Classification and the Purpose of General Retention Schedules: RIM v. GRAMA

Rebekkah Shaw General Retention Schedules, GRAMA, Records Management

There is something unique about records management in Utah, and it might be causing confusion. We have two meanings for the term classification. One comes from the Government Records Access and Management Act (GRAMA), the other from the records management profession.

Most of the records officers we work with refer to classification as defined in GRAMA, which states classification is “determining whether a record series, record, or information within a record is public, private, controlled, protected, or exempt from disclosure” (63G-2-103(3)). In other words, in the context of record requests, classifying records authorizes the denial, partial denial, or release of a specific record at the time it is requested.

Classification is also done at the series level, but then it is called “designation” in GRAMA. GRAMA defines designation as “indicating, based on a governmental entity’s familiarity with a record series or based on a governmental entity’s review of a reasonable sample of a record series, the primary classification that a majority of records in a record series would be given if classified and the classification that other records typically present in the record series would be given if classified” (63G-2-103(7)). In other words, the designation is assigned at the time a record series is identified and is an assessment of the classification of a typical record in the record series. You can see your agency’s designation for each record series on the Division of Archives and Records Service website (see below).

In the Records and Information Management profession
In the field of records and information management, classification is defined as “the process of identifying the category or categories of business activity and the records they generate and of grouping them, if applicable, into files to facilitate description, control, links and determination of disposition and access status” (ISO/TR 15489:2:2001). Simply put, classification is the system used to organize your records into categories of function, or business activity, to provide for easier searching and management through the life of the record.

In the past, some agencies used the organization of the general retention schedules on the Archives website as a classification scheme. Some general retention schedules were even designed and written as role-based, or were so specific that they named specific forms in the description. The State Archives has been moving away from that practice because classification systems and retention schedules need to be function-based in order to comply with ISO standards. Also, in the digital world, specific and restrictive general retention schedules are roadblocks rather than tools; a function or process-centered approach is more practical. The general retention schedules are now broader, so you can comply with a retention schedule while having the flexibility to use it to fit your agency’s unique classification scheme.

These are some of the reasons for the reorganization of the general retention schedules on the Archives website. Adjusting to the new organization will require a change in thinking for some people, but there are definite advantages to these changes as well. For example,  Utah Code 17-16-5.5(2018) says counties can assign duties of the assessor to the treasurer. The law here allows for a function to be moved from one role to another, so organizing the general retention schedules by role doesn’t work. There used to be a category under the county schedule titled ‘treasurer’ and another category titled ‘assessor.’ A record officer in this situation had to search both lists.

Purpose of the Retention Schedule
The purpose of the general retention schedules is to specify the approved retention and disposition of common records. They do not classify your records according to GRAMA; designation and classification are both responsibilities of the agency maintaining the records (Utah Code 63G-2-307). General retention schedules also do not classify or categorize your records in detail for the purposes of records management. It is up to your agency to determine which general retention schedules apply to the records you create, which should be identified within your own classification scheme. What the retention schedules do provide is pre-approved legal authorization to retain and dispose of records with confidence (either destroying them or transferring them to the State Archives, depending on the historical value established in the schedule), per Utah Code 63G-2-604.