DEVELOPING AN AGENCY RECORDS DISPOSITION AUTHORITY
Procedures for State Officials
A Publication of the Alabama Department of Archives and
Approved by the State and Local Government Records Commissions
Appraisal of records
Alabama law (Code of Alabama 1975, Section 41-13-21 and 23) calls for the classification of records by the State Records Commission as part of the process of determining the retention requirements of records. The Commission has established procedures for the classification of records in order to authorize the disposition of the records. These procedures are part of the process called records appraisal.
The appraisal process involves:
- researching the agency's history, functions, and records practices;
- examining the agency's records and assessing their value;
- grouping records by function and subfunctions and determining the appropriate disposition guidelines for the records;
- submitting the draft Records Disposition Authority to the State Records Commission for review and approval.
Agency staff, working with Commission staff, is responsible for completing this process.
1. Agency Records Disposition Authorities (RDAs)
A Commission-approved Records Disposition Authority (RDA) authorizes an agency to dispose of those records identified as no longer necessary to retain. An RDA is prepared and presented to the Commission for approval. Records Disposition Authorities govern the disposal of two types of records: general administrative records that are common to all agencies and programmatic records that are specific to the function an agency performs.
The Commission meets quarterly to evaluate requests for the establishment of agency RDAs. Records Disposition Authority requests are prepared and submitted by state officials with the assistance of the staff of the Government Records Division of ADAH.
2. Steps in Developing a Records Disposition Authority (RDA)
Agencies should make a formal request for assistance to the Government Records Division. This request should take the form of a letter from the agency head or his/her designee asking for Commission staff to work with agency staff on developing an RDA. A Government Records Division archivist will be assigned to work with the agency through the following steps:
2.1. Establishing an Agency Committee
To organize agency work, a committee representing each unit, division, or office provides a useful mechanism for ensuring an effective and comprehensive records review. The agency committee should include agency division heads, program managers, information system managers, and the legal counsel with a records officer or manager designated by the department head to serve as overall coordinator. The committee members should have the authority to speak for their respective offices regarding the disposition of their records.
The structure of the committee will vary from agency to agency depending on each agency's size and scope of activity. To assist in the coordination of the program and in reporting to the State Records Commission over time as new issues arise, the committee should continue as a standing committee or the agency should appoint a records officer.
2.2. Organizing Committee Work
The committee should determine a reasonable timetable for completing work. An RDA will generally take three to six months to complete, depending on the size and complexity of the agency. The committee should also be aware of the Records Commission's quarterly meeting schedule in order to meet the deadlines and be included on the agenda for the next meeting. Below are the steps the committee should follow in completing its work. These steps may be followed one after another or may be completed as one step during the inventory of agency records.
2.2.1. Identify the Agency's Records Requirements
The committee should conduct research using the agency's annual reports and office procedures, the Code of Alabama, and any other useful information to determine the legal and administrative requirements that affect the agency and result in the creation of records.
2.2.2. Inventory the Agency's Records
The next step is to inventory the agency's records. Each organizational unit/division/office should identify the records it creates. These records may be maintained as microfilm, as paper, as data on a mainframe or personal computer (PC), or as any other media. The records should be listed in groups relating to how they are filed, the name of computer system in which they are stored, and by the process or activity from which they result. The committee should gather all of the division records lists together and review them to ensure that all the agency's records are included.
2.2.3. Identify Record Retention Requirements
Using the agency's records requirements identified in step 2.2.1 and the records lists generated in step 2.2.2, determine the length of time each group of records should be maintained. Note the retention beside the record on the agency inventory. Make sure to cite the law, rule, regulation, or professional practice next to the retention requirement. The agency's legal counsel should be consulted about the retention of agency records. Examples of considerations that affect records retention include:
- legal requirements (laws, regulations, court orders)
evidence of rights or obligations (either of the government or of citizens whose interests are reflected in these records)
- financial or audit requirements
- policy and precedent value
- research value
Examples of some of these requirements are:
Other considerations that may affect how long to retain the records are:
The Code of Alabama 1975, Section 41-5-14, requires periodic examinations and audits of state and county offices, and departments. All records subject to audit must be retained until the audit is completed and all audit issues are resolved.
- The Uniform Administrative Requirements for Grants and Cooperative Agreements to State and Local Governments (Common Rule) requires the retention of financial and programmatic records for three (3) years from the date the grantee submits its single or last expenditure report for that period.
their value as a source of information about the subject they document
- the existence of duplicate copies
- their reliability and completeness
- their accessibility and usability
- the cost of their maintenance and retention (storage, transfer, preservation, retrieval and access)
These additional considerations are not records requirements grounded in law or policy. Nevertheless, they are issues that affect how long and where records should be kept. Using these various records requirements, the committee should recommend the minimum length of time each group of records should be retained under normal conditions. Staff of the Government Records Division is available to assist in determining these time periods. The committee should submit the completed listing of records to the Government Records Division for formatting as an RDA.
2.2.4. Identify Permanent Records
Most of an agency's records are temporary records that will someday be destroyed. A few records, however, will be deemed permanent records having administrative and historical significance. These records should be identified through the combined efforts of the agency staff and the Government Records Division staff. Government Records staff will assist in justifying or explaining the identification of these records as permanent to the State Records Commission.
3. Government Records Division Staff Responsibilities
Staff members of the Government Records Division are responsible for completing a functional analysis of the agency. This process includes identifying the agency's primary mandated function, subfunctions, and activities. A function is a group of activities that together support the furthering of the mission of the agency. Each agency has one primary function. However, functions may have large subcategories and subfunctions that best describe the overall agency mandates. An activity further breaks down a subfunction into its component parts. Example: Office of the Attorney General (agency), Public Advocacy (function), Advising (subfunction), Issuing Opinions (activity).
Government Records Division staff is also responsible for completing the justification of permanent records. The agency's listing of records is combined with this permanent records justification and the agency functional analysis to form the three reports comprising the draft RDA. These three reports are entitled: "Functional and Organizational Analysis of the Agency," "Analysis of Record Keeping System and Records Appraisal of the Agency" and "The Agency Records Disposition Authority".
4. Review and Approval of the RDA
The completed draft RDA should be reviewed and approved by the agency committee, then forwarded to the Government Records Division for review and inclusion on the State Records Commission's agenda.
The Records Commission may approve, modify, or table the RDA. Usually, a request may be carried over if it contains insufficient information to allow an evaluation of the record keeping practices of an agency or if questions arise that require additional study. An approved RDA becomes the authority for the disposition of public records within an agency. The chair of the State Records Commission signs the approved RDA. It is then returned to the agency for the signature of the agency head. The RDA only becomes the agency's legal authority to dispose of government records when both signatures are present.
5. Developing Procedures for Implementation
The work of the agency committee does not stop here. Once the agency has an approved RDA, the agency should implement an ongoing process for records disposition. Regular implementation of an approved RDA is one component in the development of an effective records management program. For information on the other components of a records management program, please contact the Government Records Division at (334) 242-4452. Current copies of ADAH publications, training opportunities, and other information are available on the department's web site at http://www.archives.state.al.us/index.htm.
Alabama Department of Archives and History
Government Records Division
P.O. Box 300100
Montgomery, AL 36130-0100
Telephone: (334) 242-4452 FAX: (334) 240-3433
ADAH web site: http://www.archives.state.al.us