I don’t think of myself as being very orga­nized, my “pro­ce­dures” for liv­ing my life con­sist mostly of plac­ing my glasses and car keys and wal­let in more-or-less the same spot in hopes of being able to find at least two of the three in the morn­ing.¹

 

1. Felony penal­ties for a uni­ver­sity destroying/not keep­ing records.

On the other hand, Illi­nois pub­lic uni­ver­si­ties have exact­ing record-keeping duties.  That obvi­ously includes such minor things as the Illi­nois Records Act, which imposes a felony penalty on some­one who “alters, destroys, defaces, removes or con­ceals” a pub­lic record:²

 

2. Lots and lots of resources to help a lit­tle ‘ole uni­ver­sity learn itself what has to be kept.

Of course, you might won­der what con­sti­tutes a “record” … but not to worry, there are actual flow-charts to help answer this ques­tion, at least if you’re a UIUC employee (from UIUC_Records_FlowChart):

 

 

I should add that — if the above isn’t clear enough — there’s also an entire web­page from the UI system’s Chief Infor­ma­tion Offi­cer (“CIO”) that pro­vides still more detail about records, and record keep­ing, and how-tos and whys — see UI CIO.

 

3. UIUC actu­ally has a pro­ce­dure that man­dates procedures.

As a result of such triv­i­al­i­ties as the felony penalty laid out in the Illi­nois Records Act, UIUC has insti­tuted on the inter­net a set of pro­ce­dures for record-keeping, and a whole bunch of what appears to be require­ments that actu­ally should be fol­lowed by UIUC per­son­nel:³

 

 

So UIUC itself informs itself that it (itself) ought have those things called “poli­cies,” includ­ing specif­i­cally record retention/disposal poli­cies.  And those should be done for each and every unit of UIUC.

 

4. And yet the Chan­cel­lor of UIUC appar­ently is procedure-free.

So given the above, you’d have thought that the Chan­cel­lor of UIUC would be equally as bound as any­one else there to have delin­eated pro­ce­dures for record keep­ing and destruction.

Well, you’d be wrong.  So here’s a bit of a rul­ing by the Illi­nois Attor­ney General’s office (specif­i­cally the “Pub­lic Access Coun­selor” or “PAC”) on a FOIA filed by a samizdat-startups viewer and con­tributed to the site by that viewer:

 

 

Now maybe it’s unfair of me to con­clude from the above that Chan­cel­lor Wise has no pro­ce­dures at all — what the above seems to say is that there’s no record-keeping pro­ce­dure spe­cific to third-party records.

But this strikes me as ludi­crous — lawyerly issue-ducking.  When the Chan­cel­lor (or any­one else at UIUC) gets a third-party doc­u­ment (like the “two-pager” that the Chan­cel­lor “can’t find”), what is the pro­ce­dure for retain­ing or dis­card­ing it?

In other words, the doc­u­ment comes in the door or attached to an email — accord­ing to the law and UIUC pro­ce­dures that doc­u­ment is sup­posed to be reviewed for pos­si­ble compliance.

Is it?  UIUC doesn’t know, or won’t say.

I guess the next FOIA to them needs to ask some­thing like “what pro­ce­dure do you fol­low in pro­cess­ing a third-party doc­u­ment for pos­si­ble reten­tion as a “record” as defined in the Illi­nois Records Act and UIUC policies?”

Some­one inter­ested in ask­ing this ques­tion?  I intend to ask it, would be great if oth­ers join in.

 

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The mar­quee image is, of course, a Gus­tav Dore, I’ll be darned if I can find it in the “Mother Goose” at project Guten­berg, but it’s eas­ily avail­able if you do a search for Dore images.

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1. I try to do the same thing with my car when I go to a mall or gro­cery shop­ping, but some­thing about either my age or my car makes it a cer­tainty that, when I come out to find it, it’s absolutely not in the spot where I’m sure I left it. [↩]
2. Note that the Illi­nois Records Act applies to more than merely Illi­nois uni­ver­si­ties. [↩]
3. See UIUC Records Dis­posal [↩]