UNC RM Presentations - EPA/SPA Personnel Records Discussion

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Janis Holder - EPA/SPA Personnel Records Discussion

The Problem

EPA personnel records have posed problems in terms of both access and storage on the UNC Chapel Hill campus for many years:

Volume of paper records has spiraled out of control
Original records are maintained in several different units on campus
Retention period of 60 years from date of hire has forced cramped campus offices to store inactive records in attics, basements, and warehouses – with disastrous results
No single unit, including University Archives, has the space available to store these records if they remain in paper format
University Archives vault is currently full of inactive EPA personnel records, including student records (grad students have EPA research associate or teaching assistant appointments, with health insurance and benefits and their service counts toward retirement). These records are still needed occasionally by Human Resources to verify employment (mainly for retirement credit or reinstatement)

The Process

Surveyed locations on campus that have original personnel records (Office of the Chancellor, Office of the Provost, College of Arts and Sciences, EEO/ADA, HR Employee Records, and University Counsel) to get a count of file drawers/boxes of inactive records
Met with representatives from each area in June to discuss the situation
Examined inactive records stored in vault to determine archival value (found lots of biographical information in older files)
Conferred with Ed Southern for state guidance on personnel records retention and disposition
Considered July 9, 2001 memo to state agency HR directors from Thomas Wright re: destruction 30 years after separation or termination
Frank working concurrently to get an accurate inventory of forms included in EPA personnel files to complete the EPA records module

Main Points to Consider

Need for central location for inactive files in order to provide necessary access for required number of years after separation or termination
Need for University Archives to have necessary items of archival value for permanent retention
Need to reformat paper records in best archival and access medium to solve storage space issue
Need to gather information and cost estimates from microfilm vendors

Proposal

Each unit maintaining original EPA personnel records to be responsible for having their inactive EPA personnel files converted to microfiche 5 years after employee’s separation or termination – one copy (diazo) to HR for additional 25 years retention, one copy (silver halide) to Archives for permanent retention
Cost analysis done on converting existing inactive records stored in various campus locations to microfiche ($38,570), including those stored in Archives vault ($47,250) – to be returned to office of origin for conversion
Other alternatives suggested as well, including scanning and saving images to CD or in a database with microfiche created from scanned images for the permanent archives copy (more on this later)
Also gave figures for offsite storage of paper records in a modern, environmentally-controlled storage facility

Why Microfiche?

Microfiche is an accepted preservation medium and low-tech solution, requiring no additional equipment or software for retrieval of the needed files, other than a reader/printer. Many employee records would be complete in one microfiche sheet (or jacket), though some larger files may require several sheets.
Each microfiche jacket can be labeled (indexed) with employee name (last name first), social security number (if desired), and date of termination. They can then be filed alphabetically in microfiche storage boxes and stored on shelves for a fraction of the space currently occupied by file cabinets full of paper records.
If duplication of files is discovered when they are centralized, employee files on microfiche can be easily merged/interfiled.
Having employee records on microfiche will enable University Archives to maintain the permanent copy in one large alphabetical series. In the future, when new fiche is transferred, it can easily be interfiled with the existing fiche.

Where Do We Go From Here?

Draft proposal for reformatting inactive records sent out in December to those who had attended the meeting in June – opportunity for feedback went largely unnoticed while HR moved to a new building in January
Necessary change in previously approved SPA records module re: 30 year retention then destruction and draft EPA records module submitted to DCR for approval in December
Follow-up meeting with Director of HR Employee Records this week. HR is considering scanning records as a solution to the paper records dilemma, and we have asked to be included in the planning discussions, stressing the importance of properly managing their records during this process, making necessary changes to records modules, and making provisions for permanent retention of EPA personnel records in University Archives (microfilm or fiche from scanned images?)

STATE OF NORTH CAROLINA
OFFICE OF STATE PERSONNEL
1331 MAIL SERVICE CENTER
116 WEST JONES STREET
RALEIGH, NC 27699-1331

To: State Agency Human Resources Directors

From: Thomas H. Wright, State Personnel Director

Subject: Retention and Disposition of Inactive Personnel Records

Date: July 9, 2001

For many years the inactive personnel records from your agencies have been stored permanently in the State Records Center under the auspices of approved records retention and disposition schedules. Those schedules, as written by the Department of Cultural Resources, Division of Archives and History, in accordance with chapter 121-5 of the General Statutes of North Carolina, were much more appropriate when state government was smaller and employee turnover was less frequent.

The growth of government and the allied proliferation of records concerning its employees have forced a reexamination of such an extreme retention period. Members of the Office of State Personnel's Management Team and the Division of Archives and History have discussed the issue at length, and several key points have come to light.

Much of the information traditionally retained in a personnel file is duplicated in the Personnel Management Information System (PMIS) database.
Information concerning state employees who are members of the retirement system is retained by the Department of State Treasurer for ten (10) years beyond the death of the member. The Office of State Personnel and the Division of Archives and History feel that this information is more vital to retain for ensuring employees' rights than the administrative records typically found in a personnel file.
Retaining personnel records in perpetuity creates management problems that do not diminish over time, such as the exponential increase of storage space for the records. Retaining the records permanently also means that they are never destroyed, even following the death of an employee.
Requests for information from personnel records should continue to be referred to an agency's human resources office, where the official files are maintained and from where they are transferred to inactive storage at the State Records Center

In light of these factors, the retention and disposition instructions listed below are recommended by the Office of State Personnel for the personnel records of all state agencies. [Note: The permanent retention of these records is no longer recommended; instead, the records may be destroyed thirty (30) years after the employee's separation or termination.] Their adoption will ensure that information is not retained needlessly beyond its useful lifespan, and that records will be disposed of properly in accordance with chapters 121 and 132 of the General Statutes of North Carolina.

PERSONNEL FILES MAINTAINED IN STATE AGENCIES BY OFFICES OUTSIDE OF THE CENTRAL HUMAN RESOURCE OFFICE

DISPOSITION INSTRUCTIONS: Transfer to agency personnel office to be incorporated into official personnel file 1 year after employee terminates service.

PERSONNEL FILES MAINTAINED BY STATE AGENCY HUMAN RESOURCES DEPARTMENTS:

DISPOSITION INSTRUCTIONS: Transfer to inactive status when employee terminates service.

Item XXXX. PERSONNEL FILE (INACTIVE). Records concerning separated or terminated agency employees. (Comply with applicable provisions of G.S. 126-22, 126-23, and 126-24 regarding confidentiality of personnel records.)

DISPOSITION INSTRUCTIONS: Transfer to the State Records Center 5 years after employee terminates service. Records will be held for agency in the State Records Center 25 additional years and then destroyed.

Note: Records currently held in the State Records Center: Destroy 25 years from date received, or 30 years from separation or termination of employee, whichever is greater.

Please be advised that your agency's official records retention and disposition schedule should be amended to reflect this record keeping change. To initiate this process, contact the Government Records Branch of the Division of Archives and History at (919) 733-3540. The staff there can assist you in promulgating this important change.