To round out our review of terms used in the Functional Schedule for North Carolina State Agencies, this FAQ looks at reference copies of records in government agencies. The Society of American Archivists Glossary of Archival and Records Terminology includes two relevant definitions for a reference copy:
- A copy of a record kept for easy access to the information it contains, as opposed to its intrinsic or evidential value.
- A copy of a record distributed to make recipients aware of the content but not directing the recipient to take any action on the matter.
The disposition instruction in the Functional Schedule to destroy in office when reference value ends is usually applied to records that were not created by the recipient. We have identified three sorts of information usually organized into reference files:
- materials that have no regulatory authority for the recipient and are received from outside the agency or from other units within the agency
- subject files containing informational copies of records organized by areas of interest
- reference copies of records where another individual or agency is responsible for maintaining the record copy
The agency is given the discretion to determine how long these records should be retained before destruction because the size of the agency and the quantity of reference copies handled likely influence how long they should be retained. Because the Government Records Section doesn’t want to make a one-size-fits-all policy for these documents, this decision should be documented in an internal file plan or other policy so that all members of the agency can be consistent in their handling of these records. Agencies may also find our crosswalk spreadsheets useful for documenting these internal policies.
Keep in mind, you very likely have electronic records that are reference copies. Any time someone attaches a file to an e-mail, that file becomes a reference copy for the recipients. However, if you work in an executive agency and are subject to Executive Order 12, you would not delete these e-mails unless they’re at least 5 years old.
Does this mean every record I have in my office that I didn’t create is a reference copy and will not have a specific retention on the Functional Schedule?
Not necessarily. There are some records that are required to be submitted to state agencies. So even though the agency did not create the record, it is still responsible for retaining that record for a specified length of time. Some records, such as reports from a licensee, may be submitted as part of monitoring conducted by the agency. These records are on the Monitoring and Compliance schedule.
What if I receive a document and am not required to act upon it – surely that’s a reference copy?
To give the most common response of records managers, it depends. If someone circulates a memorandum in your office to let you know what decisions were made by the management team, that’s definitely a reference copy. But in other cases, the General Statutes specify to what agencies reports or other materials should be filed. For example, the Department of the Secretary of State collects annexation ordinances from municipalities. In these cases, retention is specified in the Functional Schedule because the received records fulfill part of the core duties and responsibilities of the agency.
Why does my agency need to establish internal policies for how long reference copies should be retained – why can’t I just throw these out whenever I want?
Reference copies are still public records, according to General Statute 132, which means the Department of Natural and Cultural Resources can make requirements about how they are destroyed and until that point, anyone may request access to these records. Agencies need internal policies to ensure that all employees are handling these records consistently, which will make it easier to respond to public records requests or any potential discovery or audit holds.