1
The R.A.C.I. matrix is used to organize these guidelines and best practices. The matrix explains the roles and responsibilities of the various DEO personnel in the
implementation of DEO Policy 4.09. The DEO personnel are classified in the R.A.C.I. matrix as follows:
Executive Director
Records Custodians
Program Areas
DEO Associates
Records Management Liaison Office (RMLO)
IT (DEO Office of Information Systems and Support Services)
The R.A.C.I. matrix lists each major activity within the DEO Policy 4.09 and specifies the role for each type of DEO personnel listed above. The possible roles are as
follows:
R –
Responsible
for performing the task; the person doing the work to complete the task
A –
Accountable
for the task being done in a satisfactory manner
C –
Consulted
with and whose input is used to complete the task
I – Informed as to the status of the task
Reemployment Assistance (formerly UC) Program Experience
The Reemployment Assistance (RA) Program has been working toward implementation of this policy since May 2011, when it was initially a proposed AWI policy. The
manner in which the RA Program Area has organized to implement the policy is instructive and can serve as a useful model for other DEO Programs.
The head of the RA Program appointed representatives from all the various program areas within RA to a records retention working group. Some participants were from
other areas of the state and participated via teleconferencing. This working group began meeting every 3 weeks to identify the required tasks to implement the policy, to
make assignments, and to report on their completion. Meeting notes/minutes were distributed to keep everyone informed and working together on a common understanding
of the responsibilities and assignments. A Records Management Plan for the RA program was developed that can be used as a template by other DEO programs.
Three sub-groups were formed to address the unique requirements for each major category of electronic records, as follows:
Applications (supported by IT)
Shared Folders/File Servers Records
These three working groups also met regularly to discuss and define the requirements for implementing the policy within the RA Program as it pertained to those types of
records. The RA Program’s experience is an example and a useful reference model for the practical implementation of the policy.
2
Informed
Those people who are informed as to the status of the task, thus, communication with this group is 1-way in nature.
ID
#
Activities to Implement DEO Policy 4.09
Executive
Director
Program
Areas
RMLO
Records
Custodians
Associates
IT
1
Establish and maintain an active and continuing program for the
economical and efficient management of records.
Guidelines: Chapters 119 and 257, F.S., place a variety of public records management responsibilities on agencies. The Department of State has overall authority in these matters and has established administrative rules, guidelines and training to assist agencies in meeting their responsibilities.
Responsibility for properly maintaining public records begins with the head of the agency. The RMLO and records custodians are also specifically designated with carrying out certain responsibilities.
The Department of State document “Electronic Records and Records Management Practices” outlines eleven program elements necessary for a records management program. The link to this document is: http://dlis.dos.state.fl.us/barm/handbooks/electronic.pdf
Best Practice: A coordinated and collaborative effort that includes the
DEO Executive Director and other DEO management is established for
records management and also includes the expertise of the DEO
Records Management Liaison Officer, IT staff, legal staff, and records
custodians.
3
#
Director
Areas
Custodians
2
Designate a Records Management Liaison Officer (RMLO).
Guidelines: Section 257.36(5)(a), F.S., requires each agency to designate a records
management liaison officer to serve as the primary point of contact between the agency and the Department of State’s records management program. To appoint an RMLO, an agency needs to submit a Department of State (DOS) appointment form.
The RMLO might perform a variety of records management functions including :
• maintaining a current inventory of agency records;
• liaison with the DEO Program Areas and DOS to establish new records retention schedules ;
• liaison with the DEO Program Areas and DOS to ensure the appropriate disposition of records eligible for destruction;
• training and advising DEO staff in records management practices;
• participating in agency decision-making for issues such as microfilming, imaging, storage, and disposal of records;
• responding to public questions regarding agency records and records management practices; and
• reporting annually to the DOS regarding the agency's compliance with records management statutes and rules.
Best Practice: The Department of State recommends that the RMLO be a
senior-level position or report to a senior-level position, and has the
authority to establish and implement an agency-wide recordkeeping
program.
4
#
Director
Areas
Custodians
3
Designate Records Custodians for each Agency Program Area.
Guidelines: Records Custodians are responsible for ensuring that official state records are properly maintained and processed according to agency policies and procedures and the appropriate retention schedule. Records custodians are responsible for paper and electronic records and work closely with the agency RMLO.
Best Practice: Each Program Area decides how many records
custodians it needs to designate in order to properly manage its
records, and ensures that they receive proper training.
R, A
C, I
I
I
I
4
Ensure that DEO records have an associated records retention
schedule, and request agency-specific retention schedules, as needed
Guidelines: A records retention schedule describes a records series (a group of related documents) and sets a minimum period of time for which the records must be retained before final disposition of the records can occur. These retention periods are determined by the content, nature and purpose of records, and are set based on their legal, fiscal, administrative and historical values.
The Department of State establishes the approved records retention schedules for agencies to use, and publishes them in the General Records Schedule GS1-SL for State and Local Government Agencies: (http://dlis.dos.state.fl.us/barm/genschedules/GS1-SL.pdf)
If the retention schedules in the General Records Schedule for State Agencies (GS1-SL) do not adequately address all of the Program Area’s records, then the Program Area may apply for an “Agency Specific Records Retention Schedule.” A specific form for this purpose, Records Retention Schedule Form LS5E105, is required to be submitted to the agency’s Records Management Liaison Officer who will forward it to the State Records Center’s Records Analysis Section for assistance and approval. W:\Taskforce_ERecords_Retention\3- Deliverables\AWI Policy 4.09\Policy and Forms\AgencyUniqueRetentionSchedule_Form.docx
Best Practice: Each DEO Program Area annually reviews its e-records
inventory and revises its retention schedules, as necessary, working
with the RMLO and requesting agency-specific records retention
schedules as needed.
5
#
Director
Areas
Custodians
5
Ensure that each email message and attached document, if any, are
examined to determine which retention schedule applies, and are
retained for the applicable retention period.
Guidelines: There is no single retention schedule that applies across the board to all emails. Email can have a variety of purposes and relate to a variety of program functions and activities. The retention period of any particular email message will generally be the same as the retention for records in any other form that document that same program function or activity. For example, if the content of an email concerns non-capital improvement agreements, retention schedule GS1-SL Item #65 requires the email to be retained for five (5) years after completion or termination of the contract, provided applicable audits have been released.
Best Practice: Each DEO Associate determines what the retention
period is for each email that is created or received by them. The
following are categories of emails that should be deleted as soon as
possible:
•
Personal emails
•
Emails that are transitory records
•
Emails that are copies that you are not expected to and did not
take action on
For emails that must be retained, each DEO Associate ensures that they
are retained for the appropriate retention period. (See Appendix C of
these guidelines.)
6
#
Director
Areas
Custodians
6
Designate which version or format of each record is the official record
(master) copy.
Guidelines: The official record (master) copy can be in electronic or paper format. These cannot be disposed of until their associated retention schedule has been met. Required disposition documentation must be provided to the agency’s Records Management Liaison Officer (RMLO).
http://www.floridajobs.org/forms/recordsmgt/GSR-2_RecordsDisposition.doc Most duplicates of records, however, can be disposed of at anytime and do not require the filing of the disposition report with the RMLO.
Best Practice: DEO Program Areas ensure that the record or master
copies of their records are stored in a system that is regularly
maintained and backed up by IT so that they could be recovered, if
necessary, and that duplicates of records are disposed of when no
longer needed.
A
C, I
R
C
I
7
Maintain an inventory of all records retention schedules for DEO
records and annually review and update it.
Guidelines: The RMLO works with the Records Custodians for each Program Area to conduct an annual review of the records retention schedules for all types of records (paper and electronic) and revises the DEO inventory as necessary.
Best Practice: The DEO inventory of all records retention schedules is
updated at least annually and made available on the DEO Intranet so
that it is easily accessible by the Program Areas.
7
#
Director
Areas
Custodians
8
Provide training and technical assistance on records management.
Guidelines: The Division of Library and Information Services, Department of State, offers a series of seminars on basic records management in various locations around the state of Florida. These seminars are designed for individuals who have assumed records management
responsibilities, are employed by newly created public agencies, or desire a refresher course in records management.The DOS also makes available, upon request, Records Management Webinars to provide agencies with an efficient and economical alternative to on-site training.
Additionally, there is an email list managed by the DOS to which all records management staff can subscribe. This list is used by the Records Management Training Section of the Division to provide members with information regarding records management.
Best Practice: The RMLO develops, in consultation with the DEO
Bureau of Human Resources Management, a training module related to
records management that is required for all DEO employees. The RMLO
also develops more detailed records management training for the
records custodians, and DEO Program Areas may develop training for
their unique records management procedures. Additionally, the RMLO
works with the DOS to ensure that all DEO Records Custodians receive
DOS training and are included in the DOS email list.
8
#
Director
Areas
Custodians
9
Complete the required Agency Records Management Training Course
and read and understand the policies and procedures for Records
Management.
Guidelines: Training for individuals who create, edit, store, retrieve, or dispose of records is an important aspect of records management. Training should enable agency personnel to:
• identify public records;
• understand how records are filed in an electronic recordkeeping system;
• understand how records are safeguarded;
• know what procedures are used to edit records; and
• understand how records should be disposed of according to legal requirements. Agencies must ensure that record (master) copies of electronic records are maintained by personnel properly trained in the use and handling of the records and associated equipment.
Best Practice: Required DEO records management training includes all
the necessary elements and a signed certification by each DEO
employee as to their completion of it and their understanding of their
records management responsibilities.
9
#
Director
Areas
Custodians
10
Establish and maintain a records management plan.
Guidelines: Document management is the process of handling records or documents in such a way that information can be created, shared, organized, stored and controlled efficiently and appropriately. This can include rules for:
• creating documents/records, such as a style guide and templates;
• storing records, such as standard naming conventions for documents, folders, and files;
• creating an index to the file locations for easy retrieval of records; and
• securing, sharing and disposing of records.
The DOS has published several guidelines to assist agencies in this process.
http://dlis.dos.state.fl.us/barm/handbooks/fileshandbook.pdf http://dlis.dos.state.fl.us/barm/handbooks/electronic.pdf http://dlis.dos.state.fl.us/barm/handbooks/basics.pdf
Best Practice: Each DEO Program Area develops and maintains
through a regular review process a written records management plan
for both its paper and electronic records.
10
#
Director
Areas
Custodians
11
Establish procedures for addressing records management requirements
for all electronic recordkeeping systems (existing, new, upgraded,
enhanced, replaced, or those to be sunset).
Guidelines: DOS Rule Ch. 1B-26.003, Electronic Recordkeeping, requires agencies to establish procedures for addressing records management requirements before approving, recommending, adopting, or implementing new systems or enhancements to existing systems.
http://dlis.dos.state.fl.us/barm/rules/1B26_003FAC.cfm
A flowchart of the 7 steps necessary to incorporate records management requirements in systems (applications) is attached as Appendix A to these guidelines.
Best Practice: DEO Program Areas consult with the RMLO regarding
their records management requirements before a new or enhanced
information system is approved for their use. DEO IT incorporates the
DOS rule requirements and the flowchart as part of its project
governance approach and methodology.
A
C, I
R
C
C, I
12
Provide for regular recopying, reformatting, and other necessary
maintenance to ensure the retention and usability of electronic records
throughout their retention period.
Guidelines: Records that are part of IT-supported application systems, shared file server system, or email system are regularly backed-up to ensure their retention and usability throughout their retention period. If, however, DEO Program Areas maintain other record systems of their own, they must comply with this requirement to ensure that those records are retained and accessible even if the technology used to originally create them becomes obsolete.
Best Practice: DEO Program Areas that maintain their own software
annually test it to ensure that the records maintained by that software
are still accessible and usable.
11
#
Director
Areas
Custodians
13
Ensure that all DEO data sharing agreements providing DEO data to
other entities are subject to and will adhere to all Florida laws and
policies on records management and will follow the DEO records
retention schedules.
Guidelines: DEO Program Areas that enter into data sharing agreements with other agencies or organizations should include a clause that addresses the records management requirements related to those records, including their retention period and disposition.
Best Practice: The DEO Office of General Counsel drafts a model
clause for inclusion in all DEO data sharing agreements that addresses
this topic and ensures its inclusion as part of their review of all such
agreements.
A
C, I
R
C
C, I
14
For paper records, enter information into the DOS Total Recall System
to add new records and retrieve records stored at the State Records
Center, order necessary storage supplies, and pack and label cartons in
accordance with storage guidelines.
Guidelines: The DOS provides detailed instructions on how to store and retrieve paper records. These are included in the DEO Policy 4.09, along with the specific forms to use.
Best Practice: All DEO Records Custodians consult with the RMLO and
follow the storage guidelines established by DOS for paper records.
12
#
Director
Areas
Custodians
15
Maintain all DEO documentation on compliance with records
management.
Guidelines: An important element of the agency’s records management program is keeping the documentation of all agency actions so that compliance with the records management
requirements is easily demonstrated. This documentation includes such items as:
• Records inventory;
• Certification of records management compliance by the Program Areas; and
• Permanent retention of records disposition reports.
Best Practice: The DEO RMLO maintains up-to-date DEO
documentation on compliance with records management that is stored
in an electronic system maintained by IT, so that it is easily accessible
and recoverable.
A
I
R
C
C
16
Make system changes to implement records management requirements.
Guidelines: Appendix B of these guidelines is a flowchart that identifies the requirements to be met by the retrofit of the existing IT- supported applications in order for them to be compliant with the records management requirements.
Initial high-level cost estimates to retrofit existing applications to address the disposition
requirements for records were calculated in January 2011, by the IT Application Managers for the AWI IT- supported applications, at that time.
Best Practice: Each DEO Program Area defines its records
management requirements and discusses these with the RMLO and
their IT Application Manager in order to pursue needed changes in
existing applications, as resources allow.
13
#
Director
Areas
Custodians
17
Identify when records have met their retention period.
Guidelines: Once records have met their minimum retention period, as defined by their associated record series, they may be disposed of. Timely disposal of records that are eligible for disposition is an important element of records management. It reduces the volume of records stored and limits the future liability of the agency to review and produce records in future legal cases, public records requests, investigations, and audits.
In many cases, the DEO Program Areas have not established records management procedures that would easily allow for the identification of existing records that are eligible for disposition. Therefore, two separate, yet related, activities to achieve this requirement may be necessary.
One activity would focus on existing records and developing a means to identify those eligible for disposition. This may require each DEO Program Area working closely with IT in order to understand how their records may be searched for various criteria related to their retention periods.
The second activity would focus on establishing records management procedures for the creation and storage of future records so that identification of when those records are eligible for disposition would be readily known. This could include developing the functional requirements for an automated system to assist in the records management process.
Best Practice: DEO Program Areas establish mechanisms (manual or
automated) for determining when their records have met their identified
retention period and are eligible for disposition.
14
#
Director
Areas
Custodians
18
Implement a required retention hold for legal, audit, public records, or
investigative purposes.
Guidelines: In certain instances (audits, legal cases, investigations, public records requests) records that would have been eligible for disposition must be retained. This is referred to as a retention hold on those records. Such records must be kept until the triggering event for their retention hold has been completed, at which time the records may be disposed of.
Best Practice: The DEO Office of General Counsel, in conjunction with
the DEO IG’s Office, the DEO Division of Finance and Administration,
and the DEO Office of Information Systems and Support Services,
develops processes and procedures to provide for the appropriate
retention hold on records in the case of legal cases, public records
requests, audits, or investigations.
15
#
Director
Areas
Custodians
19
Approve and justify any extensions to retain records longer than their
retention period by completing a DEO Justification to Extend Records
Retention Period Form.
Guidelines: Records that have met their retention period are eligible for disposition. If a Program Area Manager determines that there is a programmatic need to retain those records for a longer period of time, or if there is a retention hold for legal, audit, investigative or public records request, then a special form must be completed and submitted to the RMLO.
W:\Taskforce_ERecords_Retention\3- Deliverables\AWI Policy 4.09\Policy and Forms\Justification to Extend Records Retention final for Task Force.docx
This form requires additional information to be provided by the Program Area, if the records are being kept longer than their required retention period for programmatic reasons. The Program Area must estimate the potential costs associated with that action, based on their previous costs associated with public records searches and other factors.
Best Practice: DEO Program Areas complete a DEO Justification to
Extend Records Retention Period Form each time they decide not to
dispose of records that are eligible for destruction.
16
#
Director
Areas
Custodians
20
Ensure that all records that have met their retention period are properly
documented and disposed of.
Guidelines: Section 119.0219(2)(c), F.S., requires agencies to “systematically dispose of records no longer needed . . . .” The Department of State requires that records must have a records retention schedule before they can be disposed of.
Electronic records can be divided into three major categories for records management purposes: Applications
Shared Folders/File Servers Records Emails
Identifying when records have met their retention period can be an automated or a manual process.
When records have met their retention period, as determined by their retention schedule, they are eligible for disposition, and one option is to permanently dispose of them.
When disposing of records that contain sensitive, confidential or exempt information care must be taken to ensure that the records cannot be read or reconstructed. The Information
Technology Operations Manual Protocol 5.05,02 governs the process for disposing of electronic data. DEO Information Technology Operations Manual Protocol 5.05.02 (IT Security / Risk Mitigation
Services)
With the exception of duplicate copies of records, when disposing of records (whether paper, electronic, confidential or not) a “Records Disposition Document” form must be completed and sent to the DEO Records Management Liaison Officer (RMLO).
http://www.floridajobs.org/forms/recordsmgt/GSR-2_RecordsDisposition.doc This form is kept by the RMLO as a permanent record of the action.
Best Practice: All DEO Program Areas follow proper procedures and
document the disposal of their records when those records are eligible
for destruction.
17
#
Director
Areas
Custodians
21
Annually complete and sign a DEO Records Management Compliance
Certification Form.
Guidelines: The Director of each DEO Division must annually complete and sign this form attesting to certain records management actions. Records Management Compliance Certification Form
Best Practice: All DEO Division Directors annually complete and sign
the DEO Records Management Compliance Certification Form and send
it in a timely manner to the RMLO.
R, A
C, I
C
C
22
Annually complete and sign a DOS Records Management Compliance
Statement.
Guidelines: Florida Administrative Code Rule 1B-24.003(11) states: "Each agency shall submit to the Division, once a year, a signed statement attesting to the agency's compliance with records management laws, rules, and procedures." It is important that the agency return the Compliance Statement in a timely manner, as the DOS is required to report to the Governor and Legislature annually on records management compliance. Annually, the DOS sends each agency a brief form to complete and return. The form asks:
1) if the agency had conducted certain activities reflecting compliance with records management requirements;
2) the quantity of public records destroyed in the past fiscal year; and 3) what needs, if any, the agency has for records management training or
assistance.
The agency is also asked to provide updated RMLO information.
Best practice: DEO Executive Director annually completes and signs
the DOS Records Management Compliance Statement and sends to the
DOS in a timely manner for inclusion in its report to the Governor and
Legislature on records management compliance.
18
Upgrade orEnhancement to Existing Information
System
New or Replacement Information System
Sunset of Existing Information System
Program Area owner of affected Information System consults with the
RMLO and IT Application Manager.
Records management requirements of the system are addressed, including
recordkeeping requirements and disposition.
System modification, development, or sunset proceeds, as applicable, incorporating records management requirements determined necessary.
Does change affect
records? If Yes
If No
RMLO documents changes in records retention schedules, if any,
in the DEO E-Records Inventory.
1. Are the records series associated with the system accurate and complete? 2. Is there a means to: A. Identify records eligible for disposition?
B. Extend the retention period? (Hold or Justified) C. Review the identified records prior to disposition? D. Sign-off on the records disposition?
E. Dispose of records? F. Provide a post-deletion report with required DOS info?
19
Are records retention and disposition requirements of
the system(s) addressed?
2. Is there a means to: A. Identify records eligible for disposition?
B. Extend the retention period? (Hold or Justified) C. Review the identified records prior to disposition? D. Sign-off on the records disposition?
E. Dispose of records? F. Provide a post-deletion report with required DOS info?
No changes to
system(s) required If Yes
Requirements to bring system(s) into compliance are defined.
A project budget(s) for bringing system(s) into compliance is developed and submitted.
Is budget for project(s) approved?
Service Request or Project developed to bring system(s) into compliance
Modifications made to system(s) to bring into compliance If No
If Yes No system
changes are made to bring into compliance.
20
Email is Sent orReceived
Is the email a personal message? (not a public record)
Delete as soon as possible
Each DEO Associate: 1. Determines for each email that is received or sent which retention schedule applies, and 2. Saves the email, along with the associated transmission data and attachments, for the required retention period.
Has short-term value and is not intended to formalize or perpetuate knowledge, does not set policy, establish guidelines or procedures, certify a transaction or become a receipt.
Examples: 1. Office announcements 2. Meeting reminders
If Yes
Examples: 1. Correspondence and Memoranda: Program and Policy Development #338 2. Complaints: Citizens/ Consumers/Employees #94 3. Grant Files: Grantor Agency #109
Is the email a transitory record?
If No
If Yes
Is the email a copy that you were not expected to and did not
take action on? If No
If Yes
