement.

F. Master Electronic Records Retained in Third-Party Systems

A department may contract for services that include the creation, management, retention, and disposition of university information and records in non-university systems, such as hosted services, cloud storage, or other systems. Departments must ensure that contracts expressly provide that the contractor will comply with applicable state records management laws and university records management policy. Records in third-party systems may not be destroyed before all retention requirements have been met. Records that have not met retention at the end of a contract must be returned to the university to be retained until they are eligible for disposition. Contract language must also require all third-party custodians of records to provide the university with descriptions of their business continuity and/or disaster recovery plans as regards to the protection of the university's vital state records. Refer to 20.4.4 Contracts Pertaining to State Records for further information regarding contract requirements.

Part 20. Records Management - Table of Contents