by Brianna Cochran
For state agency Records Management Officers or liaisons tasked with recertifying their agency’s records retention schedule, the process can seem a bit overwhelming. This article will help break the process down into more manageable steps.
Note: This article only applies to state agencies. For local governments looking to customize their local retention schedules, see this article.
First, let’s look at an overview of the recertification process. “Recertification” or “certification” is the process of reviewing and updating your agency’s records retention schedule and analysts often call the schedule you’re updating a “recert”.
Most state agencies recertify their retention schedules every 5 years but check with your assigned analyst if you’re a new agency, because your first two recertifications require shorter review periods. Agencies can also update schedules at any time by submitting an “amendment”, but this article focuses on how to recertify schedules. Generally, these are the steps to recertify state agency retention schedules:
The recertification process is not always so linear. Some parts of the process are more cyclical. For example, some very complex or older schedules may require multiple rounds of corrections and sometimes corrections are required after Step 5: Archives Review. In any case, when first learning the process it helps to understand those six basic steps, so let’s look at those steps in more detail:
1. Recert Notice Period
Six months before your recert is due, your analyst will send your agency a recert notice letter and email reminding you of your recert due date. During this 6-month period, you will review and prepare an updated retention schedule for submission. You’ll want to follow the instructions in your Recertification Packet (PDF) closely and ask your analyst if you have any questions. See Step 2: Submit Materials for more details about what to submit. Bulletin 3 outlines the minimum requirements for recertification in Section 6.5 and we also explain our review criteria in Step 3: Analyst Review.
(a) To be a candidate for certification, a records retention schedule must:
(1) list all records series maintained by the state agency, regardless of medium;
(2) indicate whether the records are archival state records or state records that must be reviewed by the state archivist for potential archival value prior to their destruction;
(3) ensure that state records maintained by the state agency listed in the Texas State Records Retention Schedule or Texas State University Records Retention Schedule are retained for the minimum periods prescribed in the schedules;
(4) ensure that state records not listed in the Texas State Records Retention Schedule are kept for a length of time sufficient to meet administrative, legal, fiscal, and archival requirements; and
(5) be submitted in a manner and form prescribed by the state records administrator.Bulletin 3: 13 TAC §6.5
2. Submit Materials
After you’ve prepared an updated schedule, the next step is to submit your materials. To submit a retention schedule for recertification, email the following files to your assigned analyst:
- SLR 105C (PDF). The 105C is a cover page for your recertification and is included in your agency’s Recertification Packet (PDF).
- SLR 105 (Excel). This spreadsheet is your agency’s revised retention schedule—the “recertification” or “recert”. See Instructions for Completing Form SLR 105 (PDF) for more information.
What if you need an extension? If your agency isn’t ready to submit a recert by the deadline, you may request an extension by emailing your analyst. Analysts can issue a maximum of four 3-month extensions.
3. Analyst Review
After your analyst receives your recert, we review the submission and write a Review Memo documenting required and suggested revisions. “Required” revisions are any corrections you’re required to make to your schedule in order for it to be approved. “Suggested” revisions are optional changes you may want to—but are not required to—implement. See below for examples of required and suggested revisions:
We won’t approve your schedule unless:
- Retention periods meet or exceed the minimums required by the:
- The schedule includes archival codes and state publications depository notes from the RRS and/or URRS.
- Every record series has at least an:
- AIN (Agency Item Number)
- Record Series Title
- Retention Period
- “AC” retention codes are defined in the “AC Definition” column.
- AINs are unique/not duplicated across the schedule. —Only required if your agency stores records at our State Records Center.
We’d be delighted if your schedule also had:
- A description for every series. This is especially helpful for any custom series unique to your agency.
- Record Series Item Numbers (RSINs) which align with the RRS/URRS or use appropriate stems.
- Any abbreviations or acronyms are defined when first used or the schedule includes a supplemental document defining acronyms.
- An organized structure. Schedules can be structured to group records by department, function, etc.
4. Agency Corrections
After we review your schedule, your analyst will email you their Review Memo requesting any corrections. They may ask you to add series common to state agencies, explain why your agency does not need those series, make required changes related to records management laws or rules, or address any storage concerns if applicable. To move the recert to the next step you’ll need to:
- Make any corrections as needed.
- Leave any feedback for your analyst in the Review Memo’s “RMO Notes” columns. How you fill out those columns is up to you, but you might use the Review Memo to:
- Note where you’ve completed a requested change.
- Ask your analyst questions or document why you’re not implementing a requested change.
- Return the Review Memo and corrected submission to your analyst.
5. Archives Review—Not Required for Universities
After your analyst approves your corrected recert, they send the recert to our State Archives for their review. Ultimately, the reviewing archivist is concerned with making sure your agency’s records which have long-term historical value are properly identified on your schedule. They’ll pay close attention to archival codes and archives notes on your schedule to make sure they’re appropriate and align with the RRS. The archivist may ask for corrections to your schedule or approve it as is. If corrections are required, your analyst will work with you to update your schedule then send your schedule to Archives for their approval.
Note: Universities do not require Archives Review because the State Archives does not collect university archival records other than those required by the Texas State Publications Depository Program.
6. Final Approvals
Once an archivist approves your recertification, the schedule goes through its final approvals. Both our agency head and State Records Administrator sign off on the recert. Finally, an analyst uploads your schedule to our website and sends you an approval email and letter to let you know your schedule is approved and ready for use.
The entire process from submission to final approval can take up to a few months or longer, depending on the number of recertifications and amendments analysts and archivists are reviewing, and how quickly your agency can make any corrections. If you ever need help updating your schedule or are feeling unsure about the process, please let your analyst know—that’s what we’re here for!
For additional information about recertifying your agency’s records retention schedule, check out our related resources:
- State Agency Recertification 101 Webinar
- State Agency Records Retention Schedule Recertification Guide
- Bulletin 3: Records Retention Scheduling Rules
- Forms for State Agencies. See the SLR 104 form if you need to update your agency’s Records Management Officer.
- The State Archives Answers FAQs from State Agencies