UW System Administrative Policy 650

Public Records Management Roles and Responsibilities

Original Issuance Date: July 22, 2026
Last Revised Date: July 22, 2026
Effective Date: September 1, 2027

1. Policy Purpose

To facilitate the transaction of business, ensure public accountability, and preserve the history of University of Wisconsin System (UW System) institutions, Wis. Stat § 15.04(1)(i) requires that agencies establish and maintain a records management program. Regent Policy Document (RPD) 3-2, Public Records Management defines the characteristics of the UW System records management program and states that it is the responsibility of all UW System employees to manage public records in compliance with state and federal legal requirements. This policy outlines the roles and responsibilities for the proper management, disposition, and preservation of UW System records to comply with these requirements.

2. Responsible UW System Officer

University of Wisconsin System Chief Compliance Officer

3. Scope and Institutional Responsibilities

This policy is specific to requirements under Wisconsin Statutes Chapter 16 regarding records management. This policy does not apply to requirements under Wisconsin Statutes Chapter 19 regarding responding to public records requests. This policy applies to all UW System institutions and to all public records created, received, or maintained in the course of UW System business, regardless of the office of record, location, or format of the records. This includes:

  1. All UW System units (campuses, departments, divisions, offices, etc.).
  2. All UW System employees and agents, including appointees, faculty, academic and university staff, temporary employees, student employees, and volunteers.

UW System institutions must develop their own procedures to operationalize this System policy. UW System institutions may also develop guidance to support the System policy and campus procedure.

4. Background

UW System is committed to responsible stewardship of UW System resources which extends to the public records created, received, and maintained in the course of UW System business. To maintain accountability and to preserve the trust the public and students place in UW System, records must be maintained legally as evidence of our work, decisions, and behavior. Like all state agencies, UW System must adhere to Wis. Stat. § 16.61, which ultimately governs the length of time public records must be kept and how these records must be disposed of or transferred to university archives. Unauthorized disclosure, alteration, or destruction of records constitutes a serious breach of public trust and risks legal and reputational harm to UW System.

5. Definitions

Disposition: Disposition is the action carried out upon completion of a record’s retention period. Disposition methods may include destroy, destroy confidentially, and transfer to archives.

Office of Record: The administrative unit that is designated for maintenance, preservation, and disposition of the “official” public record. All units are the “office of record” for at least some records. This will typically be the records created by the unit, or where the unit is the primary recipient of externally received records. Since many copies of a single record may exist, particularly in a digital environment, identifying the office of record is critical to avoid duplication of records management activities.

Public Records: Public records as defined by Wis. Stat § 16.61(2)(b), are “all books, papers, maps, photographs, films, recordings, optical discs, electronically formatted documents, or other documentary materials, regardless of physical form or characteristics, made or received by [UW System employees] in connection with the transaction of public business.”

Records Officer: A UW System staff member designated under Wis. Stat § 15.04(j) as being responsible for institutional compliance with all records management laws and rules. The records officer acts as the liaison between the UW institution and the Wisconsin Public Records Board. Per RPD 3-2, Public Records Management, each UW institution must have a designated records officer.  

Records Retention Schedules: Policies that describe specific types of public records, mandate how long they must be retained, and describe how they are to be disposed of at the end of their retention period. As defined by Wis. Stat § 16.61(2)(cm), records retention schedules are “instructions as to the length of time, the location…and the disposition requirements at the end of their retention period.” Records retention schedules are also commonly referred to as records schedules and records disposition authorizations (RDAs).

Unit: A group of employees under a supervisor with a common business purpose. Examples may include a division, department, office, school, program, etc.

Unit Records Management Plan: A plan that identifies the types of public records created and managed by the unit, how those types of records are organized, and the records retention schedules associated with those records. These plans ensure records are properly managed throughout employee, unit, and technological transitions.

University Archives: The university unit that collects and provides access to historically significant institutional records for research and discovery. Each university has a designated university archives.

6. Policy Statement

A. UW System Public Records Ownership

As required by Wis. Stat § 16.61(4)(a) and RPD 3-2, Public Records Management, all public records created or maintained by the UW System are the property of the UW System and the State of Wisconsin. Records must be managed appropriately as business assets throughout their lifecycle and may not be destroyed unless allowed by an approved records retention schedule. Employees may need to use multiple records retention schedules for the records they create and manage.

B. Designation of Units

Units will be designated as follows:

  1. UW System Administration vice presidents or equivalents will designate units for the areas under their purview. Units are subject to review by the system president.
  2. Vice chancellors or equivalents of each university will designate units for the areas under their purview. Units are subject to review by the university chancellor.

C. Records Officer Responsibilities

Each UW institution has a statutorily designated records officer as required by Wis. Stat § 15.04 (1)(j). Records officers are responsible for:

  1. Developing, updating, and maintaining UW institution records retention schedules, and ensuring that each type of public record created by UW System institutions has an approved records retention schedule.
  2. Developing records management guidance, training, and policy.
  3. Supporting employees with records management activities.

D. Unit Supervisor Responsibilities

Unit supervisors are responsible for:

  1. The creation and maintenance of a unit records management plan that:
    1. Identifies the types of public records created and managed by their staff and the records retention schedules associated with those records.
    2. Identifies how those types of records are organized and ensures that all pertinent records are stored in a manner accessible by the unit instead of on personal drives, devices, or accounts.
  2. Ensuring any public record created by the unit has a corresponding records retention schedule, and if not notifying the records officer to create a new records retention schedule.
  3. Completing an annual records management review to ensure that the unit records management plan is up to date, and that staff are managing and disposing of records appropriately.
  4. Ensuring records of departing employees are properly managed.

E. Employee Responsibilities

Employee responsibilities include:

  1. Using their unit records management plan to:
    1. Be aware of the records retention schedules that apply to the public records they create and manage.
    2. Organize and store the public records they manage according to the unit records management plan.
    3. Dispose of records or transfer records to the archives according to the records retention schedule regardless of format.
  2. Directing any records management questions to the unit supervisor or records officer.

F. Storage and Security of Public Records

  1. Public records, whether physical or electronic, must be stored throughout the record’s lifecycle in a way that protects the records from unauthorized access, manipulation, modification, and physical loss, whether by theft, mishandling, or accident. (See UW System Administrative Policy (SYS) 1031, Information Security: Data Classification, for more information.)
  2. Paper and other physical public records must be maintained in a manner appropriate for the record type, in areas where environmental conditions do not present a threat to the materials, and where they can be readily identified and retrieved.
  3. Information technology systems that generate, collect, store or maintain public records must meet or exceed the requirements stipulated in Admin. Code Ch. Adm 12 regardless of the system manager, owner, or location.
  4. Units may rely on third-party facilities or services to store and secure records during the records’ lifecycle consistent with UW System procurement and data security rules. Use of a third- party service does not relieve a unit of records management requirements, records production under Stat. § 19.35 or other legal obligations, and disposition responsibilities.

G. Preservation of Historical Public Records

Some UW System public records may have long term administrative or historical value.

  1. Public records identified as permanent in records retention schedules are managed in perpetuity by the office of record. Staff must make certain that these records are never destroyed and, with respect to electronic records, remain accessible as stipulated in Admin. Code Ch. Adm 12.
  2. Public records designated in records retention schedules as transfer to archives should be transferred in a timely manner by the unit at the end of their retention period after consulting with the university archives.

H. Training

Records management training will be available to all employees.

I. Audits and Other Records Holds

Per state law, records that are currently part of active public records requests, litigation, legal holds, or audits may not be destroyed even if they have completed their retention period. The UW System Administration Office of General Counsel, legal office at UW-Madison or UW-Milwaukee, or other designated university officials will inform employees of the hold and that such records must be retained until the hold is lifted.

J. Compliance

Compliance with this policy and proper records management, as outlined in Wisconsin Statutes Chapter 16, is subject to review and/or audit.

7. Related Documents

Regent Policy Document 3-2, Public Records Management
Wis. Stat. § 15.04, Heads of departments and independent agencies; powers and duties
Wis. Stat. § 16.61, Records of state offices and other public records
Wis. Stat. § 19.33, Legal Custodians
Wis. Admin. Code § Adm 12, Electronic Records Management- Standards and Requirements
Wis. Admin. Code § Adm 12 Guidance
UW System Administrative Policy 1031, Information Security: Data Classification
University Records Management

8. Policy History

First approved: July 22, 2026

9. Scheduled Review

September 2031