FAQ: When Should I Update My Records Management Policy? (Local Governments only)

Are you in a similar situation to one or more of the cases presented below?

Case 1: Our records management compliance files are from the 1990s or earlier.

Case 2: We have several ordinances and/or letters from different periods instead of one document that has all our records management policy information.

Case 3: Our Records Management Policy (RMP) designates a position that does not match the position of the current Records Management Officer (RMO) on the SLR 504 form.

Case 4: Our RMP does not clearly state who will serve as RMO.

Case 5: Our RMP is missing important components, such as stating that records are public property.

Case 6: We do not have an RMP yet, or I am not sure if we have one on file with TSLAC.

Case 7: My school district wants to use the CPC templates issued by the Texas Association of School Boards (TASB).

Case 8: Our local government wants to keep all records permanently.

Case 9: Our law firm represents our governing body, and the firm files our compliance paperwork.

Case 10: I want to serve as the countywide RMO, or I want to designate the countywide RMO to serve as the RMO for my county elected office.

Firstly, it is always beneficial to stay in contact with your assigned analyst to make sure your government’s compliance file is squared way (see FAQ: Are We In Compliance?), and secondly, here is what you will need to do in each of these cases:

For Cases 1-6:

  • Option 1: Use TSLAC’s policy template, and make sure the governing body’s signature is on the last page of the policy, or submit meeting minutes that show governing body approval of the policy.  
    1. TSLAC recommends designating a position to serve as RMO so that the same policy can be used for successive holders of that position.
    2. Make sure the current RMO files an SLR 504 form with TSLAC, and the RMO’s position on this form must match the position designated to serve as RMO in the policy.
  • Option 2: Submit an order, an ordinance, a resolution, or an updated existing policy to TSLAC, and include a copy of the meeting minutes that show governing body approval of the order, or the signatures of the governing body should be on the last page of the policy. Be sure to factor in bullet points 1 and 2 above.
  • Send all compliance documents to the following address:
    State and Local Records Management Division
    Texas State Library and Archives Commission
    P.O. Box 12927
    Austin, TX 78711-2927

For Case 7 (school districts):

  • Submit a copy of:
    1. CPC-Local and CPC-Legal (contact TASB’s Policy Service Consultants for samples of these policies)
    2. School board minutes showing the CPC documents were adopted
  • Make sure the current RMO files an SLR 504 form with TSLAC, and the RMO’s position on this form must match the position designated to serve as RMO in the CPC documents.
  • Send all compliance documents to the highlighted address above.

For Case 8 (permanent retention of all records):

  • Make sure your local government’s Records Management Policy indicates that it will maintain all records permanently. If a law firm files your local government compliance documents, please also see Case 9 below.
    • You may choose to use TSLAC’s policy template, or submit an order, an ordinance, a resolution, or an updated existing policy to TSLAC, and include a copy of the meeting minutes that show governing body approval of the policy/order, or the governing body’s signatures must be on the last page of the policy.
    • If your local government invokes Section 203.041(g) of the Local Government Records Act, it is exempt from preparing a records retention schedule.
  • Send all compliance documents to the highlighted address provided in the section for Cases 1-6.

For Case 9 (law firms):

  • File a copy of the Order Establishing a Records Management Program (may include titles such as “Exhibit A”), and include the governing body’s signature is on the last page of the order, or submit meeting minutes that show governing body approval of the order.
    1. TSLAC recommends designating a position to serve as RMO so that the same policy/order can be used for successive holders of that position.
    2. Make sure the current RMO files an SLR 504 form with TSLAC, and the RMO’s position on this form must match the position designated to serve as RMO in the policy.
      • For example, if the order designates “a Paralegal with Freed PC” to serve as RMO, the individual who signs the SLR 504 form must have the same position that is designated as the RMO in the order.
      • If the law firm is designated in the order to serve as the RMO, the SLR 504 form must be completed and signed by an individual at the law firm with signature authority. Additionally, the law firm must submit a list of authorized individuals, including their titles, who can sign compliance documents for the local government’s records management program.
  • Send all compliance documents to the highlighted address provided in the section for Cases 1-6.

For Case 10 (countywide RMO program; see FAQ: What is a Countywide RMO?):

  • By default (see Section 203.001 of the Local Government Records Act), each elected county official is the RMO for their own office (this includes the divisions and the departments that work for their office), but the elected county official can designate the Countywide RMO to serve as their RMO if one of the following bullet points is true in your case:
    1. The Countywide RMO is not another county elected official, and:
      • The elected county official and the RMO for the county have signed the SLR 512 form in the appropriates spaces on the form (see instructions to complete this form).
    2. The Countywide RMO is another county elected official, and:
      • The compliance file for the county has been updated with TSLAC by the current elected county official that will also serve as the RMO for the county (see FAQ: Are We In Compliance?).
      • The separate compliance file for the current elected county official that will also serve as Countywide RMO has been updated with TSLAC.
        • For example, if the County Clerk wanted to serve as Countywide RMO for Travis County, the current County Clerk would need to make sure their own compliance file is updated, and they must make sure the compliance file for Travis County is updated before any other elected county officials can designate the Countywide RMO to serve as the RMO for their offices.
      • The elected county official that wants to designate the Countywide RMO on the SLR 512 form has signed the form, and the Countywide RMO has signed the form (see instructions to complete this form).
  • Send all compliance documents to the highlighted address provided in the section for Cases 1-6.

Reach out to your analyst to make sure your local government’s compliance file remains up to date or, find out if there is a current Countywide RMO on file if your elected county office would like to participate in the Countywide RMO program.

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