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Records Management Program Procedure

Supersedes Records Management component of Archives and Records Management Policy, March, 1993.

I.    Purpose

This procedure outlines in detail how Toronto Metropolitan University (the "University") complies with its legal and operational obligations and requirements to manage records and information in its custody or control.  The authority for this procedure is derived from the Records Management Policy and falls under the jurisdiction of the Office of the General Counsel and Board Secretariat.

II.    Procedure

1.    Access and Retrieval

For accountability purposes and to ensure records are easily accessed and retrieved by authorized personnel when needed, all records must be filed in accordance with University Records Management Program practices. 

2.    Privacy and Security

For guidance on protecting restricted information, including personal information, please see the University’s Information Protection and Access – Restricted Information Policy and Procedure.  For guidance on the protection of the University’s general information assets, see the Information Protection Policy.  

3.    Disposition

Records disposition must be carried out in the manner established by the applicable Records Retention Schedule or as specified by or approved by the General Counsel and Secretary of the Board of Governors.

4.    Legal Holds

Legal requirements supersede any and all University policies authorizing destruction of records.  If the content of a record is related to actual or pending litigation or government investigation, it is subject to a Legal Hold.  Holds begin from the moment an employee becomes aware of or gains knowledge that legal action or a government investigation is reasonably foreseeable, and remains in effect until explicitly removed.  Records part of a Legal Hold cannot be destroyed until the hold is removed and it is expressly permitted by the General Counsel and Secretary of the Board of Governors. 

5.    Succession

Officers, employees and contractors leaving the University or relinquishing their positions shall leave all Official Records for their successors.  

6.    Transfer to Archives – Records of Enduring Value

The University Archives manages records of enduring historical or permanent value, which are no longer required for ongoing administrative purposes.  The Archives provides storage, preservation and access to these records as authorized by relevant University policies, including Freedom of Information and Privacy principles.  For additional guidance on transferring records to the University Archives, contact the University Archives. 

7.    E-mail

E-mails documenting University activities must be treated as records and maintained according to the Records Retention Schedule whether within the e-mail application itself, other electronic recordkeeping system or where the primary related records are maintained in paper format, e-mails should be printed and filed with those records as appropriate. 

8.    Technology-Dependent Records

Technology-dependent records, including structured data within various databases, electronic records, micrographic records and audio-visual records, generated or received in the course of business are University Records.  Electronic information whether structured (e.g. database records), unstructured (e.g. word processed documents, web content, social media) including any relevant contextual metadata should be preserved, maintained and accessible for as long as they are required to meet legislative, accountability, business and historical obligations.

9.    Records Management Systems

The University’s Records Management Systems are intended to manage the life cycle of data, documents and records in various media.  Records Management Systems aim to preserve the integrity and authenticity of records and their contextual metadata over time from creation through to disposition or long term preservation.  These systems may be designed to automate and track access and privacy, manage retention, preserve and audit the integrity and authenticity of records throughout their life cycle.  As technologies are considered for replacement or upgrades, recordkeeping, privacy and security requirements should be included as part of the analysis and review process.

10.   Electronic Imaging Management Programs (Scanning)

Electronic imaging programs (conversion of paper to electronic images, such as through scanning) shall be performed in accordance with the Electronic Imaging and Document Management Policy.