Disposition of Information

Adoption
Date : 1989-10-11
Approving Body : University Secretary-General

Modifications:

2022-03-17
2021-09-23
2007-08-22


Responsible Service : University Archives

  1. Purpose
    1. This procedure supports Policy 23-Information Management and its purpose is to ensure consistent methods for the retention and final disposition of University information assets, in accordance with the University Classification and Retention Schedule.
  2. Interpretation
    1. This procedure provides guidance to University of Ottawa employees, faculty, staff, and heads of units with the responsibility of the management of information, in accordance with the University Classification and Retention Schedule and provides instructions for preparing information assets for final disposition.
    2. Authority to establish this procedure is derived from Policy 23- Information Management which delegates authority to the Senior Director, Information and Archives Management to establish and maintain a retention and disposition schedule for all information assets, based on legal, regulatory, fiscal, operational, archival, evidential and historical requirements.
  3. Scope
    1. This procedure applies to all information assets, regardless of medium or format, that are in the custody and control of the University.
    2. This procedure does not apply to transitory information, which may be securely destroyed as soon as it is no longer useful.
  4. Terms and Definitions
    1. For the purpose of this procedure the following definitions apply:

      “information asset” is information that is generated or managed by the University and has value to the University.

      “disposition” is the action taken on University information assets by the Office of Primary Interest, when the retention period has been reached. There are three possible disposition actions documented in the University Classification and Retention Schedule:

      “destroy”: all information in the class code are destroyed or erased in an irreversible manner which ensures that the information cannot be recovered or reconstructed, by methods outlined in section 7 of this procedure.

      “send to archives”: all information in the class code are transferred to the archives and become part of the University archives for permanent preservation and access.

      “archival selection”: some of the information assets in the class code are eligible for addition to the University archives. The final selection of these will be made by the Information and Archives Management archivist.

      “University Classification and Retention Schedule” is a University tool to manage information assets created or received by the University.  The systematic application of managing information through a classification structure allows for the control of information assets throughout its lifecycle – from creation through to disposition.  The classification and retention schedule provides authority for the management of information regardless of whether they are in paper, digital, image, audio, or video format. 

      “primary heading class” is a group of high level functions of the University to fulfill its goals and accomplish its functions and transactions.

      “class code” is a numerical code to identify the information class

      “secondary heading”  is a major action, or task, undertaken to complete a given function.

      “office of primary interest” is the University unit or units who are considered to have the authority, responsibility and accountability for managing, maintaining, and disposing of the most complete version of information assets in a class code.

      “retention trigger” describes when to begin the retention period

      “retention period” is the length of time that information assets must be kept by the Office of Primary Interest.

      “transitory information” is information of temporary usefulness in any format or medium having no ongoing value beyond an immediate and minor transaction or the preparation of a subsequent information asset. Transitory information can be securely destroyed when no longer needed.

  5. Responsibility
    1. Responsibilities of University employees, faculty, staff, and heads of units:
      1. apply this procedure to the information assets in their custody and control,
      2. securely destroy transitory information once it is no longer useful,
      3. complete the Information Destruction Authorization Formfor all information assets who have reached the end of their retention period and are being securely destroyed by their unit,
      4. respond to and approve, in a timely manner, all Information Destruction Authorization Formssent to highest-level directors or managers,
      5. prepare information assets for their final disposition,
    2. Responsibilities of the Senior Director, Information Management:
      1. monitor the retention periods for information assets that have been stored with their service and request Information Destruction Authorizationfrom the most senior director of the unit, when applicable,
      2. ensure the secure preservation and access of information assets that are determined to have enduring value, according to the University Classification and Retention Schedule,( and in accordance with the Archives Management Policy-coming soon)
      3. establish, monitor and maintain best-practices, and tools, as well as, provide advice, awareness and training sessions to employees, faculty, staff, and heads of units to support the application of this procedure, specifically, the University Classification and Retention Schedule.
  6. Procedure
    1. Approval from the highest-level director or manager of the Office of Primary Interest is required to dispose of information assets created by their department or unit. Approval should be based on the current, approved Classification and Retention Schedule.
    2. Units must not destroy any information pertaining to an ongoing or reasonably anticipated investigation, legal action or proceeding, Freedom of Information (FIPPA) request, audit or program review, even if the retention period or disposition date specified has already expired.
    3. Information assets must be retained for the full duration of their retention period, as defined by the Classification and Retention Schedule. Once the retention period has been reached, the information asset is eligible for secure destruction or transfer to the archives.
    4. The retention period begins only after the Retention Trigger defined in the Classification and Retention Schedule has occurred.
    5. Steps for disposition of information

      To determine the disposition of information assets in your custody and control follow these steps:

      StepActionYesNo
      1-Consult the classification and retention scheduleConsult the Classification and Retention Schedule for the retention and disposition of information that applies to your information assets. If you have questions contact the IAMS.
      2 Determine Primary HeadingIs there a “Primary Heading” that applies to the information assets in question?See step 3Contact the IAMS. We will help you determine where your information fits, or adjust the Classification and Retention Schedule, if needed.
      3-Determine secondary headingIs there a “Secondary Heading” that applies to the information assets in question?See step 4Contact the IAMS. We will help you determine where your information fits, or adjust the Classification and Retention Schedule, if needed.
      4-Identify the Office of Primary ResponsibilityIs your unit the “Office of Primary Interest (OPI)” for the information determined in step 3?See step 5You are not the OPI and your office is not responsible for managing the most complete version. The OPI for the heading is responsible for managing the most complete version. You can securely destroy your copies when no longer useful, according to methods in Section 7- Approved methods of destruction.
      5- Retention triggerHas the “retention trigger” occurred yet?See step 6The unit must continue to manage the information assets until the retention trigger has been reached.
      6- Determine the retention periodHas the “retention period” for the information assets in question been reached, or is the retention period “0”? As described in section 6.4: The retention period begins after the Retention Trigger defined in the Classification and Retention Schedule has occurred.See Step  7The unit must continue to manage the information assets until the retention period has been reached.
      7-Disposition actionIs the “disposition action” destroy?See step 8The action is “archival selection” or “send to archives”, meaning this information is to be sent to the archives. Contact the IAMS.
      8- Complete destruction authorization formHave you completed the Information Destruction Authorization Form, and received approval from the highest-level manager for the information assets in question?See step 9Receive authorization or contact the IAMS for guidance.
      9- Conduct destructionSecurely destroy of the information assets according to Section 7-Approved methods of destruction. Document the destruction in the appropriate section of the Information Destruction Authorization Form. Send completed form to IAMS.  
  7. Approved methods of destruction

    The medium and the nature of the information will influence the destruction method to be followed. There are five accepted methods of destruction:

    1. Secure deletion: Secure deletion of file, directory, and data - follow the methods recommended by Information Technology in Policy 117.
    2. Device cleanse: Cleansing of information storage devices before reuse or disposal (external server, laptop, tablet, cell and other IT assets) - follow the methods recommended by Information Technology in Policy 117.
    3. Secure shredding : Secure shredding in padlocked recycling bins for confidential paper documents and, if in small quantities, for photographs, negatives, slides, video, USB key, DVD, CD, diskette, microfiche, microfilm, etc. Use a padlocked bin dedicated to confidential documents that are not paper if you destroy a large quantity. (Contact Facilities to obtain padlocked bins)
    4. Recycling: Recycling of non-confidential paper documents in the regular recycle bins.
    5. Multi-media disposal: Disposal in trash can of non-confidential photographs, negatives, slide, video, and DVD.