Step 4: Destroy Transitory Records on a Routine Basis
As indicated in “Step 2”, if your office isn’t listed as the responsible unit in the records retention schedule, then any copies of records in that records class which you are keeping are transitory records rather than the University’s official records.
Official records are evidence of the university’s administrative activities, transactions, and decisions, and managed by the units carrying out or responsible for these administrative actions. Official records have continuing value to the university and are kept for the time period specified in the records retention schedules to meet legal, financial, operational, historical or other official requirements. Transitory records are of temporary or insignificant value, used for a limited time to complete routine actions or to prepare the final version of records, or they are convenience copies kept by employees who aren’t responsible for the official record but still need the information in their current work.
Transitory records are mentioned in the records retention schedules only if a specific retention rule applies to them, usually to ensure that copies of records containing personal or confidential information are securely destroyed as soon as possible and that this disposal is documented, when required.
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.
Common examples of transitory records include the following:
- Working documents – drafts, rough notes, preliminary versions, and other intermediate documents – and supporting materials used in the preparation of final documents (reports, contracts, academic calendars, policies and procedures, letters and memos, etc.) which are not needed once the final documents are completed;
- Committee agendas and minutes held by units on a distribution list or by committee members other than the committee chair and secretary;
- 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 of electronic records retained as the official record in an enterprise system (e.g., the HR system);
- "cc" or FYI emails, or other documents kept only for convenience or information;
- Announcements, broadcast emails, and notices of a general nature;
- Insignificant or inconsequential 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 stock of university publications or blank forms.
This list is not exhaustive, so you should contact the University Records Manager for assistance when you are unsure if records are transitory or not.
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 can be used for this purpose, but destruction approval is not required since every University employee can (& should) dispose of transitory records when they are no longer needed for current work. Although it would be impractical to use the form to document every instance of destroying transitory personal information, it’s recommended that the form be used in cases involving high volumes of transitory personal information, or highly sensitive information. Please contact the University Records Manager if you’d like assistance with assessing such cases.
The concept of transitory records as intermediate versions, supporting materials, or duplicate copies of the University’s official records can also apply to content found in the University’s digital information systems, including enterprise systems.
Data files exported from administrative systems and used only for a limited time to support routine system functions in other systems are also 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 simply duplicate some content of those databases are transitory records. However, if this extracted data is incorporated into another administrative activity, edited or altered during this activity, or becomes a required resource for this activity, then the data becomes part of the records of that new activity. For example, if data extracted from the student information system is incorporated into a system used by academic advisors in their work with students, then the data becomes part of the University’s academic advising records and is not transitory.
As the previous example indicates, it is important to distinguish between cases where copies of records are kept for short-term reference needs – and are therefore transitory – and cases where information/data is re-used in new administrative activities: for example, when enterprise system data is extracted and then used in a different system for other administrative purposes. This is an example of information sharing and re-use, and the contents of the 2nd system will fall within the scope of a retention schedule which is specific to those administrative activities and their records.
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.