Administratively Valuable (AV) is a retention code that stirs a lot of questions. How long is AV? What even is AV? Can you say “Administratively Valuable” five times fast? While we analysts at TSLAC can point out best practices and strategies regarding this retention code, we can only speculate so much. To offer a different perspective, we’ve asked a few experienced record managers from Local Governments and State Agencies to help chart the gray territory that is Administratively Valuable.
Victoria (V) – Denton County (LG)
Lena Roberts (LR) – Texas Department of Motor Vehicles (SA)
Lee Woodward (LW) – City of La Porte (LG)
Introduce yourself. What is your records management background?
V: Since starting with Denton County in April 2018, it’s become a habit to say, “Hi, it’s Victoria from Records Management!” anytime I meet someone or make a phone call, but most of my previous work experience was in libraries. While attending UNT, I worked as a student assistant in multiple campus locations and library departments, so I developed an intense appreciation for the work librarians do and the services they provide to communities. A few months before I was set to graduate, a full-time Stacks Manager position became available, so I jumped at the opportunity. I worked full-time in UNT’s Eagle Commons Library (now known as Sycamore Library), which housed their government documents collection among other materials. The GovDocs team was my first real introduction to the wide world of government records and information and I learned a ton! About a year and a half later, I applied for the Assistant Manager role with Denton County at the recommendation of a previous library coworker. I’m glad I did because I really enjoy the work I do here with Denton County and just hit my fifth anniversary in records management.
LR: My name is Lena Roberts, and I’m the Records Management Officer and Public Information Coordinator for the Texas Department of Motor Vehicles (TxDMV). I’ve been in this position for a little over a year now. Prior to coming to TxDMV, I advised the RMO and PIC at another state agency for about four years.
LW: Howdy, all! I’m the City Secretary and PIO for the City of La Porte (east of Houston on the Ship Channel bay – we’re near Baytown). I’ve worked in this profession since 2009, in two cities with populations around 35,000-38,000. My records management education first came from the Texas Municipal Clerks Association (TMCA), as part of our certification program. That led me to TSLAC (we’re huge fans of y’all’s!) and professional records management organizations. Our staff are members of NAGARA. I have earned the GARA certificate and, through ICRM, became a Certified Records Analyst (CRA) and Certified Records Manager (CRM) last year. Now, I serve on the GARA Certificate Committee, am a grader for the ICRM Part 6 exams, listen in as a guest at the SACC RIM meetings, and help out the NDSA/Digital Library Federation (DLF) Forum’s Planning Committee and Fellowship and Reviewer Subcommittees—in addition to working on records management within our City. We kinda love records!
How would you define or explain AV to someone unfamiliar with records management?
V: Whenever I approach “AV” with county employees who aren’t already familiar, I explain it as the useful life of a certain type of information. I try to stay conceptual when talking about AV because I find people misunderstand it to mean “as long as I want” or “there’s no retention.” While that is kind of true, I always want to make sure they understand you need to be deliberate and consistent when determining the administrative value for a type of information.
LR: “Administrative Value” is really subjective. If you ask an attorney whether a record is administratively valuable, you’ll get the standard lawyer response: it depends. Generally, a record is administratively valuable if it’s worth keeping because it contains information that will likely be of use or value in the future, perhaps because the subject matter is unique, complex, or was of high media, legislative, or public interest. Even records with “hard” retention periods can be kept longer than required if they have administrative value.
LW: I would encourage them to think about the usefulness of a record and how often they access it. I’d ask them to consider how they view what’s valuable to their work and whether it is valuable administratively, historically, or in some other sense. For example, something I think is going to be valuable if we’re in disaster recovery mode may certainly be valuable, but not likely to be saved in the same manner or under the same retention as a reference document they use weekly. Same goes for a copy of the City’s original articles of incorporation. All have value, but some fit a records schedule in a different way. Alternatively, the roster of executive staff cell phone numbers from two years ago that is now out of date and no longer administratively valuable like it was when it was new.
Do you find AV to be useful or troublesome? Why?
V: I usually find AV to be troublesome because people tend to think it’s a sort of freebie when it comes to retention. Or people tend to think AV information doesn’t need to be managed. I do see the value in allowing agencies to individually determine the useful life of a certain kind of information, but more often than not, I find most people don’t realize they are determining the administrative value for that entire category of information and that retention should be applied consistently.
LR: If find it troublesome in that what may be of administrative value to an individual may not be of administrative value to the organization as a whole, and when it comes time to evaluate records for disposition, people tend to keep things in case they are or may be valuable instead of because they are valuable. The thought of disposing of such records can cause some people extreme anxiety, which leads to electronic hoarding and puts a strain on an agency’s storage resources. I’ve never run across a situation where folks over-dispose of AV records… it’s always the other way around!
LW: It can be problematic if it is used as a crutch to save everything, but it can also be useful as a learning tool, to help convey the idea that we use the retention schedules to manage and improve them. If an employee has a record they really want to keep, we can have a good discussion about where it fits in the schedule or why this might be a good idea to consider an amendment to a schedule or reaching out to TSLAC to see if others are running into similar issues (who doesn’t love a good records conundrum?). When employees know records management isn’t just designed around throwing things out or second-guessing work habits, the anxiety can drop down for more thoughtful consideration and the ability to make their case for something more clearly.
How do you limit risk involved with AV retention?
V: I think the biggest risk with “AV” series types is that you will have people retaining the same information inconsistently. For example, with the appointment records series I mentioned above, you might have several Public Health clinics creating records that fall into that group. If no deliberate decision making is done about what the actual value of the information is or how long it should be kept, you’ll end up with folks disposing of things inconsistently. In my opinion, the best way to limit the risk with an AV group is to ensure the owning office has done some research about the information and made a decision for how long they really need to retain it. This will prevent the inconsistency and confusion.
LR: When I train staff on record retention for AV records, I tell them that if they elect to retain records because of their administrative value they should consider the agency’s resource limitations—such as physical storage space and disk/network storage space—and that they should be cognizant of the fact that records kept because of their administrative value are subject to discovery, subpoenas, and Public Information Requests, even if any applicable “hard” retention period has expired. Before each mandatory disposition review period, I remind staff that records retained because of their administrative value should be evaluated for their continued usefulness and advise them to consider whether the information has become outdated—for example, whether the records relate to a law that has since been repealed or an internal memoranda that’s been superseded—and how likely it is that the scenario that prompted the creation of the record or the need for it will reoccur. Lastly, I give them this piece of advice: If you believe that a record is no longer administratively valuable but are having trouble pushing that delete button, consider seeking a second opinion and ask a colleague to review the records first. Concurrence from an objective observer can give you the confidence you need to push that button without fear! (After you’ve completed the applicable disposition form and had it approved, of course.)
LW: Relationships and conversations. We just went through budget meetings for the new fiscal year and the conversations reminded us that different departments have different viewpoints and experiences, and no one knows what they don’t know. We brought it right back to records management and how we tend to overwhelm departments and divisions with presentations that try to cover too much. Like the fish who say, “Water? What’s water?”, we realize that points of view that may seem obvious to us are not necessarily always obvious. Our amazing Open Government Analyst just took a position with another city (we’re still weepy!) but it provides the perfect opportunity to change the way we’ve offered training. We’re going bite-sized and more frequent for a while.
What components of a record do you consider for a proper AV retention? Do you have an example of identifying these aspects?
V: I usually spend some time asking the record holder basic questions like how, when, and why they would access the information. This helps me understand more about the records and get familiar with how they’re created and accessed. I also check with them to see if there are any external requirements that would impact retention like grant or contract terms or if there are entities that would ask to see the info as part of some kind of audit. I ask them these questions because I want this info in the forefront of their mind when they’re considering the “value” of the information. An example of this process would be when I worked with our Public Health employees who work with patients in the Denton County Jail. They had documentation that we thought was outside the scope of PS4200-11, Inmate Medical Records, that instead would fall under HR4750-01, Appointment Records, which is an AV series. They explained that they typically don’t need to refer back to this documentation after about a week or two, but because we’re providing care to jail inmates, there are additional considerations and they need to retain the documentation longer than other Denton County Public Health divisions were keeping similar records. We went over all their considerations and I believe we landed on three years as the appropriate retention period for their division.
LR: As stated above, I first consider whether the record contains information that will likely be of use or value in the future. I then try to think of scenarios where we would need to access the records and consider: 1) how likely it is that those scenarios would occur, and 2) what would happen if those scenarios did occur and we no longer had the information—sort of like a cost-benefit analysis. For example, in the PIR world, the retention period for information that was released pursuant to an Attorney General decision is two years. For one particular PIR we received, the responsive information was so voluminous that it took multiple staff weeks to pull the information together. The information requested in that PIR is requested quite often, it just happened that this particular PIR covered a multi-year date range. When the two-year retention period was up, I decided that the information was administratively valuable because we could refer back to those records and produce information in response to other PIRs with much smaller date ranges without staff having to reproduce the work. It turns out we’ve only referred back to that information a few times, but the times we did refer back to it really were time savers in the end!
LW: I think this is again related to how useful a record is in the day-to-day work of an employee and how often it’s accessed. Some records are just safety nets, some may be better truly viewed as training documents, and others just haven’t been fully questioned. In our office, we use checklists in relation to council meetings, election procedures, and liquor permitting processing, some more regularly than others and some we could probably recite or recreate parts of in our sleep. But if things get a little hectic or we have to pull in a temp, it’s great to just pull something up and have it to refer to. Could we live without some of these documents? Possibly, but life is smoother with them. As with all records, we do want to consider other issues, like risk management, legal and regulatory standards, and historical or archival value.
Is there an artist, character, or song that you think portrays AV?
V: I think I’d go with NSYNC’s song “Bye Bye Bye” because I really want people to determine the administrative value of their AV record types and then say “bye bye bye” to them once they’re no longer useful.
LR: “With or Without You” by U2. The actual verses may not be applicable, but the chorus is dead on! Oh, my little AV record, I can’t live with you taking up all this space, but I can’t live without the security you give me by just being there for me just in case I need you… someday.
LW: TSLAC’s posts about records management references in media have been great! I can no longer watch someone in a film walk into a law enforcement evidence locker or dusty basement of file boxes without thinking about records. Raul’s example of The Clash’s “Should I Stay or Should I Go” as a good reference to administratively valuable records is spot on. Thinking about what I said above, I’d have to go with Janet Jackson’s “What Have You Done For Me Lately?”, a true paean to taking a moment to evaluate what’s going on and how it’s serving your life—or not!
Who knew that AV is the sole inspiration for many rock/pop hits? It makes you wonder what the other analysts were listening to when writing about AV:
- How Long is “AV”?
- FAQ: Is it possible to keep records too long?
- Why should I purge electronic records that have met retention?
- The Meaning of “Historical Value” on Local Government Schedules