Records conveyed electronically are subject to University and departmental retention schedules. See 90.01. Electronic communication records may also be subject to public records requests, legal discovery, and audit review.
Electronic communication methods include, but are not limited to, e-mail, instant messaging, social networking (e.g., Twitter, blogs, wikis), and text messaging.
For retention purposes, electronic communications are considered methods of delivery rather than record types. Electronic communications, like conventional paper-based mail, can convey many kinds of records and messages. As such, electronic communications are to be managed by message content.
The University does not have a central process for managing electronic communication records, thus management responsibility resides with University staff and departments.
RETENTION OF ELECTRONIC COMMUNICATIONS
Personal Electronic Communications
If conditions specified in 20.37 are met, University employees may make occasional but limited use of University computers or accounts to briefly retain personal electronic communication messages unrelated to official University business.
Personally-Owned Computers or Personal Electronic Communications Accounts
University employees should not use personally-owned computers or personal accounts (e.g., non-University e-mail accounts) to retain official University business-related electronic communication messages.
- When working from personally-owned computers, employees are encouraged to use remote desktop connections and retain official messages on University computers and accounts.
- When it is necessary to generate an official message on a personally-owned computer or account, the employee is responsible for expediently moving the message to a University storage device or computer for retention.
NOTE: University business-related electronic communications stored on non-University computers or electronic communications accounts may be subject to public records requests, legal discovery, court-ordered production, audit review, and records retention requirements.
Social Networking Websites
When retention of authorized electronic communications is outside University control, e.g., retention of postings to social networking websites, departments must consider what other records need to be retained. E-mail confirmations of each post or comment are possible examples.
Departments must consider records retention issues when considering any agreements with vendors of social networking websites and when configuring settings for departmental social networking website accounts.
Electronic Communications That May Be Deleted When No Longer Needed
As described below, many electronic communications consist of transitory messages. As such, many electronic communications and attachments may be deleted when no longer needed.
Meeting notices and requests for meetings may be deleted when no longer needed.
Copies used for informational/reference purposes may be deleted when no longer needed.
Electronic communications records that have no administrative, legal, fiscal, or archival retention requirements may be deleted as soon as the messages have served their purpose. See "Administrative Materials With No Retention Value," in 90.01.12. Such records include:
- Information-only copies, or extracts of documents distributed for reference or convenience, i.e., announcements or bulletins
- Copies of published materials
- Telephone message notifications
- Preliminary drafts, unless a retention period is otherwise specified on an applicable records retention schedule
- Transmittal memos
- Reservations and confirmations
- Copies of memoranda, bulletins, or directives of a general information and noncontinuing nature
Electronic communications records meeting the definitions included in "Reference Files," in 90.01.13 may be deleted when no longer needed. Such records include:
Reference files containing copies of correspondence, memoranda, copies of reports, studies, articles, reference copies of minutes, distribution lists, and other general reference information on office administrative issues and concerns, used to support administrative analysis, planning and development.
Electronic Communications To Be Retained
Electronic communications and attachments that contain record material must be retained in conformance with the applicable retention schedule. See 90.01.
The following types of electronic communications messages and attachments are likely to include records with specified retention periods:
- Electronic communications that authorize some official action, transaction, or effort.
- Electronic communications that support or explain a business transaction.
- Documents that complete a business transaction.
- Final reports or recommendations.
- Documents relating to audit or legal issues.
- Electronic communications in support of student class activity, e.g., assignments, class participation.
- Official correspondence that does not fit in another records series. (Non-executive-level general office correspondence is to be retained for at least 30 days. See 90.01.12.)
Most executive records are retained for four years after the end of the current fiscal year. This includes official correspondence concerning policy issues, concerns, actions or issues. (NOTE: For purposes of this policy, officials with the status of dean or above are considered executives.) See 90.01.10-11.
PRIMARY RECORD HOLDER
It is important to determine who holds the primary record of a document for retention purposes. Reference or informational copies may be deleted when no longer required by the record holder (see above).
The retention schedule usually identifies the office responsible for retaining the official record copy. If the retention schedule does not provide sufficient guidance, refer to the following:
- Ask how would this record be handled if it were a hard-copy transaction or letter. In such cases, the recipient is responsible for retaining the record copy.
- If an electronic communication is sent to a large number of recipients, the sender is responsible for retention of the electronic communication as well as the distribution list.
A draft of a policy is sent to a number of reviewers. The initiator of the draft is responsible for retaining the record copy.
An agenda or meeting minutes are sent to a number of attendees. The sender is responsible for retaining the record copy.
MANAGEMENT OF ELECTRONIC COMMUNICATION RECORDS
University departments and personnel may use one or more of the following methods to assure appropriate management of records with assigned retention periods.
Retain in Electronic Communication Application Format
Retain the message in the original electronic communication application format on the record holder's hard drive; removable digital media; or an external storage service or device. The original electronic communication application format is likely to capture and preserve all relevant metadata and attachments related to the record. Metadata is defined as data about data and may describe the content, time, date, author, and formatting of a message. Metadata may be used to aid in the storage, indexing, and retrieving of electronic records for public use.
NOTE: Printing and retaining a paper copy of an electronic communication is not a substitute for the electronic version, in accordance with WAC 434-662-040.
To facilitate retrieval, retention, and eventual disposal, the record holder could establish separate folders. Each folder could correspond to a specific scheduled records series. Electronic communications folders should be coordinated with any paper or other electronic filing systems that are in place.
Retain in Document Management System
Electronic communication messages may be retained in a document management system (DMS) or records management application (RMS). Such systems offer sophisticated control of electronic records, allowing integration of electronic communication messages within the total document environment of an organization. Such software offers single point access to a variety of formats, thus preserving the functionality of documents. NOTE: The DMS or RMS software must have the capability of capturing and preserving all relevant metadata and attachments related to the records.
Many electronic communication messages must be retained longer than the original technology that was used to send, receive, or store them. Departments are responsible for ensuring that older electronic communication messages are migrated to newer technology.
Employees are encouraged to review the privacy provisions of EP4, Electronic Communications Policy.