Are you a non-elected local government considering updating your RMO designation? This article will explain your options!
Note: “Non-elected local government” refers to counties, municipalities, ISDs, and other local entities outlined in our article on local government status. This article does not apply to elected local officials or state agencies/public universities.
Two Ways to Designate an RMO
Every non-elected local government’s governing body has to designate a records management officer (RMO) by either name or position. That designation should then be filed with TSLAC, along with minutes from the meeting at which it was adopted and form SLR 504.
When designating by name, these steps must be repeated each time the RMO changes. Designating a position can save you some time: as long as the new RMO has the same position as their predecessor, only form SLR 504 needs to be submitted; no further governing body action is needed.
These requirements come from the Local Government Records Act, specifically Local Govt. Code §203.025.
City of Townville: Designation by Name
It’s a beautiful day in the City of Townville, and City Secretary Jane Doe has just finished filing her compliance paperwork with TSLAC. Everybody knows Jane is the go-to person for all things records, so the city council designated her by name in an ordinance:
Jane Doe shall serve as Records Management Officer for the City of Townville.
She sent TSLAC the ordinance, minutes from the council meeting, form SLR 508: Declaration of Compliance with Local Retention Schedules, and form SLR 504: Designation of RMO with her name and contact information.
But all of a sudden… Jane gets a job offer! When the next city secretary is hired, the city council must amend the ordinance to designate a new RMO:
John Smith shall serve as Records Management Officer for the City of Townville.
John sends TSLAC the updated ordinance, minutes from the council meeting, and form SLR 504 with his name and contact information.
As you can see, designating the RMO by name means that the city needs to repeat the steps of designating the RMO through governing body action when the RMO is replaced.
Townville ISD: Designation by Position
Down the road, Townville ISD’s school board has approved a policy that designates a position instead of a name:
The Superintendent shall serve as Records Management Officer for Townville ISD.
Mary, the current superintendent, sends TSLAC the approved policy, minutes from the board meeting, form SLR 508, and form SLR 504 with her name and contact information.
Some years later, Mary retires. The new superintendent, Bill, sees the approved policy and files form SLR 504 with his name and contact information. Since the designation of “superintendent” is still accurate, no action is required from the school board.
In this scenario, the ISD does not need to use an action of their governing body to update their RMO designation.
Note: The Declaration of Compliance (SLR 508)
The Declaration of Compliance (form SLR 508) generally does not need to be resubmitted for each new RMO. Contact your analyst or check out our article on the 12 local schedules for more information.
Why does this matter?
Both situations comply with the Local Government Records Act, but Townville ISD has fewer steps to follow when a new RMO is hired.
If you are managing compliance for a local government other than an elected official:
- Do you have a designation of RMO on file?
- Do you know if it designates a name or position?
For questions on your compliance file, contact the analyst assigned to your county.
For both elected and non-elected compliance requirements, check out our article on local government compliance.
