As a state agency, any recorded information created, received, or used by the University of Washington is considered a record. Washington State defines a record as information regardless of physical form or characteristic. UW and its employees have the legal responsibility to demonstrate proper care and management of its records. Text messages are no different. APS 55.01 is the policy that governs the use of mobile device technologies at the UW and explains that employees who use mobile devices to conduct UW business are subject to all policies and laws applying to that activity, including records management requirements. This resource provides best practices for mobile device use and how to best manage the text message records you create or receive while using these devices.
Now you may be asking, which text messages are considered public records and need to be managed? How do we as UW employees know which texts are considered UW records and which texts that are not?
When Texts Are UW Records
UW Owned Device
If you are using a UW owned device to send/receive text messages, all those messages are UW records, regardless of the content or purpose of the message. Big UW decision? UW record. Personal text to a family member? UW record. All of these texts need to be managed in accordance with the UW retention schedule based on the content and function of the text.
Mobile Device Allowance
If the UW is paying a stipend or a mobile device service allowance (MSA) to cover costs associated with a service contract or other related service charges, the texts you create while conducting UW business are UW records and must be managed. The texts you receive that are part of UW business are also UW records. In contrast, texts unrelated to UW business on this mobile device are not UW records.
Personal Device
If you are using a personal device, not receiving any UW service allowance to use the device for work purposes, but you send/receive texts on the personally owned device about the work of the agency, those are considered UW records. If texts are related to the work of the University or are being sent/received in an employee’s official capacity, they are UW records. In contrast, texts unrelated to UW business or an employee’s assigned duties are not UW records.
FAQs re Personal Devices
- Does that mean the entire conversation thread of texts are UW records, if only 1 out of 100 are related to the work of the agency? No, just the pieces of the text thread that are business-related are considered UW records.
- If I have one text thread containing UW records, say with my supervisor that are work-related, but I have separate text threads with my family that are not work related, does that make every text thread on my device a UW record? No. Only the work-related texts are UW records.
- If I have a text thread containing UW records, does that make the entire contents of my personally-owned device a UW record and subject to potential disclosure? No. The work-related texts are UW records, and that does not inherently make your personal photos, social media apps, or any mobile-device content a UW record.
Best Practices
Now that you’ve determined which texts are UW records, how should you behave moving forward?
UW Owned Device
- Visit APS 47.02 for personal use of University facilities, computers and equipment. Be aware that even while occasional limited personal use may be allowed under certain circumstances, all the content you create, receive and use is considered a UW record in the same way that your UW-owned workstation computer is. As a result, avoid using your UW-owned device to send personal and non-related work texts. Keep personal information on personal devices.
- While all texts are considered UW records, it is difficult to manage text messages for long-term retention. As a result, you should attempt to keep texts transitory in nature so that you do not have to retain a text for 6+ years on that device. Consider using mobile Apps like UW Exchange (Outlook) email, UW Gmail, or Microsoft Teams Channels (avoid Teams Chat) to send/receive information where the data would be backed up in the cloud and accessible outside of your mobile device. If there is ever the need to export or provide a copy of your communications, it’s often easier to do so from a workstation than to do so from a mobile device.
- Avoid using emojis, gifs or ‘reactions’ to texts. This type of information can be misconstrued or cause ambiguity. Did a thumbs up mean you received the project proposal from your colleague? Or did it mean you approved their proposal?
Mobile Device Allowance
- The texts you create or receive while conducting UW business are UW records and must be managed.
- Attempt to separate UW related work content from personal (non-work) content. Consider using mobile Apps like UW Exchange (Outlook), UW Gmail, Microsoft Teams Channels (avoid Teams Chat), to send/receive information where the data would be backed up in the cloud and accessible outside of your mobile device. This keeps communications out of text formats all together, while still using your mobile device for certain business purposes.
- Keep text messages transitory in nature, so that you do not have to manage work texts with long retention periods on your device. Text messages are hard to manage and this adds complexity when needing to transfer content during an offboarding process or when responding to a Public Records Request, Litigation or Investigation.
Personal Device
- If you have a personally owned device, avoid using it to send work-related text messages. UW business should be not be conducted via text messages on personal devices.
- If you do use texts on occasion for work purposes, it’s best practice to ensure they are transitory in nature.
- If a communication for UW business that has business value and importance needs to be made while on-the-go, consider giving someone a call or send an email using your UW email account using your mobile device. Sending correspondence through your UW email (not any personal email accounts) will ensure that the email is captured on UW servers and will be easier to manage for a longer retention period.
- If you did use text messages to communicate UW business and it is deemed substantive (based on its content and function) and required to be retained for a long retention period, efforts should be made to covert and save the record in a more central UW location.
If using any mobile device to conduct UW business, be sure to follow UWIT best practices on keeping smartphones protected and secure: https://itconnect.uw.edu/guides-by-topic/security-authentication/devices/smartphone-configuration/
Contact our office with any questions.