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Almost every employee creates records as a part of his or her job at Harvard. Of the records created, those that apply to a person’s job or to the University are "University records." University records are those that are "created, received, recorded, or legally filed in the course of University business or in pursuance of the University's legal obligations." ¹ These records may be paper, e-mail, word processing documents, spreadsheets, photographs, or in other form or format. Often employees will keep them in their own desks, local file cabinets or on their local computer drives. Nonetheless, they remain University property and are subject to University records policy.
When an employee leaves a position, all records under the control of that employee should be reviewed and dealt with according to University records policy (http://grs.harvard.edu/). This includes records in shared spaces about which the employee has sole knowledge. Some records may be disposed of immediately, but most will need to be retained to ensure continued smooth operation of the office or for legal or policy reasons. In this case the records may need to be transferred to another employee, into the office’s filing system or to another location. University offices should establish procedures to ensure that records in the possession of employees at the time of separation are managed properly and that important University information is not inadvertently destroyed or made public.
Prior to separation, the employee should provide his or her supervisor with a list of all University records in his/her possession and their location. If possible, the employee and supervisor should review the records together. If it is not possible to review the records before separation, the employee's direct supervisor is responsible for ensuring that the records are stored, transferred, or destroyed properly. These actions should be documented as part of the separation process, for example by inclusion on a separation check-off list.
While information technology personnel need to be involved to ensure proper transfer, protection, or deletion of electronic records, it is the responsibility of the employee's supervisor to apply University policy to the employee's electronic files. Offices should establish procedures for initiating clean-up of the electronic files. IT personnel should take no actions that will result in the deletion of University records without the express approval of the separating employee’s supervisor.
- Places to look for records:
- Paper records
- desktop
- desk drawers
- filing cabinets, both shared and in the individual's workspace
- any records temporarily in the possession of a colleague or another department
- Electronic records
- removable media (USB sticks, CDs, floppies, etc.)
- the employee’s hard drive
- area(s) on server(s) designated for the employee's use or under the employee's control
- e-mail accounts
- calendar accounts
- the shared areas of servers for
- areas that are primarily controlled or used by the employee
- records created by or known only by the employee
- personal devices, whether Harvard- or personally-owned
What to do with the records:
- Active records should be transferred to the custody of other employees as appropriate. Under certain circumstances the status of the employee or the sensitivity of the records may require that the transfer be documented.
- Consult the General Records Schedule and any appropriate special schedules to determine the proper retention of any inactive records.
- Inactive electronic records may need to be printed, depending on the length of time the files have value and the need to have them in electronic form.
- Records that are not University records may, if not claimed by the employee, be discarded immediately.
- For assistance with determining the proper retention or disposition of any of these records, contact Records Management Services.
- Dispose of any information securely.
- For physical records, use secure shredding. The University has a preferred records destruction vendor who has been vetted by the University. The vendor can also set up shred bins in your office when appropriate.
- For electronic information, appropriate steps should be taken to completely remove any information from discarded computers. When information is no longer needed, it should be rendered inaccessible or unreadable using appropriate software or other means. (For more information visit the Harvard University Information Security and Privacy web site.)
Note:
¹ Vote of the President and Fellows of Harvard College in Cambridge, March 13, 1995 |
