Service Alberta, Records Management Services can be contacted for advice, and they can consult with ministries on specific situations.

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1 (ARMC) ARMC Circular: Background (This Circular rescinds Circular ) The Records Management Regulation s.10(4) stipulates Records may be disposed of only in accordance with the approved records retention and disposition schedule.. This may not be possible with contaminated or damaged records as the records may be unscheduled or have not met the requirements of the approved Records Schedule. The purpose of this circular is to provide direction to records management staff and Senior Records Officers in the event of an incident where records have been contaminated or damaged. With potentially contaminated records, worker safety is the most important consideration. Staff should use appropriate safety gear and follow procedures when handling contaminated boxes or records. For information on worker safety, please contact your ministry Health and Wellness Advisor. Service Alberta, Records Management Services can be contacted for advice, and they can consult with ministries on specific situations. Records Schedules for Contaminated Unsalvageable or Damaged Records Two cross-government Records Schedules are available for ministries to use in the event of an incident for the destruction of contaminated unsalvageable or damaged records: Schedule 2011/002-A001 Unsalvageable Damaged Records can be used to dispose of records determined to be a health risk to humans and unsalvageable. There are two items available: o Item #1 - records contaminated with substances that could pose a health risk to humans; and - ARMC approval is not required to use Item #1 for contaminated unsalvageable records. Ministries must document the incident and records, and send a copy to the ARMC Secretariat. o Item #2 - records that are not contaminated with harmful substances but the information contained in the records has been obliterated, rendering the records unusable. - ARMC approval is required to use Item #2 to dispose of unsalvageable records that are not contaminated. Ministries must document the incident and affected records, and send this information along with a request to use this item for the disposal of the documented records to the ARMC Secretariat.

2 Schedule 2012/005 Salvageable Damaged Records can be used for scheduled records deemed salvageable that are of little business value and where the cost is prohibitive to restore. ARMC approval must be obtained before the ministry can use this schedule. Ministries must also ensure the damaged records are scheduled, have a low business value and the final disposition of the damaged records is destroy. Resolving a Records Incident While an incident involving records may be unique, the recovery actions are similar and the steps taken to recover records may vary depending on the severity of the situation. It is important that the records not be touched or removed from the contaminated site until contaminates have been identified and the situation has been assessed. The less the records are handled, the less chance of further damage occurring to the records. There may also be health issues with the contamination. New records should not be added to the contaminated records. outlines the actions to resolve a records situation. Depending on the situation, not all action steps may need to be taken. Appendix 2 provides a decision tree to assist in dealing with damaged records. There are a number of resources that can be used to assist in assessing and resolving the situation. Service Alberta, Records Management Services (RMS) Depending on the type of damage and/or contamination, records may be salvageable. Service Alberta (SA) can help to assess the situation and provide guidance as to the actions that should be taken. They also have access to external vendors who are experienced in the assessment and recovery process. Additional information is available through the Service Catalogue. Contact: SA, RMS at (780) Provincial Archives of Alberta (PAA) has two conservators that can help with textual and audio-visual (AV) materials. They can assist in the evaluation of contaminated records and provide support for the conservation of paper (including blueprints, plans, etc.), photographs, moving images, and audio and digital records by identifying appropriate equipment and processes for restoring contaminated records. Contact: PAA Conservators at (780) Risk Management will assess the situation from an insurance and safety perspective. If the cost to deal with the damaged records situation is greater than $5,000, you must contact Risk Management. Under the Risk Management Program, some costs related to the recovery and restoration of damaged records may be reimbursed such costs of freezing, drying or cleaning of records. Costs to re-gather lost information are not included. Contact: Ministry contacts are listed on the website at: Page 2

3 Ministry Business Continuity Officer. All incidents should be reported to the Ministry Business Continuity Officer. This information will be gathered by the Alberta Emergency Management Agency. If the incident involves several ministries and a significant amount of records, they can assistance in resolving issues related to resources. Contact: Check your Ministry s internal web site for your Business Continuity Officer. Conclusion For clarification, further details or assistance on the contents of this circular, please contact the ARMC secretary at sa.informationmanagement@gov.ab.ca or (780) Signed by: Cathryn Landreth September 25, 2013 Chair Date Page 3

4 The steps below outline the actions that should be taken when an incident has occurred that resulted in contaminated or damaged records. Remember: Do not remove the records from the contaminated site until you have a plan in place. Also, do not add any new records. Assess the Situation 1. Determine what type of contamination is affecting the records. If it is water damage, is it clean water, sewer water, dirty river water? Is the contamination related to mould, infestation by insects or rodents, asbestos, etc? NOTE: All contaminates must be identified and documented on the containers that will be used to transport the material. 2. Determine the urgency of resolving the contamination to the records. Is time a factor? With infestations by insects or rodents, time is not a factor. The records can stay untouched until a complete resolution can be implemented. With water damage, mould will start to grow within hours of being wet. Time is a factor and you need to resolve the water contaminated records quickly before they also become further contaminated with mould. 3. Determine if any action can be taken to stop the contamination, i.e. turn the tap off, plug holes so that rodents cannot access your storage area, etc. Notify the Appropriate Individuals 4. Notify the appropriate property management body and inquire if they have a process in place for site decontamination. If other government departments are sharing the same storage space as you, inform the property management firm to contact the other affected departments. 5. Determine the level of danger to staff. Contact your local Joint Worksite Health and Safety Committee member, or the appropriate body for the location, to help determine appropriate safety measures. Damaged records from clean water 1 or mould can be restored. Notify the Ministry Senior Records Officer (SRO) of the damage that has occurred to the records. The current list of SROs can be found at: 6. Contact Service Alberta RMS for assistance with the incident at (780) Depending on the type of damage and/or contamination, records may be salvageable. RMS can help assess the situation and provide guidance as to the actions that should be taken. They also have access to resources that can help in the assessment and recovery process. 1 Clean water is water that has not been contaminated with dirt, sewage or other chemicals. Page 1

5 7. Contact Risk Management to assess the situation from an insurance and safety perspective. Ministry contacts are listed on the web site at: Under the Risk Management Program, some costs related to the recovery of records may be reimbursed. These costs include the restoration of damaged records such as freezing, drying or cleaning of records. Reconstruction costs do not include re-gathering lost information. If the cost of the incident is greater than $5,000, Risk Management must be contacted. Assess the Damaged Records 8. Identify which records are affected. Are they all contaminated, or a few files in several boxes? Separate boxes if possible, and store the non-contaminated ones in a secure site free from further contamination. 9. Obtain the inventory of the damaged records. If no inventory exists, DO NOT attempt to inventory them now. 10. If there is no inventory, work with the ministry and business area staff to capture any information they may have about the records: - What program(s) do the records support? - What types of records are affected - are they administrative or program records; policy and research, or transactions and cases, etc? - Do the records constitute a Personal Information Bank (PIB), or contain significant amounts of personal information? How sensitive is the information? 11. Gather information on the current status of the records: - Which schedule(s) and items would likely be used for their disposition? If the records are not scheduled, try to estimate their legal, financial, and business value for retention. - Are these records required as evidence in a litigation case or is there an outstanding FOIP request? - Are copies of these records available elsewhere? 12. Evaluate the gathered information on the damaged records to determine the value of the records to the organization. Restoration costs should be identified if possible. 13. Complete a risk assessment. Damaged records with little or no business value should be further evaluated to determine if the cost to restore the records is justified. Damaged records that have an approved Records Schedule with a final disposition of destroy may, after approval from ARMC is given, be destroyed using the Salvageable Damaged Records Schedule (Schedule # 2012/005). Page 2

6 If the damaged records, according to the approved Records Schedule that they fall under, have completed their retention period and the final disposition is destroy, those damage records can be disposed of according to that approved Records Schedule. 14. Determine if the information on the damaged records has been obliterated to the point that it cannot be retrieved (physical paper is fine but the ink used to record the information has been washed off). These records may, after ARMC approval is given, be destroyed using Unsalvageable Damaged Records Schedule (Schedule # 2011/002-A001, item # 2). 15. Determine whether the contaminated records can be cleaned or copied using appropriate methods. It may be determined that records are too badly contaminated to risk any handling. For example, if the records are considered to be a risk to human health, they may be unsalvageable. Contact the PAA Conservators for assistance with this evaluation (phone number: (780) ). Records too severely damaged or contaminated will not be accepted into the PAA for long-term preservation. The PAA Conservators can also help with guidance on the appropriate equipment and processes that can be used to restore records. 16. Recommend an appropriate action of restoration or destruction of the contaminated records. The contamination danger to staff should also be factored into the decision. Contact the appropriate health authority. 17. Obtain ministry approval to implement recommended action: Restore or Destroy. 18. Report the incident to the Ministry Business Continuity Officer. Provide details on the incident such as brief description, location, current status, the severity of the incident, causes, specific services being disrupted by the incident, resumption activities and length of disruption. 19. Obtain materials to start the rehabilitation process such as boxes, plastic bags, wax paper, contamination tape, etc. that can be used when boxing the damaged records for transportation. (Restoration vendors can supply). 20. Arrange for another temporary storage location for any new records. Do not add new records to the contaminated environment. Implement Recommended Action: Restoration 21. Take appropriate action to have the records cleaned, copied or preserved as identified in Steps Ensure that the privacy of individuals is maintained. 22. Determine what to do with the damaged original records that were copied by photocopying or imaging. 23. Record the circumstances of the restoration and retain this information with the records inventory. Page 3

7 Implement Recommended Action: Destruction 24. Destruction may be the appropriate action if the records are determined by the ministry to be unsalvageable, where unsalvageable refers to records that are a risk to human health and the risk cannot be reasonably mitigated; or if the records are determined to be salvageable but have little or no business value. 25. If destruction is the appropriate action for damaged records with low business value as determined in Step 13, the ministry must obtain ARMC approval to use the Salvageable Damaged Records Schedule (Schedule #2012/005) prior to implementation of the schedule. The Ministry must forward in writing to the Secretary of the ARMC, the following information: - Risk assessment steps taken and results; - Information on the damaged records including inventories or best descriptions of the records as captured in Step 10 and 11; - Schedule and Item numbers the records were originally scheduled under; and - Number of boxes damaged and description of damage. Once ARMC approval is obtained, proceed to step If destruction is the appropriate action for contaminated damaged records, the ministry can use the Unsalvageable Damaged Records Schedule (Schedule # 2011/002-A001, item #1) to destroy these records. ARMC approval is not required to use this item. Once the destruction has been completed, the ministry must also forward, in writing to the Secretary of the ARMC, detailed information on the destruction including: - Number of boxes contaminated and type of contamination; - Assessment from the health authority - a quick memo or is fine; - Inventory or best description of the records as captured in Step 10 and 11; Please note: all personal information should be severed. - Records status information gathered in Step 12; - Information from the archivist or conservator; and - Preventative measures being taken to prevent similar situations from happening again in the future. These measures can be documented after the fact especially if time is of the essence. Preventative measures should include: Alternate storage arrangements for records, so that business unit(s) do not continue to add records to risky sites; Cleanup and protection of the storage site if it will continue to be used; Action plan to identify and assess other storage areas at risk; and Measures to mitigate risks and develop ongoing storage solutions. Page 4

8 27. If destruction is the appropriate action for uncontaminated and unsalvageable damaged records where the information has been rendered unreadable, the ministry may be able to use the Unsalvageable Damaged Records Schedule (Schedule # 2011/002-A001, item #2) to destroy these records. ARMC approval is required to use this item. The ministry must request approval in writing to the Secretary of the ARMC and provide detailed information including: - Number of boxes damaged and type of damage; - Inventory or best description of the records as captured in Step 10 and 11; and Please note: all personal information should be severed. - Records status information gathered in Step 12. Once ARMC approval is obtained, proceed to the next step. 28. Destruction can be coordinated by Service Alberta RMS. For assistance with the destruction process call (780) It is important that proper labeling on the exterior of each container be done. The type of contaminate should be documented on the labels for the safety of anyone handling the material. Also, if the records are to be destroyed by recycling, the vendor needs to know the type of contaminate. 29. Document the circumstances of the destruction including transportation of the records, how the records were destroyed, who destroyed them, and date they were destroyed. 30. Retain the information gathered in Steps and for the damaged records as a Destruction Certificate. Future Contamination Prevention 31. Review the source of the contamination with your Business Continuity Officer and Risk Management Analyst. Identify measures that can be taken to ensure this damage does not happen again. 32. Review preventative steps that could be taken to ensure that any future damage can be minimized i.e. for floods, records are not placed on the floor; they are placed on shelving units that are 3 inches off the ground, for infestations by insects or rodents, records will not be stored in granaries or barns; appropriated storage units will be used. Page 5