Records Retention and Redacting/Removing Sensitive Data
Redacting Retained Records
An explanation of the University's position on redacting or removing information from records that are retained as part of the USG records retention policy.
What are Retained Records?
For the purpose on this document, "Retained Records" refers to any document or record that is being maintained at UGA in accordance with University System of Georgia Record Retention Guidelines and Schedules. These may include administrative records, auxiliary services records, student records, human resources records, etc.
What does "Redacting" mean?
Redacting is the act of editing out portions of a document to render those portions unreadable. This might include removing information of record, masking information in a document, striking through or marking out portions of a document, etc.
This is usually done to prepare a document for public consumption by removing elements of the document that are either considered confidential or otherwise protected from public disclosure.
What is the University's Position on Redacting / Removing Information in Archived Records?
The general position the University has taken is that redacting or removing information from a retained record may be permissible assuming it is not done fraudulently and that the act does not alter or obscure the meaning of the record.
In particular, risks incurred by redacting sensitive identity information, e.g. Social Security Numbers, from retained records are far outweighed by the risks of archiving individuals' Social Security Number information.
In other words, it is advisable to remove or redact Social Security Numbers or other sensitive identity information from retained or archived records for the purposes of identity protection unless that information is absolutely required.
How do I find out more about records retention at UGA?
Records retention guidance is somewhat complex as requirements come from various sources such as accrediting bodies, Georgia Records Act, and other state and federal laws--just to name a few. Naturally, there may be caveats for certain record types to which the general position might not apply.
If there are specific questions about redacting a specific retained record, they should be directed to an appropriate contact in the UGA Office of Legal Affairs.
How do I find out more about identity protection at UGA?
For more information on data classification, sensitivity, protections, etc. please direct your questions to the Office of Information Security.