As a state agency, all records created or received by UMPO employees in the performance of their duties are presumed to be Public Records unless specifically exempt under that law. This applies regardless of the format—whether paper or electronic.
The Impact of Virtual Meeting Tools
Zoom meetings can generate various artifacts that, when related to University business, are presumed to be Public Records. The content of the communication determines its status, not the software used. The following examples of Zoom artifacts are considered public records if they document official University business:
- Meeting Recordings (Video and Audio): Recordings of meetings, lectures, or discussions regarding official UMass policy, decisions, or operations.
- Transcripts: Automatically generated text of the meeting conversation.
- Chat Logs: All text exchanged in the Zoom chat function during a meeting.
- Poll Results/Q&A Reports: Data collected during the session used for official purposes.
Your Records Management Responsibility
The key challenge is that third-party platforms like Zoom do not automatically retain records in a manner compliant with the University’s records retention policies. It is the responsibility of employees (both host and attendees) to ensure their own compliance:
- Determine Record Status: Review the artifacts immediately after the meeting. If the content documents an official decision, policy formulation, administrative action, or any substantive University business, it must be treated as a public record and retained in accordance with the proper retention period.
- Capture and Transfer: Do not rely solely on Zoom’s cloud storage. Compliant records must be securely transferred from Zoom and managed within an official University record-keeping system (e.g., Dropbox, authorized institutional repositories) where their retention and disposition can be properly controlled.
Best Practice Recommendations
To minimize public records risk and ensure compliance:
- Be Strategic with Recording: Only record a meeting if a permanent record is truly required (e.g., mandatory training or for accessibility).
- Manage Chat Usage: Remind participants that side conversations in the chat discussing University business are official records subject to retention and public disclosure.
- Regular Review: Periodically review and delete non-record material according to University policy and the applicable retention schedule.
We urge everyone to familiarize themselves with the scope of the Public Records Law and the University's records retention policies: Records Management Retention Disposition & Guidelines.
Thank you for your cooperation.