Building a records management program: roles, policy, and training

Reference article · 6 min read

A retention schedule tells staff how long to keep a record. It does not tell anyone whose job it is to apply the schedule, how a department gets permission to destroy a shelf of boxes or a departed employee's mailbox, or what happens when the record lives in a cloud system the records officer has never logged into. That work belongs to the records management program: the named roles, the written policy, the training, and the recurring checks that keep the schedule from becoming a document nobody opens.

Most of this structure is the same whether you are a city of ten thousand or a county agency with several divisions. What changes is how much of one person's time it takes. Records requirements come from state law and, in many states, from a state archives or records commission that issues or approves retention schedules, so confirm the specifics for your jurisdiction with that office or your attorney before you adopt anything described here.

Who runs the program

Write the roles down and attach names. A program with no named owner reverts to each department doing whatever it did last year.

• Records officer. One person, designated in writing by the manager, administrator, or governing body. This person maintains the schedule, approves destruction, runs training, and is the point of contact for the state archives office if your state has one. In smaller jurisdictions this is commonly the clerk or a deputy clerk, and it is usually a portion of a job rather than a full position.
• Department records coordinators. One per department, named by the department head. They know what their department actually creates, they route destruction requests, and they are the first call when a new system is being considered.
• Legal. Your attorney approves the policy, issues and releases legal holds, and decides close questions about whether something is a record.
• IT. IT does not own the schedule, but it owns the systems, the backups, and the export paths. Give IT a standing seat rather than calling it only when something needs deleting.
• An executive sponsor. Someone at the manager or director level who signs the policy and hears the annual report. Without this, the program has no way to compel a reluctant department.

What the policy has to settle

Keep the policy short and adopt it formally, by resolution or executive signature, so it carries authority beyond the records officer's persuasion.

• What counts as a record. State the format neutral definition your state uses, and give examples that match how staff work: email, text messages, chat threads, shared drive documents, form submissions, body camera video.
• Where records may be kept. Name the approved systems. Say plainly that agency business conducted in personal email or personal messaging accounts is still subject to records law and must be captured.
• Transitory material. Define the low value category clearly, because staff will otherwise apply it too broadly.
• Who approves destruction. Name the role, not the person, and describe the sequence.
• Legal holds. How a hold is issued, who must act, and that a hold suspends all disposition until it is lifted in writing.
• Departing employees. What the supervisor and IT must do with the mailbox, drive, and devices before the account is closed.

Training people will retain

Train on the tasks, not on the statute. Two short sessions a year beat one long annual lecture.

• Onboarding. Cover records basics in the first few weeks, in the same session as ethics or public meeting rules, and include a one page handout the employee keeps.
• Annual refresher. Fifteen to thirty minutes, built around what went wrong in the last year: a hold that was missed, a system that filled up, a request that was hard to answer.
• Coordinator training. Longer, hands on, and focused on running the destruction cycle and the inventory.
• Attendance records. Keep them. In a public records dispute or an audit, evidence that staff were trained is frequently what matters.

Destruction: approval, certificates, and holds

Run disposition on a regular cycle rather than when someone runs out of shelf space.

1. Generate an eligibility list from the schedule for each department.
2. The coordinator reviews it against active litigation, holds, audits, and ongoing business need.
3. The records officer verifies the schedule item and the date calculation.
4. Obtain any external approval or notice your state requires before destruction.
5. Destroy the records using a method appropriate to the media and the sensitivity.
6. Record the result on a certificate of destruction.

The certificate should list the department, the records series and schedule item, the date range covered, the volume or system, the destruction method and date, and the signatures of the coordinator and records officer. Keep certificates for as long as your schedule requires, which is often a long period, because the certificate is your proof that a missing record was destroyed under authority rather than lost or concealed.

Records in systems you do not administer

Cloud systems are where programs quietly fail. The fix is to inventory by system rather than by department.

For each system, record the business owner, the administrative contact, the records series it holds, whether it can apply retention and disposition rules, whether it supports legal hold, how data is exported and in what format, and the renewal date. Renewal is your leverage point: review the retention capability every time the contract is renewed. Watch for systems bought on a card without IT or records review, and give departments an easy path to register one rather than a reason to hide it.

Ask a prospective vendor: Can retention periods be configured per record type, and can disposition run automatically with an approval step? Can records be placed on hold so they survive automatic deletion? What does a complete export look like, in what format, and what does it cost? How long does data survive after termination, and what evidence of deletion do we receive? Are administrator actions and deletions logged? Put the export right, the deletion evidence, and the post termination data window in the contract rather than relying on the proposal.

Self-audits and the report to management

Once a year, pull a sample from two or three departments and check it: are files stored in the approved system, is anything past its retention still sitting there, were destructions documented, are holds being honored, did the coordinator complete training. Write the findings as a short memo with a few corrective actions and a date to recheck.

Then report upward. A brief annual report to the manager and governing body should cover destruction cycles completed, holds opened and released, systems inventoried and reviewed at renewal, training completion, the backlog still unscheduled, and the two or three risks you cannot fix without a decision or funding. Programs lose support when they are invisible. Describing avoided storage, faster public records responses, and reduced exposure in litigation is what keeps the line item in next year's budget.

HQT works with state and local agencies on systems and integration work, including records retention and export requirements in the platforms agencies buy and build.

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