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UCD Records Management and Freedom of Information

Aonad Bainistíochta Taifead & Saoráil Faisnéise UCD

Record-keeping Guidelines

An increasing body of accountability and transparency regulation demands the maintenance of good record-keeping systems that meet best practice requirements. This page is intended to provide practical guidelines on record-keeping in accordance with best practice. The function of the guidelines is to promote the creation and maintenance of complete, authentic, reliable, accessible and accountable records.

Composition

  • Compose text using formal language that is clear, accurate and factual, avoiding irrelevant or unnecessary comment.
  • Try to be as objective as possible when expressing opinions.
  • Record the opinion in the context of the facts that support it.
  • Avoid personal comments or inappropriate 'colourful' remarks (potential embarrassment to individuals or organisations does not constitute grounds for withholding access to the record).
  • Do not record unsubstantiated subjective comments, particularly those made by one person about another. Remember that the recorded comment is considered the personal information of the individual about whom it was made and that person has a right of access to it. Comments by one person about another using intemperate language can usually be re-phrased before recording without losing meaning.
  • Make sure that the medium on which text is recorded is appropriate to the subject matter. Correspondence on important subjects via e-mail should be composed as formal business letters and sent as attachments. Important information should never be recorded on post-its and fixed to a file cover or to a document on file. If information is important enough to place on file it should be entered in an appropriate way.
  • Make sure all manual notes and annotations are legibly written.
  • All recorded information forms part of the official record holdings of the university. Naming or stamping a record "unofficial" or "confidential" will not render in inaccessible.
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Assessment Records

Individuals have the right to obtain in writing, the reasons for decisions made by the university that have materially affected them.
It is important that clear and accurate records are kept of the outcome of discussions that inform the decision-making process, particularly in selection processes that involve evaluating individuals.
Use pre-designed forms to record the outcome of the selection process.
Record the short-listing process, as those not short-listed have the right to obtain in writing the reasons why.
Record the decision as soon as the decision is made.
Make sure the records clearly illustrate the selection process, showing the formulated, agreed and published criteria for selection, the weighting attaching to each criterion, and the performance of the candidate against each criterion.
Where a candidate fails by a narrow margin to satisfy the selection criteria, make sure there is sufficient information in the records to explain why, as this is the evidence that the decision was fair and equitable.
Make sure the records are sufficiently detailed to enable a written statement of reasons to be composed should it be requested under Freedom of Information. A record emanating from the selection process may satisfy, but if the record does not indicate clearly the reasons for a decision, a new record must be prepared giving a detailed statement of reasons. In the case of non-competitive promotions, a statement of how the individual was assessed against the criteria and the rating system used will be required if requested.
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Minutes
Minutes are the written record of the business transacted at a meeting. Good practice in minute taking includes the following:

Minute headings:

Name, place and date of meeting

List of members, of those in attendance and of those who tendered apologies for non-attendance

Agreement of previous minutes
Matters arising from previous minutes
Correspondence
Presentation of reports
Items discussed
Decisions taken
Any other business and date of next meeting
Chairperson’s signature and date
Recording minutes:

Minutes should clearly reflect the decision-making process and should contain an accurate account of decisions taken.
Minutes should reflect the nature and content of all discussions that feed into decisions.
When recording an item, discussion should be recorded in a manner that gives a precise account of the proceedings of the meeting.
Record only relevant business considered, facts noted, the decision taken and its rationale.
Individual contributions at a meeting should only be attributed, when an individual expressly requests it and the meeting agrees that the contribution should form part of the minutes of the meeting.
Minutes should be recorded so that they are complete, and contain sufficient detail to enable a person who was not present at the meeting to fully understand what business was transacted.
Initial drafts of minutes should not normally be retained.
Supporting documentation circulated with minutes is part of the record of the meeting and should be retained.
Following approval of minutes at a subsequent meeting they should be signed and dated by the Chairperson. All previous drafts should be destroyed.
Alterations to minutes should be hand written with a notation stating at whose request the alteration was made. This should be done prior to the chairman signing the minutes
Do not record every discussion as verbatim. Record objective statements that explain concisely and accurately the subject discussed, the decision taken and the desired action. As minutes reflect collective decisions record a quotation only if the individual concerned expressly desires it.
Do not render minutes useless by making them too brief to be a true reflection of the decision-making process. Avoid the use of cryptic numbering and coding. If a requester under FOI has difficulty in deciphering their content, he or she can request clarification.
Committee members should be advised

That they must obtain the approval of the meeting if they wish a particular contribution to be attributed to them.
That access may be given to all minutes and associated documents under the Freedom of information Act, 1997. Certain information may be withheld under the various exemptions available in the Act, but the withholding of information under FOI cannot be guaranteed.
Remember
All minutes are potentially accessible and may enter the public domain.
Individuals may request access to their own personal information contained in them.
As permanent records, minutes may be relied upon in the future to provide an historical record of important decisions and events.
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References
When writing a reference the referee must assume that the subject of the reference will ultimately receive it. Under the Freedom of Information Act, records relating to an individual are the personal information of that individual, including all assessments and referees' reports. The terms of the Irish Freedom of Information Act preclude the withholding of references provided in the course of official duties by those within its jurisdiction. Where a reference requested by an individual to whom it relates has been provided outside the ambit of the Irish FOI Act, the provider of the reference is consulted informally about release. If the referee does not agree to release informally, he or she is formally consulted and given the opportunity to make a written submission against release. The university will then make a decision to withhold or to release. A decision to withhold may be overturned by the Information Commissioner, who is external to the University and whose decision is binding.
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Filing Systems
A good filing system is one that permits easy, economical and efficient organisation, maintenance and protection of documents in current use. A filing system should

Reflect the functions of the office it serves in its organisation and design
Have a structured numeric or alpha-numeric referencing system in which each element equates with a function of the file title to a maximum of four elements
File naming and maintenance

All documents on a file should bear the file reference number
File titles should clearly identify file contents
File titles should never be generic, such as "miscellaneous"
File covers should be printed to permit the title, reference and date of opening and closing of the file
Documents should be filed in reverse order
A new file should be opened if a new subject develops, rendering the original file title inaccurate
Unannotated duplicates should never be placed on file
Files should be closed when the business to which they relate has been completed
Files should not exceed 5cms in thickness
Closed files should be removed to a suitable storage facility
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Classifying Records
The management of records and the information they contain becomes easier when they are organised according to a classification system. Classification means the arranging, or grouping, of records according to a logical scheme, ideally based on the activities of the office that generates them. Classification schemes usually require the organisation of records relating to a particular business function into groups, or series, and, if necessary, into sub-series and even sub-sub-series. These series are then allocated reference numbers or codes, which serve as unique identifiers and also indicate the inter-relationship between the series.

For efficiency, order, continuity and ease of retrieval, related records are usually managed by their accumulation into folders or files. Each file should bear the reference code or number of the series of which it forms a part, and also have its own unique reference number within the series.
The file titles composed for files should reflect their contents accurately. It is recommended that file titles should also indicate the series of which they form part. Therefore, primary and, if necessary, secondary titles, representing sub-series within each of the functional areas, may then be devised. Where required, tertiary titles, representing sub-series within secondary titles, can then be determined. For example, a primary title might be 'Building maintenance', and under 'Building maintenance' ' secondary titles might include 'Cleaning contracts' and 'Fire prevention'. Tertiary titles under 'Cleaning contracts' could include an alphabetical list of contractors.
In this way, order is maintained by putting records of a similar category together, thus enhancing the flow of information. It allows for change of organisational function and preserves continuity throughout changes in personnel. It also obviates the use of non-specific headings such as 'Correspondence' and 'Miscellaneous'.
When the major primary groupings have been devised, groups will fall into a natural order within secondary and tertiary divisions. When establishing the relation between headings and divisions, i.e. secondary subdivisions within primary headings or tertiary subdivisions within secondary headings, proceed from the major to the minor and from the general to the specific. Always compose your classification plan in advance. Maintain an up to date list of file titles.
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Retaining Records
The records retention schedule specifies the length of time that records must be maintained for organisational, legal, fiscal and historical purposes.

The records series is the most appropriate unit for scheduling. Related documents are normally managed by accumulation in folders or files and files relating to a particular business function are normally managed as a group, or series.

The records retention schedule:

  • Names the content and purpose of each records series
  • Prescribes the necessary retention period

The retention period will range from immediate destruction or destruction after a period of time, to permanent retention. Some records need not be scheduled at all as they are transitory and only required for a limited period of time for convenient reference. A small percentage of records are ephemeral and, though scheduled, can be destroyed almost immediately after use. Between three and six per cent of records are scheduled for permanent retention. The majority of records fall into the intermediate category. The retention period for these should be set as close as possible to the point where the economic cost of retaining them exceeds their value. It should be as short as possible, the normal range being from four to seven years.

Before scheduling, it is necessary to take an inventory of all records series in the office.

There is no strict format or layout for the schedule: tables, charts, or forms and reports generated from a database, are all satisfactory. It is inadvisable to copy schedules from another office or organisation. If the schedule is not tailored to the office’s particular requirements it will not meet the administrative and operational needs of users.

The following are general guidelines only. A comprehensive set of retention schedules based on a business process analysis model is currently being compiled for university records. It will be published when it has been fully approved. Please consult the Records Management and Freedom of Information Unit if you have a query concerning records retention

Approved Retention Schedules: