IRM-017: Records and Information Management
Academic Division, the Medical Center, the College at Wise, and University-Associated Organizations.
The University of Virginia is committed to adhere to best practices for the management of all University records regardless of format to:
- Comply with state and federal statutory requirements, including the Virginia Public Records Act.
- Reduce risks associated with unintended disclosure of sensitive information.
- Respond efficiently to record requests and preservation orders.
- Protect vital and historical information about the University.
This policy supports the consistent, efficient, and comprehensive management of University records and information. It establishes expectations for all University state agencies (207, 209, and 246) to comply with the Virginia Public Records Act via standards and guidelines issued by agency designated records officers for the management of University records. It clarifies that University-Associated Organizations are not subject to the Virginia Public Records Act but are strongly advised to follow best practices for records management.
- Archival/Historical Records:University records that document transactions or activities of the University designated by the University Archives and/or designated historical records repository, the agency’s designated records officer and/or the Library of Virginia as having long-term historical value. Records with historical value may include documentation of decisions, activities, and products of the University. Examples of historical records include but are not limited to: Board of Visitors' meeting minutes, President’s correspondence, research final reports, and accreditation records.
- Closed Records:Records which have restricted access due to legal or administrative confidentiality but would eventually be open. (Society of American Archivists Definition: Closed.)
- Records Officer:An appointed official designated by the state agency who is responsible for providing standards, procedures, training and guidance to meet requirements for the proper management of University records. Appointments of agency records officers must be filed with the Library of Virginia per state code § 42.1-85 C.
- Records Retention and Disposition Schedule:A listing of records series, approved by the Library of Virginia, that provides retention and disposition instructions for University records.
- Disposition:Final destruction or transfer of records to the proper archival repository.
- Retention:The length of time records should be kept in a certain location for administrative, legal, fiscal, historical, or other purposes.
- University Records:Recorded information that documents a transaction or activity by or with any appointed board member, officer, or employee of the University. Regardless of physical form or characteristic, the recorded information is a University record if it is produced, collected, received or retained in pursuance of law or in connection with the transaction of university business. The medium upon which such information is recorded has no bearing on the determination of whether the recording is a University record. University records include but are not limited to: personnel records, student records, research records, financial records, patient records, and administrative records. Record formats/media include but are not limited to: email, messaging (texts, instant messaging, etc.), posts (social media or collaboration software), databases, electronic files, paper, audio, video, and images (digital and printed).
The University of Virginia will comply with federal and state statutory requirements and specifically, the Virginia Public Records Act, in the handling of University records.
- Agency Requirements:
The Academic Division (Agency 207), the Medical Center (Agency 209), the College at Wise (Agency 246) must:- Records & Information Management:
- Comply with retention and disposition instructions in the applicable Records Retention and Disposition Schedules approved by the Library of Virginia. For the Academic Division, see Records and Retention Schedules. Contact the Medical Center and/or the UVA Wise records officers for directions on which records retention schedules to use.
- Store physical records in compliance with the Physical Records Storage Standards for onsite and offsite locations. Offsite storage requires review and approval of the agency’s designated records officer.
- Store electronic records in accordance with the University Data Protection Standards and guidelines from the agency’s records officer for management and authenticity.
- Destroy University records once the retention period in the University Records Retention and Disposition Schedules has expired. A Certificate of Records Destruction (RM3 Form) must be approved by the agency’s records officer as required by the Virginia Public Records Act before destruction. For the Academic Division, see Destruction of Public Records. Contact the Medical Center and/or UVA Wise records officers for directions on completion of the Certificate of Records Destruction (RM3 Form).
- Special Records Requests:
In addition, agencies/departments/units should adhere to the following:- Archival/Historical Records:
Transfer records designated with historical/archival value, as listed in the Records Retention and Disposition Schedules, to the designated archival repository. Leadership (President, Chief Operating Officer, Provost) records are closed for 10 years after the individual holding the position has left the leadership position. - Audits, Court Orders, Investigations, and Freedom of Information Act Requests:
Retain all records requested or placed on hold by internal offices (such as University Counsel, Internal Audit, Office of Sponsored Programs, University Communications, UVA Health's Chief Corporate Compliance and Privacy Officer, etc.) until cleared by the office placing the hold, regardless of retention requirements. Offices placing holds or requests for University records should copy the agency’s records officer on all notices. - Review of Electronic Records Systems:
Departments and units should review with the University Records & Information Management Office the implementation of electronic systems, including cloud services for compliance with Records & Information Management policies, standards, and guidance.
- Archival/Historical Records:
- Records & Information Management:
- University-Associated Organizations (UAOs):
While University-Associated Organizations are not subject to the Virginia Public Records Act, UAOs are strongly advised to follow best practices for records and information management. UAOs may use consulting services provided by the University Records & Information Management Office (Agency 207). - Responsibilities:
- The agency records officer is responsible for developing standards, guidance, and providing assistance to organizational units within their agency for managing University records, including designation of confidential or records containing highly sensitive data.
- All Academic Division, Medical Center, and College at Wise employees (faculty and staff) and All Board Members should receive records and information management guidance about their responsibilities as an employee/board member at the time of hire/appointment. Each agency will determine the area responsible for providing records management guidance. For the Academic Division, completion of Introduction to Records & Information Management at UVA online session (5 min) is required.
- Supervisors should support additional records and information management training for their employees, especially those with records responsibilities, from the agency’s records officer. It is strongly recommended that employees with records responsibilities complete Records Management Basics (on-demand training). Additional online training and resources can be found here.
Compliance with Policy:
Failure to comply with the requirements of this policy may result in disciplinary action up to and including termination in accordance with relevant University policies.Questions about this policy should be directed to the University Records & Information Management Office, Health Information Management at the Medical Center, or the College at Wise Library.
For specific procedures and guidance:
Academic Division (Agency 207): See the University Records & Information Management Office website.
Medical Center (Agency 209): Contact the UVA Medical Center Records Officer, Crystal Ford.
College at Wise (Agency 246): Contact the UVA Wise Records Officer, Kimberly Larmee.
All other agencies and University-Associated Organizations: Contact the University Records & Information Management Office.
Revised 7/24/24; University-Related Foundation changed to UAO 5/10/22; Added Compliance section 7/21/21; Updated links 9/14/17, Updated Oversight Executive, 5/30/17, Revised 1/15/2013.
II.C.I, Records Retention and Disposition.