According to RCW 40.14.060, public records can only be destroyed according to approved retention schedules. This applies to records in all forms, digital or paper, textual or audiovisual. When records become eligible for destruction, this process can be carried out in a variety of ways.
Destruction of paper records stored in the University Records Center will be managed by University Archives and Records Management. This process always involves the offices whose records are eligible for destruction, and only occurs after review and consent of those offices.
Destruction of paper records or digital records held by offices themselves is the responsibility of the respective offices of record. We strongly recommend a process involving Confirm, Document, and Destroy.
Confirm that there are no additional requirements for retaining the records. This may require a review by multiple people and includes ensuring that:
- the correct retention schedule is being applied;
- there is no legal action (lawsuit, grievance, dispute, or other proceeding) that requires the records' remain intact beyond the retention period;
- there is no impending audit or review that will require the records;
- there is no unresolved public records request that requires the records;
- the records are not also classified as “archival” (which requires their ongoing preservation – see below)
- if you are wiping a disk, you have taken appropriate steps not to wipe any records that must remain active and accessible
- [Note: it is illegal to destroy records that are subject to ongoing or anticipated legal, audit, investigative, or public records request actions]
Document the records that are being destroyed:
- In order to ensure accountability, compliance with recordkeeping laws, and corporate memory regarding records disposition, we strongly encourage that individual program units use a records destruction log to document all formal records destruction. Please use or extend the University Archives and Records Management Destruction Log template for this purpose. The authenticity of this log must be safeguarded, and each program unit should retain the destruction log indefinitely.
- You do not need to list every single item that will be deleted; rather you can identify the records in aggregate form per the examples in the spreadsheet.
Destroy/delete the records once you have confirmed their eligibility and made the necessary documentation
- For paper records, we strongly recommend shredding. If you have a large volume, see information below about how to access the services of a shredding vendor for your office.
- For digital records, you should delete all relevant copies of the records with the goal that they will be irretrievable.
- If you need to wipe a disk, consult IT for options, but keep in mind that you will need to ensure that there are no active records on the disk being wiped. Prior to wiping a disk, you must ensure that any records still subject to retention schedules, or to other legal actions mandating ongoing retention, are transferred to active, accessible storage. Backup tapes are not considered active, accessible storage.
Archival records must be retained. Records that are historical in nature or that have an "archival" designation on a retention schedule must remain intact. University policy and state law require that these records undergo review and selection for preservation in the University Archives. Contact University Archives for disposition of historical/archival records.
Information regarding shredding vendors is provided as a courtesy only: University Archives and Records Management is not the coordinator of shredding service on campus. All information should be verified with the vendor and with Barbara Lewis in WWU Business Services (x3068) before proceeding.
Offices that need direct shredding of confidential or other eligible records must establish an account directly with one of the university's contracted shredding vendors. To initiate service, contact Barbara Lewis in Business Services at x3068.
- The University Archives and Records Center will still provide shredding for all non-permanent records that are stored in the Records Center for university departments/offices/programs.
- Records with "archival" designation (digital or paper) must not be destroyed. Archival records are records with long-term historical or legal value. These records must be transferred to the University Archives for long-term preservation. Call x3124 with any questions.
- Records subject to legal holds or public records requests must not be destroyed until the hold is lifted. Legal holds may be required due to litigation, investigation, audit, public records request, or other official action requiring a suspension of records destruction. In these cases, affected records (paper or digital) must not be destroyed until the hold is formally lifted.
Document what you shred: In order to ensure accountability, compliance with recordkeeping laws, and corporate memory regarding records disposition, we strongly encourage that individual program units use a records destruction log to document all formal records destruction. Please use or extend the University Archives and Records Center Destruction Log template for this purpose. The authenticity of this log must be safeguarded, and each program unit should retain the destruction log indefinitely. [download Destruction Log template]
Establish a service point: Contact Barbara Lewis in Business Services (x3068) to set up service. You will need to work with Barbara Lewis to request a bin or bins from a vendor and to set up billing. The vendor will supply the bins and will retain ownership of the bins.
- Program units may want to consider coordinating shredding service at the departmental, divisional, building, or other level as appropriate in order to attain logistical efficiencies. This is entirely up to individual offices/programs/departments to undertake. Coordination should include consideration of both space/location and billing.
- Request service: You must work with the vendor to establish an appropriate service schedule.
- Pay for service: Barbara Lewis in Business Services (x3068) will help you establish departmental billing for shredding service. Please confirm pricing with Barbara Lewis.
University Archives and Records Management no longer provides direct confidential shredding of records from campus offices.
UARM had coordinated free confidential shredding to campus units since at least the 1980s through November 2012. Although this service was always provided as a courtesy, the decision to stop offering it was not made lightly. The bottom line was that our core workload has increased substantially since 1980 (5 times the amount of records stored, 20 times the number of reference/retrieval requests compared with 1979), but our resources have not.
In some cases, such as student labor hours, real resources are actually lower than they were decades ago. For example, UARM student labor hours were actually 15% higher in fiscal year 1991 than in fiscal year 2010, yet the amount of confidential shredding service UARM provided for campus almost quadrupled in that period. In that same period, all other workloads associated with transfer, storage, and retrieval of records more than doubled, and those related to shredding more than tripled.
Technology and management have definitely gained us efficiencies in dealing with these increases, but in almost every category the increased workload represents a need for labor hours. And to put this increased cost into budget perspective, as of 2012 the only dedicated funding for the UARM program, aside from a single FTE salary, was just over $2000 per year. All additional money to fund the program must be siphoned from the budget of the Library, our parent organization, which takes away resources from one of Western’s most important academic assets.
In looking at all the service areas of the UARM program, it was clear that the one service that could be turned back to program units with the least overall impact to the university was direct confidential shredding (which many departments already did on their own). All other services provided by UARM are either related to our mandated stewardship of records in storage or assigned to us by law.