DUA violated Section 8 of Chapter 66 of the General Laws, which is part of the state’s Public Records Law, and the Massachusetts Statewide Records Retention Schedule because DUA only retained call log data for 13 months instead of the required three years.
By not retaining call log data for the required time, DUA limits its ability to review and evaluate its call-handling performance, identify trends, and take corrective action to improve its service. This also adversely impacted our audit by preventing a complete and accurate review of the intended audit period, and ultimately, of DUA’s performance over time.
Authoritative Guidance
According to Section M02-08 of the Massachusetts Statewide Records Retention Schedule, DUA must retain UI claims for three years, including documents such as claims for unemployment with the state, payment information, and related correspondence.
Additionally, according to Section 8 of Chapter 66 of the General Laws,
Every original paper belonging to the files of the commonwealth . . . and every other paper belonging to such files shall be kept for seven years after the latest original entry therein or thereon, unless otherwise provided by law or unless such records are included in disposal schedules approved by the records conservation board for state records . . . and no such paper shall be destroyed without the written approval of the supervisor of records.
Reasons for Issue
DUA officials stated that they retain call log data for 13 months, which complies with the standards outlined in Sections F04-03 and F04-03(b) of the Massachusetts Statewide Records Retention Schedule, which state,
F04-03: Audio-Visual Tape or Digital Recordings . . .
Consists of agency program data captured as sound or moving images. Includes intake or dispatch telephone call recordings, digital messaging system messages, security video tapes, hearing testimony tapes, investigators audio and video tapes, special projects videos, meeting minutes and proceedings recordings, or other digital renderings.
F04-03 (b): Dispatch, digital messaging, program intake tapes.
Retain 1 year.
Additionally, DUA stated that customer service call recordings—regardless of whether they reference specific claims or are made by currently unemployment claimants—are more comparable to the types of telephone call recordings mentioned in the retention schedule than to documents associated with specific claims. Further, DUA feels it is unreasonable to require indexing and associating these calls with particular claims. Therefore, DUA asserts that the provision applied to electronic and physical UI claim files (which includes all claims, payment information, and related correspondence) does not apply to the vast number of calls received on the customer service lines daily.
We disagree with DUA’s interpretation of the Massachusetts Statewide Records Retention Schedule as it applies specifically to digital recordings, rather than documentation related to a claimant’s telephone activity, including information such as the queue time, queue callback wait time, and interactive voice response time to determine the length of time it takes for a claimant to receive assistance. We believe that this information falls under Section M02-08 of the Massachusetts Statewide Records Retention Schedule, which requires records to be retained for three years.
Recommendation
DUA should ensure that all call log data is retained for three years, in accordance with Section M02-08 of the Massachusetts Statewide Records Retention Schedule.
Auditee’s Response
DUA disagrees with the Audit’s interpretation of records retention requirements. DUA maintains that a 3-year retention period is not required for customer service call data received by DUA. During the one-year audit period, DUA handled 735,750 incoming calls from constituents. These calls cover a wide variety of requests to the agency and are by-definition Audio-Visual Tape or Digital Recordings, often relating to program intake. These calls, as a group, are much more akin to the type of telephone call recordings referenced in Section 04-03 of the [Massachusetts] Statewide Record Retention Schedule and, therefore, subject only to a one-year retention period. DUA retains these records for thirteen months, which is longer than the Retention Schedule requires.
Auditor’s Reply
We agree with DUA that its customer service call recordings are audiovisual tape or digital recordings under Section 04-03 of the Massachusetts Statewide Records Retention Schedule and subject to a one-year retention period. However, the records we requested, and that are at issue in this finding, are not DUA’s customer service call recordings themselves, but rather the call log data associated with those customer service call recordings, including but not limited to, the date and time of the call, queue time, talk time, the time to reach a call center agent, conference or consultation time (if any), whether the claim was placed on hold and for how long, the DUA skill category, the call center agent’s name, identifying case or file numbers, and the final outcome of the call. Such call log data, which is distinct from call recordings, is subject to a three-year retention period under Section M02-08: Unemployment Insurance Claims of the Massachusetts Statewide Records Retention Schedule as records that “document claims for unemployment with the state, [including] claims, payment information, and related correspondence.”
Beyond compliance with the Massachusetts Statewide Records Retention Schedule and the Massachusetts Public Records Law, there is value to retaining these records in order to analyze trends over time, identify areas of improvement, maintain and facilitate institutional knowledge, and ultimately better serve claimants.
| Date published: | September 21, 2026 |
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