Revised Sample Electronic Records and Imaging Policy

One of the most common things that records management analysts work with state and local governments on is developing and adopting policies for electronic records. As more and more agencies complete their work electronically (whether through creating digital records using word-processing software, digital cameras, or other born-digital methods, or through scanning existing paper records), it becomes more and more important to have a plan in place for these electronic records’ long-term retention and admissibility in court.

An electronic records policy is required if a) you are a state agency retaining electronic records in office longer than 10 years, or b) if you are a local agency scanning your records and would like to destroy the paper originals. However, given the increasing amount of public business that is conducted on computers, we recommend all agencies who conduct a significant amount of their business electronically to adopt a policy that fits their needs.

With this in mind, the Digital Services Section created a revised, improved sample policy, which is available on our website here. This policy replaces our old sample policies, as well as the Electronic Records Self-Warranty form, which is included in Section 10 of the new sample policy. The goal of the Digital Services Section was to create a policy that could work for local and state governments, and could fit all of an agency’s needs for electronic records management.  The new policy is also designed to fit with the Digital Services Section’s recently revised guidelines on Managing Trustworthy Digital Public Records.

What’s Changed?

  • It’s better organized. The new document separates and delineates component parts that were covered in the basic text of the old policy. By organizing the sections better, it’s easier to tell what functions each section is supposed to cover, and what we consider to be the most important parts of an electronic records policy.
  • It’s more thorough. Each section has bullet points which explain exactly what an electronic records system should do in order to comply with the requirements of that section. This results in more text than our previous policies, but the result is added clarity for those who are making and following the policy.
  • It reflects current practices. The new sample policy explicitly discusses current electronic recordkeeping practices that need to be addressed if your office uses them, such as cloud computing, contracting, and databases (which need to be indexed per G.S. 132). Previously, these requirements were handled directly through contact between the office and the analyst. While we still encourage you to talk to your analyst if you have questions about these and other electronic records, we like getting the information to government agencies in as many ways as possible.
  • It assigns and explains responsibility. One of the challenges of working with electronic records is coordinating with Information Technology to make sure that records custodians are taking proper care of their records, and that IT is providing adequate space and support for the records. The new policy lays out who should be performing which functions. This division of labor is repeated in the self-warranty form, and is designed to give more flexibility to agencies that have one document management system maintained by IT, but many custodians who use that system.

If you haven’t already done so, we encourage you to check out the new sample policy, especially if you are thinking of adopting one or revising your current one. If you have an older policy, you’re free to use it, but keep in mind that many policies state that they will be reviewed and revised after a set amount of time.

If you’ve decided to adopt a policy based off our sample one, you might find it easier working from a version that you can edit directly.  Contact an analyst and we’ll send you a copy.


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