Note: This is part of a series of FAQ posts on records management practices incorporated into the signature page for the State Agency Functional Schedules. The previous two posts in the series can be found here and here. While this post is written with state records in mind, the guidance within is also applicable to local governments and universities.
Frequently, when someone calls in to the Government Records Section office with a question about how long to retain a record, the first question we’ll ask is whether this version is the record copy, or if the record copy is held elsewhere. Knowing which version of a record is the record copy is important because it increases records’ authenticity, and ensures that the appropriate record is kept for the full retention period listed in the records retention schedule.
Here are some of the questions we’ve received about the record copy:
What does “record copy” mean?
The Society of American Archivists‘ Glossary of Archival and Records Terminology defines “record copy” as “the single copy of a document, often the original, that is designated as the official copy for reference and preservation.” It’s the first version of the record you should look for in response to a public records request or subpoena, and the version that should be managed until its final disposition–whether that’s destruction, permanent management in office, or transfer to the Archives. Other terms you might hear for it are the “copy of record” or “official record.”
Can there be more than one record copy of a record?
Sometimes, but it’s extremely rare. If more than one agency has the same statutory responsibility to maintain the exact same record, there may be more than one record copy. For example, local governments and the Department of Health and Human Services both maintain a record copy of birth certificates, death certificates, and other vital records. These are scheduled separately in local government schedules and in the Legal functional schedule.
More frequently, two different agencies may maintain the exact same record for completely different purposes. For example, the State Construction Office keeps as-built blueprints of buildings as Infrastructure Management records. The Division of Emergency Management, however, may keep the same records for Risk Management purposes. Even though these records may be physical duplicates of one another, they are considered to be different records because they fulfill different functions within their respective agencies. They are two record copies of two different records.
In the vast majority of cases, there should be only one record copy of a record in the State of North Carolina. One advantage of the functional schedule system is that, when multiple agencies are involved in the creation of a record, we can indicate which agency holds the record copy very easily. For example, when the Governor, Lieutenant Governor, and General Assembly appoint officials, their appointment records are filed with and maintained by the Secretary of State, so the Department of the Secretary of State would be considered to hold the record copy of these records.
If there’s only one record copy, what do I do with the other copies?
Additional copies of records are typically made for reference purposes, so they are called reference copies or access copies. They can be destroyed prior to the full retention period, provided the records in question are not under a legal or other official hold. The next post in this series will discuss reference copies in greater detail.
Who is typically responsible for managing the record copy of a record?
This is going to depend on the record, and on your agency’s internal policies and procedures. The office in charge of managing the record copy is called the records custodian, and is frequently, but not always, the office that created the record.
How do I know whether I am the custodian of a record copy?
If the records custodian is a separate agency, the North Carolina State Agency Functional Schedules will indicate which agency is the custodian. If the record is entirely internal to your agency, though, this decision is made in the agency.
Agencies should designate clearly, through a file plan or similar documentation, which office holds the record copy of a given record. Contact your agency’s Chief Records Officer to determine whether there’s a file plan that indicates who the custodian of the record is.
If your agency doesn’t yet have this documentation in place, consider a few questions that might help you narrow things down:
- Does your copy of the record have all the necessary signatures on it?
- Did it need to be handed off to another office once you were finished with it?
- Was the record created for a reason that’s outside of your office’s normal functions?
Accounting, payroll, and human resources are frequently managed by respective divisions within departments, so they may be the custodians of travel requests, pay stubs, and interview documentation. When in doubt, contact these divisions to see they hold the record copy. This is also an excellent way for them to ensure that they have received all the necessary documentation for these records.
Why is designating the record copy of a record, and the records custodian, important?
Having this information documented helps establish the records’ authenticity, and makes agency operations more efficient. If I know for a fact that Accounting holds the record copy of my travel reimbursement request, and my agency’s internal policies on reference copies allow me to do so, I can destroy my copy as soon as I’ve been reimbursed.
Authenticity of records is established through developing and documenting systems that indicate how records are to be created, used, managed, and disposed of. By stating that the record copy of a given record is stored in one particular file room (or networked storage folder) and kept under secure storage, it will be easier to prove that this record is an accurate, unaltered account of the business it is supposed to document. And, when the record copy is destroyed according to the retention schedule, listing it on the the destruction log indicates that the record has been completely destroyed in a defensible destruction.
Is the original record the same thing as the record copy?
No! Frequently the original record is also the record copy, but not always. The record copy is designated by an agency’s documentation and active management of that copy, not its intrinsic qualities.
Agencies that wish to digitize paper or other analog records, and then destroy the originals, are, in effect, designating the scan as the record copy. This is why agencies must first have an electronic records policy in place that documents the steps the agency is taking to maintain the record copy’s authenticity as it is converted to an electronic form.
Establishing record copies and records custodians is key to managing your records effectively, because it demonstrates that your agency is maintaining its records as a business practice and not just storing documents. If you have any additional questions about record copies, contact a records management analyst and we’ll be happy to answer them.