Administrators of UWM HR related shadow and supplemental systems are reminded that the data contained within these systems are public records per Wisconsin’s Public Records Law, Wis. Stat. 16.61.
Wisconsin’s Statutes make it clear that administrators are responsible for proper management, retention, and disposition of these records, including ensuring the continued authenticity and accessibility of electronic records, and managing data security.
Additionally, these records may also be subject to Wis. Stat. 19.31-19.39 (Open Records Law), which allows residents of Wisconsin to request access to public records, and which requires public agencies to provide that access in a timely manner. Inability to provide access to public records may bring legal or financial penalties to the University.
“Shadow Systems” are non-UW System applications, which extract data from UWS common systems, but are not intended as the “official system of record.” As a result, these systems’ data are generally considered “convenience copies” for the purposes of open records requests; administrators may usually refer requestors to the main HRS system.
It is important to note that even if data in shadow systems are “out-of-synchronization” with the data in HRS, system administrators may still be responsible for producing accurate records and reports on the data as represented in their system. Additionally, confidentiality and data security requirements still apply to records contained within shadow systems.
It is recommended that shadow systems be made fully compatible with HRS as early as is reasonably possible, to mitigate potential security or records access issues that may arise.
A “Supplemental System” is a locally-supported application or process which is dependent upon a common system-of-record as a data-source, but which also performs additional “value-added” creation, augmentation or modification of that data, to add important context or decision-supporting information, beyond what is held in the common system.
Supplemental systems’ data are considered to be public records for the purposes of open records requests; administrators are responsible for management of, providing access to, and appropriate protection and disposition of records held within these systems.
These records may or may not already be associated with a “Records Retention and Disposition Authority (RRDA),” also known as “records schedules,” which provides retention guidance and legally sanctions the destruction or archiving of records at the end of their active life, as appropriate.
If no records schedule exists, system administrators should work with UWM Records Management to develop and approve an appropriate RRDA. The Wisconsin Public Records board approves new RRDAs 4 times per year. For a partial list of active UWM RRDAs, see:
What is a Records Schedule?
Records schedules, or Records Retention and Disposition Authorities (RRDAs), dictate to offices throughout the state of Wisconsin how long to keep their records (called the retention period) and what to do with those records once that time has passed (called the disposition instructions). UWM produces many records which are scheduled under general records schedules, which are RRDAs which cover record types produced by multiple offices.
Some units at UWM may also be covered by specific records schedules, which dictate retention and disposition of records for that office only. Under Wisconsin state law, records may not be destroyed unless they have been scheduled under an approved RRDA.
All records schedules sunset, or expire, after 10 years, at which point their associated records groups must be re-scheduled.