Compliance

Records Management Officer Resources

Duties of a Records Management Officer:

The SUNY System Records Management Officer coordinates the proper retention and disposition of records throughout University campuses and at the System Administration Office.  The campus RMO's job is to ensure proper retention and disposition of records at the campus level.  According to SUNY's FOIL (Compliance with Freedom of Information Law) policy, Document Number 6601 “The University shall maintain a reasonably detailed current list, by subject matter, of all records in its possession, whether or not records are available pursuant to subdivision 2 of section 87, of the NYS Public Officers Law (Freedom of Information Law).”  It is the responsibility of the RMO to maintain this records list.

Getting Started as an RMO:

-        Join the SUNY System Records Management Officer Listserv (e-mail Nedra Abbruzzese-Werling , SUNY Records Management Officer at System Administration to be added to the listserv)

-        Read SUNY's Records Retention and Disposition Policy (Document Number 6609) and  pay special attention to the Introduction section.

-          Sit down with each office on campus to find out:

• WHAT records they have
• WHERE the records are housed
• HOW they manage their records on a day to day basis
• IF they have an effective plan for e-mail management

-          Establish a Records Management Liaison/ designee/ coordinator in each office – someone who is charged with ensuring the Records Management of that particular office

• This liaison should be encouraged to contact you regarding records questions they encounter
• Assign this liaison to create an inventory of all the records they have in their area, where they are kept, and the retention schedule that governs each record

-          New York Archives hosts training workshops on Records Management. The full list of trainings is available on the NY State Archives website http://www.archives.nysed.gov/a/workshops/index.shtml

-          Communicate the importance of following the records retention schedule, available at http://www.suny.edu/compliance/topics/recordsretention/

• The SUNY Records Retention schedule has been reviewed and approved by NYS Archives and OSC

-          Ensure that the leaders on your campus know and understand the importance of adhering to the SUNY Schedule

-          Get to know your campus IT Departments – being an RMO requires coordination with your Information Technology departments so that you are aware of how data is saved, stored, archived, and backed up

-          Become the Counsel’s liaison for E-discovery on your campus

• Discuss e-discovery protocol with your campus counsel so that you are prepared when information is requested or when a litigation hold is issued

-       Ensure that a "notice containing the title or name and business address of the Records Access Officer and FOIL appeals officer and the location where records can be seen or copied shall be posted in a conspicuous location wherever records are kept."  (This language comes directly from SUNY's FOIL (Compliance with Freedom of Information Law) policy, Document Number 6601).

Each Year Thereafter:

-          Follow up with the offices each year to ask how they are maintaining the management of their records, and to help with facilitation of destroying of records that are past their retention period

-          Effectively communicate the records retention schedules with the campus offices http://www.suny.edu/compliance/topics/recordsretention/

-          Facilitate and encourage destruction of records past their retention period by setting up shredding services at the campus, or installing confidential shredding bins at various locations around the campus

-          Create an inventory box label to help campuses label the records that they store for long periods of time

• The inventory label should include:

1. The Name of the Department
2. The Types of Records Stored in the Box
3. The Contact Person responsible for those records
4. The Date of Destruction (the date at which the records can be disposed of)

-          Continue to be Counsel’s first point of contact for e-discovery issues

Helpful Tips:

-      Create a Records Management Pamphlet to be given to all new employees in their HR packet upon their hiring, which communicates the Records Retention schedule and the importance of following it

-      Create awareness at your campus regarding the importance of Records Retention.  The SUNY College at Brockport made a video to spread awareness on campus, available here. (Other installments to this video series will be forthcoming)

When Records are Damaged:

-      Records that are damaged by water are not completely lost. Vendors have the ability to freeze the damaged records to retard any mold growth and then review your files. The State Archives maintains a list of disaster recovery vendors that includes vendors who will pick up your records, freeze them, and then freeze dry/restore them, see the New York State Archives page on Disaster Assistance.  Some of the vendors listed on the disaster recovery (and other) vendors list are on state contract. There is a link to OGS's state contract for Emergency Standby Services and the Hazardous Incident Response Equipment (HIRE) at the top of the disaster recovery list.

-      Before you destroy any records, you must obtain authorization from the Archives to do so. The process is simple and quick and I can certainly assist you in the process. For more information about requesting early destruction of records, refer to the New York State Archives website on early destruction of records .

For questions, contact the SUNY Records Management Officer.

The information contained on the SUNY Compliance website is for general campus guidance only and is not intended, nor can be relied upon, as legal advice or the imposition on SUNY campuses of specific policies or requirements.  The site is intended to be an informational-only clearinghouse for some of the laws, rules, and regulations that may impact the State University of New York’s campuses.  Additionally, given the rapid, changing nature of laws, rules and regulations, there may be delays or omissions contained on this site which therefore cannot be relied upon as complete.    For complete compliance information, consult your campus compliance officials or the SUNY Compliance Administrator.  For legal advice, consult your lawyer.