Step 4: Destroy Transitory Records on a Routine Basis
Official vs. Transitory Records
As described in “Step 2”, if your office isn’t listed in the “Responsible Unit” section of the records retention schedule then your records in that class are transitory, not the University’s official records.
Official records are evidence of the University’s administrative activities, transactions, and decisions, and managed by the units responsible for the activities. Official records have continuing value to the University and are kept for the time specified in the records retention schedules to meet legal, financial, operational, historical or other official requirements. Transitory records are of temporary or insignificant value, needed to complete a current routine or to prepare the final version of records, or because you need the information they contain for current work.
Transitory records should be destroyed on a regular basis, when their usefulness has ended. The general rule of thumb is to destroy transitory records when your operational need for them has ended and before the end of the retention period for the official record.
Please note that preliminary drafts or versions of documents are transitory records which may differ significantly in their content from the final approved versions of the documents (the official records). They are therefore classified as confidential even if the official record is public. Transitory records are mentioned in a records retention schedule only if a specific retention rule applies to them, usually to ensure that copies of records containing personal information are securely destroyed as soon as possible and the destruction is documented.
All confidential (including restricted & highly restricted) transitory records should be securely destroyed.
Examples of Transitory Records
Some common examples of transitory records are:
- Working documents – drafts, rough notes, preliminary versions, and other intermediate documents – and supporting materials used to create final documents (reports, contracts, academic calendars, policies and procedures, etc.) which are not needed once the final documents are completed;
- Committee agendas and minutes kept by committee members other than the committee chair and secretary, or received by units for information;
- Copies of records retained when the original is sent to another unit (e.g., a copy of an invoice that was sent to Finance for payment);
- Records in an alternate format from the version retained as the official record: for example, printouts or extracts from enterprise systems such as Quest or Workday;
- Announcements, broadcast emails, "cc" or FYI emails, or other documents (electronic or hard copy) kept only for convenience or information;
- Insignificant information items concerning routine administrative or operational matters: for example, routine email exchanges to schedule or confirm meetings or events;
- Advertising & promotional materials received from suppliers;
- Extra copies of University publications or blank forms.
This list isn’t exhaustive, so you should contact the University Records Manager for assistance when you are unsure if records are transitory or not.
Documenting the Destruction of Transitory Records Containing Personal Information
The Freedom of Information and Protection of Privacy Act (FIPPA) requires that we document the destruction of records containing personal information, including transitory records. The University records destruction form should be used when destroying significant volumes of transitory personal information (e.g., extracts from the student records system) or when destroying highly restricted information. Destruction approval is not required when destroying transitory records because every University employee can & should dispose of transitory records as a regular routine. Contact the University Records Manager if you need assistance in assessing such cases.
Transitory Records in Information Systems & Applications
The definition of transitory records also applies to data found in or derived from the University’s digital information systems, including enterprise systems.
Data files exported from information systems and used only for a limited time to support routine system functions in other systems are transitory records. For example, data exported from the student records system or HR system and used in other systems for automatic verification of student enrolment or staff employment status, or to support “autofill” functionality in data entry screens, are transitory records.
Similarly, data extracts, reports, or printouts from databases which duplicate content of those databases are transitory records. However, if the extracted data becomes part of another administrative activity, edited or altered during this activity, then the data becomes part of the records of that activity. For example, data extracted from the student records system and added to the system used by academic advisors when advising students becomes part of the University’s academic advising records and is not transitory.
Transitory Records vs Reusing Information in New Activities
It's important to distinguish between transitory records used for short-term information needs and the re-use of information/data in new administrative activities, where this information becomes part of the official records of the activities. For example, when enterprise system data is extracted and then added to a different system supporting other administrative activities, this is an example of information sharing and re-use. The contents of the 2nd system falls within the scope of a retention schedule specific to those administrative activities and their records.
Transitory Records, FIPPA, & Legal Holds
As with official university records, transitory records are subject to FIPPA and legal discovery. When a FIPPA access request is received, any transitory records that are responsive to the request must not be destroyed until the request has been processed and any appeal period has elapsed. Similarly, transitory records related to actual or pending litigation or government investigation must not be destroyed without the express permission of the University Secretary or delegate. This restriction begins from the moment any employee gains knowledge that legal action or a government investigation is reasonably foreseeable, and remains in effect until removed by the University Secretary.