Electronic record keeping involves the use of a computer to create, retrieve, analyze, transmit manage, preserve or delete records. Electronic records are data in a form that can be read and processed by a computer and/or other electronic devices with digital memories and that satisfy the legal definition of a record. Electronic records may include data files and databases, magnetic tapes and disks, optical disks, compact disks (CDs), and any other form of magnetic, electronic, or digital media and their associated software programs, documentation, manuals, or instructions, machine readable indexes, word processing files, electronic spreadsheets, electronic mail and messages, as well as other text, video, or numeric information.
Generally, the retention and disposition requirements for records are the same regardless of their format (paper, microfilm, or electronic). Electronic records not listed on a retention schedule but used in an office must be added to the Specific Records Retention Schedule.
Establishing record keeping requirements for an information system that uses electronic records and data necessitates:
Generally, certain practices are associated with maintaining a sound and compliant electronic record keeping system.
Procedures Manual for Keeping Electronic Records
Each office that creates electronic records should create a manual describing how the information is created or imaged, maintained, retrieved and stored. The system's hardware and software characteristics should be fully documented, indicating the type, brand names, and model numbers of all hardware components including media which are used in the system together with the dates that specific components were put into or taken out of service (refer to vendor technical specification sheets).
All software and application programs used in the system should be described, including version numbers and implementation dates for upgrades. Custom software applications should have documentation for flowcharts, source code and other developmental information.
Information added to the system by document scanning or data entry, as well as quality control procedures, should be documented for each application. This includes written instructions for operators of all equipment used in creating and managing electronic records. It also should include periodic training and routine checks of information in the system.
Access Control Procedures
A list of all users and their access privilege authorizations should be audited regularly to ensure document password protection. The list should differentiate users who are authorized to record or edit images from those who can only read or retrieve them. Changes should be documented, along with the name of the person who performed the changes and reasons for making them.
Annually review all information changes, practices and system security, re- document where necessary and date.
In an imaging system, copies made from the system are verified against the original image and must be authenticated by the custodian of the records or the system administrator.
At least one person is designated as the system administrator with responsibility for system operations. This person should be able to give knowledgeable testimony about the system if required in a court of law.
The system should be checked periodically to ensure it meets relevant state standards.
Each locality is responsible for recopying or "refreshing" its electronic recordings scheduled for long-term retention. This is done at least once a year for magnetic disks or diskettes and at least every 10 years for magnetic tapes or optical disks. Procedures must also be in place that require this to be done when hardware and software operating system changes are made, or when media may have been compromised by environmental failure.
Each office must maintain the hardware and software needed to retrieve electronic records until the expiration of the applicable retention period listed on the appropriate Records Retention Schedule, or the records must be converted (migrated) to newer systems.
Format Not Permanent
Since the media on which electronic records are maintained is not considered permanent, presently electronic records are not acceptable for archival storage. If the information stored in electronic format is required by a retention schedule to be kept permanently or to be transferred to the State Archives, the records must be converted to paper or microfilm, the two accepted "eye-readable" media that meet the standards for permanent archival retention.
Similar security precautions required of paper records must be employed when destroying or reusing recording media that contain privacy-protected or confidential information. Electronic storage media containing such information must be electronically wiped clean or physically destroyed in such a manner that the information cannot be reconstructed.
As with other records, electronic records must be destroyed pursuant to approved records retention schedules.
Electronic Filing Practices
Generally, electronic files are stored by program of creation rather than by file function. Issues in managing electronic files include:
- Identifying authorship
- Tracking versions of a file
- Managing large volumes of files
- Standardizing filing practices
The same concepts used to manage paper, or document-based, records are also used to manage electronic records. The classification schemes developed in the document-based system can be applied to electronic files. "Main heading" and "subheading" in the document-based file management system are called "directories" and "sub-directories" in an electronic filing system. These directories are stored by the application in which the document was created. Deleted files created in any application should be brought together in one sub-directory, if not already linked.
In an electronic filing system, files are stored in the main or root directory. The sub-directory level would include the department/office which maintains or creates the records, and the actual file would be located in a folder under the sub-directory. Having a classification system for electronic records is essential due to their huge volume and the number of versions produced.
An electronic filing system allows files to be accessed through the use of a personal computer on a stand-alone basis or by using a local area network (LAN) or wide area network (WAN). A stand-alone system does not permit more than one user to access files at the same time.
A networked system allows a number of users to have simultaneous access. Files on a stand-alone system are stored on the computer hard drive; files on the network system are stored on the network's computer server. The level of access is controlled by the use of authorities assigned to users. Computer software has "search and find" capabilities which allows files to be retrieved in seconds. The computer will only retrieve documents by the specific name created in the directory or sub-directory. An index should be created so that all documents can be referenced. Some systems allow for full-text retrieval.
Unlike paper-based file systems which only allow one user to access a file at a time, electronic files can be accessed by many users simultaneously. Therefore, it is important for file names to be indexed in a logical manner.
A data dictionary or thesaurus should contain a listing of terms and cross-references which identify files. This provides structure and consistency to the process of naming files. A data dictionary or thesaurus should be distributed to all users so the same indexing terms are used to create and access files. File names should not be excessively abbreviated to the point where the name cannot be understood. In addition, the file names should not be too broad ("correspondence") or too narrow. The search capabilities of computer software enable fast retrieval when the right keywords are known.
Retention and Storage
There are special filing media designed to store electronic data. The preservation of all non-paper media such as diskettes, film, magnetic tapes, cassettes, CDs and optical disks is dependent on the environment while stored. This type of media will deteriorate rapidly if proper temperature and humidity are not maintained. All electronic media should be labeled accurately, and, to avoid contaminating the media, they should not be stored near magnetic fields or placed in smoking or eating areas.Computer Tapes can be stored on special lateral files or in open files which use canister racks or hanging racks. Magnetic media should be stored in a climate-controlled environment between 63-68 degrees F, with a relative humidity of 35-45 percent.
3.5-inch Diskettes should be placed in protective pockets and storage boxes to minimize their exposure to dust.
CD-ROMs and Optical Disks can be stored in jukeboxes or plastic containers, lying flat.
Migration Plans: If the retention period for any electronic media is 10 or more years, consideration should be given to building into a storage plan a strategy for the migration of the recorded information to the next generation of technology's record media. The software and/or source codes need to be stored with the electronic records. Technological obsolescence should not be allowed to prevent the retrieval of records from their original formats.
Electronic records should be included in general (and specific) retention and disposition schedules, the same as in paper-based records. The State Archives should be consulted to obtain necessary approvals prior to disposing of electronic records.
Electronic Mail (e-mail)
E-mail is not a records series or a classification of records; it is a generic term used to describe a mode of communicating information through an electronic media. Records in e-mail systems include messages sent, messages received, header information, attachments, and transmission and receipt data.
E-mail has become an integral part of how government conducts business. Through e-mail, approvals are made and authorizations given. It is the content of the records transmitted in an e-mail system that determines the value of the records. Therefore, the value of the records, regardless of the format they are in, is determined by a Records Retention Schedule.
To determine the disposition of e-mail, refer to the appropriate retention schedule for the type of information contained in the e-mail (e.g., correspondence, projects, planning, working papers). Most records transmitted via e-mail are covered by general retention schedules.
E-mail may require retention of transmission data to be intelligible and to understand the context. When a record in an e-mail system is preserved, the transmission data also must be captured to maintain a complete record. If retained in electronic form, a system of retrieval and access, related to the records schedule, must be developed. Permanent records must be scheduled to format to eye- readable format.
By storing the e-mail document in paper format, it can be integrated with other types of records in a series. The information is then in the records series one would expect to locate it in and accessible to all users.
Internal E-mail Policies
Public employees should assume that e-mail messages are public records. E-mail should be used for appropriate government purposes only. Incidental and occasional use of e-mail occurs, but it should be used wisely and with consideration for the perspective of others. It is important to remember that public employees' e-mails can be accessed by others without prior notice, so nothing should be written in an e-mail which would be objectionable for third parties to read. E-mail cannot be used for soliciting business ventures, promoting particular religions, personal, or outside causes.
The best method for dealing with e-mail locally is for each office to determine the retention period for e-mail messages and then cause them to be erased electronically. Most businesses and many governments have adopted as little as a 30-day retention period, although each government office must determine the retention period that works best for them.
There is a difference between e-mail used in the normal conduct of the government's business, and the use of e-mail to convey policies or procedures or official opinions on public matters. In these latter cases, a paper hard-copy of the information should be made. Then the Records Retention policy for that particular record is easier to follow.
Sometimes government localities create their own World Wide Web sites. These pages are not records series, nor are they record keeping systems. Because of the enormous volume of information on the Web and the speed with which it changes, it is difficult to capture in the manner we have traditionally used to identify records. Web pages are more and more able to offer the citizen swift, informed access to local records, government offices, and helpful public information. The State Archives encourages the development of these Web sites, but also encourages taking a periodic "snapshot" of the information contained on the page and either printing it out, or if it is too voluminous, at least capturing a printout of the home page and index. These methods of recording the official correspondence with and the services provided to the citizens of West Virginia and elsewhere via the Web are the least sophisticated methods available, but they are very valuable for research purposes.
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Records Management and Preservation Board