Records have been created and managed using a plethora of media formats: DVDs, paper, cassette tapes, photographs, microfilm, microfiche, unstructured data (e.g. spreadsheets, PDFs, etc.), structured data stored in tables of a relational database, hard drives, clay tablets, web pages, floppy discs, reel-to-reel tapes, flash drives, etc. All formats eventually become obsolete, and the rate of change has increased dramatically during recent decades. This presents a huge challenge when maintaining and accessing information contained in the records, regardless of the media and file format on which they originated. Some records officers and chief administrative officers wonder when to preserve records in paper format, or if they can preserve all or some of their records in electronic formats. There are a variety of factors to consider when deciding what media formats to use for creating and preserving records, how to maintain electronic records so that they remain usable, and what storage media will best meet your agency’s needs.
One factor to consider is what is mandated by law. The Public Records Management Act requires that the “record copy” of government records must be maintained according to approved retention schedules.1 The record copy is the official copy; it may be the original copy, but not always. The original may be created in paper and scanned electronically with the electronic copy being designated as the record copy (and therefore legally subject to the retention schedule). The agency chooses which copy of the record will be designated as the record copy.
Other types of copies include security copies, access copies, and preservation copies. A security copy is a reproduction of a record created and managed (usually off-site) to preserve the information in case the original is damaged. It is a temporary back-up copy that is preserved only as long as needed, but never longer than the record copy. An access copy is usually a lower-quality version of the record, created to be used by patrons, or to provide access to the record. In some cases the record copy doubles as the access copy (if no other access copies are made), but for permanent records it may be better to create and use distinct access copies in order to increase ease of access and decrease the risk of over-handling the record copy. A preservation copy is preserved permanently as a back-up copy of a record with a retention of ‘permanent’. This copy functions as insurance against the loss of the record copy, and should be stored in a different location than the record copy and used only to make other copies for access. The media formats used for these various copies should be chosen with the function of the copy in mind.
The Uniform Electronic Transaction Act states that if a law requires that a record be retained, the requirement is satisfied by retaining an electronic record of the information in the record as long as it remains accessible and accurately reflects the information set forth in the original record.2
Utah Code 46-4-301 – Retention of electronic records – Originals.
(1)If a law requires that a record be retained, the requirement is satisfied by retaining an electronic record of the information in the record that:
- (a) accurately reflects the information set forth in the record after it was first generated in its final form as an electronic record or otherwise; and
- (b) remains accessible for later reference.
In other words, retaining the electronic version as the record copy meets the legal requirement to retain the records. Consider what format contains the fullest information. Records created electronically have properties (i.e. metadata) that do not exist for the paper format and that are a required part of the record. For this reason, if a record is created electronically (born digitally), the electronic copy contains the fullest information and should be designated as the record copy. For example, the printed PDF of an email does not contain all of the associated metadata (i.e. IP addresses) and is not considered a legitimate version of the record. For records created in an analog format (i.e. paper), the record copy should be selected based on the length of the scheduled retention for a record series and on which media format will best facilitate the maintenance and accessibility of the records for the entire retention period.
Lunch atop a Skyscraper, 1932, by Charles C. Ebbets, copyright Corbis Corporation
Another factor to consider is liability. It is imperative that you balance the importance and required retention of the records with the characteristics of available options for how, where, and in what format to maintain the records. Before you make these decisions, you should conduct a risk assessment. Evaluate how important the records are to your agency, to the state, and to the law: Are they essential to the continued operation of your agency? Do they document your agency’s history? Are they subject to audit or litigation? For how long must the records be kept and when should they be disposed of? What are the costs associated with storing and managing the records? How likely is it that your database will crash or lose valuable data? How long does data on an external hard drive remain intact? What is involved in migrating old data? When you understand these aspects of the records and your storage options, you can make better decisions about how to maintain the records.
Records with retentions of ten years or longer can be difficult to sustain electronically because they must remain accessible for the duration of the retention period. Obsolescence of hardware (e.g. BetaMax), software (e.g. Lotus), file format (e.g. .pld, .hdb, .mac), and media (i.e. floppy discs) can prevent the recovery of files stored only a short time ago. To address technology changes, agencies must either maintain the ability to retrieve and view imaged records in systems and file formats that the agency is currently using, or export the records (including associated metadata) to succeeding systems and file formats throughout the required retention period. The latter process is commonly referred to as data migration and involves converting the data from one technology to another, while preserving the essential characteristics of the data.
On the other hand, records with short retention periods, i.e. nine years or less, will likely require less investment and may not need to be migrated. Keep in mind that the retentions stated on retention schedules do not indicate only the minimum amount of time that a record should be kept, they also indicate the time at which a record should be disposed of. Uploading imaged documents into a database to be kept indefinitely is not maintaining the records according to their retention schedules.
Another issue to consider is that electronic records must be protected against alteration, deletion, damage, or loss throughout the entire retention period. Specific protective measures may include:
The cost of storing records is a major issue. The State Records Center does not store electronic records and the State Archives only stores electronic records that have a permanent retention. Electronic storage is more expensive than paper storage, particularly if the record was originally created in a paper format. There are several acceptable data storage options available for long-term storage, meaning ten years or longer; agencies should consider and research their options to find the best solution for their data storage needs. Magnetic tape, Hard disk drive (HDD), Solid State Drive (SSD), Cloud storage, and developing technology such as M-Discs™ all have the potential to be reliable media for storing data. Data storage planning is discussed further in section three.
It is important to weigh the strengths and weaknesses of each media format and identify which would best suit the record copy and any additional copies of a record that you manage. The factors involved in managing electronic records need to be considered and researched as you determine in what media formats you create, manage, and preserve your agency’s records. Conduct a risk assessment and research the costs and benefits of any options that you are considering. Format management, data migration, and reformatting plans need to be well thought-out and documented as office practices change.
1Public Records Management Act, Utah Code Ann. §§ 63A-12-105 (Supp. 2009). Accessed February 18, 2015. http://le.utah.gov/xcode/Title63A/Chapter12/63A-12-S105.html.
2Uniform Electronic Transactions Act, Utah Code Ann. §§ 46-4-301 (Supp. 2000). Accessed November 18, 2015. http://le.utah.gov/xcode/Title46/Chapter4/46-4-S301.html.