ARA-8.10 - Preparing City Record Retention Schedules

A. Purpose

To provide a process for the regular updating of the City’s record retention schedule to ensure compliance with city, state, and federal recordkeeping requirements. The City Record Retention Scheduleis incorporated into these policies by reference.

B. Policies

Frequency of revision

The City retention schedules will be reviewed and updated at least every five (5) years. Minor administrative updates will be performed as needed without Citywide review.

It is the responsibility of the City Administrator, Assistant City Administrator, and Deputy City Administrators or their designees to ensure the retention schedules reflect the functions or activities of the agencies for which they are responsible. In the event of significant changes in agency function resulting in needed updates to the schedule, they must notify the Records Manager.

Retention Schedule Update Process

The City Auditor or City Archivist will notify the City Administrator, Assistant City Administrator, and Deputy City Administrators in writing when it is time to update City retention schedule. The City Administrator, Assistant City Administrator, and Deputy City Administrators will designate sufficient employees from each service area or agency for which they are responsible to cooperate in the update process. These designees will be involved in the process to ensure that all records that are created or maintained by the agencies within the service area are addressed in the retention schedule.

The designees, with guidance from Archives & Records, will conduct a review of agency records to determine:

1. That all records created or maintained in the course of undertaking agency activities and functions are part of a record series in the retention schedule;
2. That record series descriptions clearly describe the nature, function, and operational purpose of their agency records that fall within them; and

3. That record series are logically grouped by the function or activity that is responsible for their creation.

Vital Records

As part of the retention schedule review process an agency’s vital records and record systems must be identified. The agency will consult with Archives & Records to implement appropriate methods of safeguarding these records and systems.

Establishing retention periods

As part of the review process, agencies can request an extended retention period beyond the legal requirements as written in the State schedule, but final determination is made by Archives & Records.

The Records Manager will research state and federal recordkeeping requirements for the record categories in the proposed retention schedule. If the legally mandated retention period is longer than that of the City’s operational need, the retention period will be lengthened to comply with those requirements. If a category of records is not addressed in any state or federal recordkeeping rules, a special schedule with a proposed retention period will be created and forwarded to the State Archivist for approval. If a category of record is covered by state administrative rules and the proposed retention period complies with those rules, that schedule does not need to be approved by the State Archivist. (OAR 166-030-0027)

Some records, regardless of their retention period, may have historical value that merits their inclusion in the City Archives’ historical collection. The Records Manager will work with the City Archivist to determine whether certain record series as a whole should be retained permanently for their historical value, and whether the records in certain series should be subject to archival review at the end of their retention period. If a record series has a finite retention period but is made up of records that frequently have historical value, language will be included in the schedule to indicate that Archives & Records will conduct an archival review prior to destroying the records.

Authorization Procedure

Once the designees and the Records Manager have agreed on the record series descriptions, retention periods, and identification of vital records, the Records Manager will create a final draft retention schedule (including any special schedules authorized by the State Archivist) to be routed through an authorization process. This process will be composed of the following steps:

1. Deputy City Administrator for each service area – review for completeness, accuracy of descriptions, identification of vital records, and alignment with operational needs. Sign and date authorization.
2. Director of Audit Services – review retention periods for compliance with City auditing requirements. Sign and date authorization.
3. City Attorney – review schedule for compliance with legal requirements and considerations. Sign and date authorization.

When the authorization process is completed, the Records Manager will publish the retention schedule on the City’s website and notify staff through Citywide communication channels that it has taken effect.

Auditor’s Office Administrative Rule Information

Questions about this administrative rule may be directed to the Archives & Records Management Division.