Records Custodians: Why It’s a Great Idea to Appoint Them

Records Custodian

Records Custodian

In the past two weeks, we’ve talked about the duties of a Records Management Officer and how  important it is for them to identify allies in the workplace. It’s unlikely that the Records Management Officer can realistically keep track of every single record at all times. How do you handle this? You need to know where your records are, but one person can’t bear that burden alone. Aside from nominating Records Liaisons, we recommend creating a system where every type of record has a designated “custodian” in your government. Records Custodians are the everyday employees who create and maintain the records that keep your office running.

This sounds complicated, but if you really think about it, some semblance of this kind of workflow is probably already in place in your office. Who is responsible for timecards? (Payroll Manager) Who is responsible for travel expense reports? (Accountant) Who is responsible for press releases? (Communications Officer) Who is responsible for your emails? (You!) All of those records have natural custodians. The best custodian is someone who created the record or someone who is in regular contact with the record. The custodian can then report to their Records Liaison, or if you’re a smaller office, directly to the Records Management Officer when they have records that are due for disposition.

The benefits of clearly defining a custodian for each type of record are numerous – by making someone aware that they are a Records Custodian, you are also including them in the overall records management program and giving them a reason to “buy-in” to your policies and procedures. A little responsibility delegated to individual employees can go a long way towards making your program successful. A great way to start is to take a look at your last records inventory and determine the individual custodian or department that should be responsible for the record. There will be some records, like general correspondence, that will be on the individual level, while other records, like time sheets, might be assigned to a particular position within your government, like the Payroll Manager of Human Resources.

Since almost all of your employees will be Records Custodians, knowledge of the overall picture of Records Management might be limited for them and that’s okay. We recommend including some basics of RM in your annual training – try to sneak it into Computer Acceptable Use Training or some other annual required training – and to include it in any new employee training. Your employees don’t necessarily need to know how to read a retention schedule or fill out a disposition log. This will frustrate or confuse a lot of employees and then they are less likely to be helpful. Give your employees only the most pertinent information, such as “Email still counts as correspondence and needs to be retained for X number of years” or “Before deleting any files from your shared drive, please check with your Records Liaison to ensure all retentions have been met.”

We’ve now posted several blog posts about different positions that are involved in RM in many local and state governments. If you have deputized department heads or key players into acting as Records Liaisons for your government, your RM structure might look a lot like this:

RMO Organization Chart

In a perfect world, your infrastructure might look like this.

It’s okay if your government doesn’t look like this or if you’re still trying to get near this goal. It’s also okay if your Records Custodians report directly to the RMO and there are no Records Liaisons at all. This will all depend on many internal factors like institutional norms, culture and size of the agency. We know that every local and state government is a little different from the next, but we’re always here to offer advice and help when and where we can!

2 thoughts on “Records Custodians: Why It’s a Great Idea to Appoint Them

  1. Great post! This is one area where working with IT is not just important, but potentially mutually beneficial. State agency IT staff are concerned with data ownership because 1 TAC 202.22 requires them to keep track of who owns what (for information security purposes). Additionally, agency Public Information Officers have a vested interest in knowing who the custodians are because they need to know who to contact with they get a PIR for something. The RMO/RML can add a layer of “…and what record series does it belong to? Is it the record copy?” and fill in any gaps in knowledge that IT or the PIO might be missing.

  2. Since the custodian of records is also the person who introduces records into evidence, it should be uncommon for the RMO or a member of the Records Management staff to be the custodian. In the Harris County Records Management Plan, we address it thusly:

    (j) “Records Custodian” shall mean the appointed or elected public officer who
    is in charge of a Harris County office that creates or receives Harris County
    records or a person appointed by the officer to serve as the custodian of

    In Harris County, the RMO does: “Act as the Records Custodian for those records for which the office of origin
    cannot be determined, records of defunct offices unless the records have been
    transferred to the custody of another County office, records that the County
    acquires coincidental to the acquisition of property unless those records are
    required by a County department to maintain or administer the asset, and for
    existing offices for programs no longer overseen by the department head if the
    department head transfers them to the Records Management Officer….”

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