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.
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.
- 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. [↩]
- Note that the Illinois Records Act applies to more than merely Illinois universities. [↩]
- See UIUC Records Disposal [↩]
