Records Management Policy

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  1. Purpose

The Provident Charter School Board of Trustees (“Board”) recognizes the importance of  establishing and maintaining a Records Management Policy that defines Provident Charter School  (the “School”) staff responsibilities and complies with federal and state laws and regulations. 

  1. Authority

The Board shall retain, as a permanent record of the School, the Board minutes, annual auditor’s  reports, and annual financial reports. All other financial records, including financial account books,  orders, bills, contracts, invoices, receipts, and purchase orders, shall be retained by the School for  a period of not less than six (6) years. 

All other School records shall be retained in accordance with state and federal law and regulations. 

The School shall make a good faith effort to comply with all proper requests for record production.  Selective destruction of records in anticipation of litigation is forbidden. 

  1. Definitions

Electronic Mail (E-mail) System – a system that enables users to compose, transmit, receive and  manage text and/or graphic electronic messages, and images across local area networks and  through gateways connecting other networks. This information consists primarily of messages, but  may include attachments such as calendars, directories, distribution lists, word processing  documents, spreadsheets, and other electronic documents. 

Litigation Hold – a communication ordering that all records and data relating to an issue being  addressed by current or potential litigation or investigation be preserved for possible production  during the litigation or investigation. 

Record – information, regardless of physical form or characteristics, that documents a transaction  or activity of the School and that is created, received, or retained pursuant to law or in connection  with a transaction, business, or activity of the School. The term includes a document, paper, letter,  map, book, tape, photograph, film or sound recording, information stored or maintained  electronically, and a data-processed or image-processed document. 

Records Management Plan – the system implemented by the School for the retention, retrieval, and  disposition of all records generated by School operations.

Records Retention and Disposition Schedule – a comprehensive listing stating retention periods  and proper disposition of records. 

  1. Delegation of Responsibility

Open Records Officer 

In order to maintain a Records Management Plan that complies with federal and state laws and  regulations and Board policy, the Board designates the CEO or his/her designee as the School’s  Open Records Officer who shall serve as the chairperson of the Records Management Committee.  The Open Records Officer shall be responsible to: 

  • Ensure that training appropriate to the user’s position and level of responsibility is provided  on the following: 

o operation, care, and handling of the equipment and software 

o requirements of the Records Retention Schedule 

o protocols for preserving and categorizing School records 

o procedures and responsibilities of School staff in the event of a litigation hold o identification of what is and what is not a record 

o disposal of records 

  • Review the Records Management Plan periodically to ensure that record descriptions and  retention periods are updated as necessary. 
  • Identify, when the retention period expires, the specific records to be disposed of, and  ensure that all identified records are properly disposed of annually. 

Records Management Committee 

A committee responsible for the development and recommendation of the School’s Records  Management Plan shall be established by the CEO. The Records Management Committee shall  give primary consideration to the most efficient and economical means of implementing the  recommended Plan. Members of the Committee shall include the: Open Records Officer, the CEO  or his or her designee, Board Secretary, Solicitor, and such other individuals as the CEO may  designate. 

The Records Management Committee shall meet periodically to evaluate the effectiveness and  implementation of the Records Management Plan and recommend changes as needed. 

  1. Guidelines to Records Management Plan 

The School’s Records Management Plan shall be the principle means for the retention, retrieval,  and disposition of manual and electronic records, including emails. The Plan shall not rely  primarily on backup systems to manage the retention and disposition of records.

The Records Management Plan shall include: 

  1. Comprehensive listing of records and data of the School. 
  2. System(s) of records storage and retrieval to be used, including in what form the  records will be stored, maintained, reproduced, and disposed. 
  3. Preservation measures to protect the integrity of records and data. 
  4. Procedures and employee designated for determining whether an item is a record. 
  5. Procedures for adding, revising, or deleting records and data, and any other details  necessary to implement the Records Management Plan. 
  6. Provisions for the storage and retrieval of records in the event of an emergency or  disaster. 
  7. Procedures to be implemented in the event of a litigation hold that immediately  suspends disposition of all records relevant to the current or potential claim. Such  procedures shall specify: who can initiate a litigation hold; how and to whom a  litigation hold is communicated; who will determine which records are subject to  the litigation hold; who will be responsible for collecting and preserving such  records and data; who will be responsible for monitoring and ensuring the School’s  compliance with the litigation hold; in what format the records will be collected. 

When possible, records and data shall be stored in their original form, including metadata, such as  creation date, author, type of file, etc. 

For any record not covered by the Records Retention and Disposition Schedule, the Records  Management Committee shall determine how long the record shall be kept and recommend any  necessary revisions to the retention schedule. 

The School shall maintain and dispose of records in a manner that protects any sensitive,  proprietary, or confidential information or individual privacy rights, and helps conserve natural  resources. 

Attached as an Appendix to this Policy is a Records Retention Schedule. 

  1. Manual Records

Manual records, which include all records not stored electronically, shall be retained and disposed  of in accordance with the Records Management Plan. 

Manual records shall be indexed in an organized and consistent manner, reflecting the way the  records will be retained and referenced for later retrieval.

The School shall develop and maintain adequate and up-to-date documentation about each manual  record system. Documentation may: list system title and responsible employee(s) or departments;  define the contents of the system, including record formats; identify vital records and information; determine restrictions on access and use 

  1. Electronic Records

Electronic records shall be retained and disposed of in the same manner as records in other formats  and in accordance with the Records Management Plan. 

Electronic records shall be indexed in an organized and consistent manner, reflecting the way the  records will be retained and referenced for later retrieval. 

The School shall develop and maintain adequate and up-to-date documentation about each  electronic record system. Documentation may: list system title and responsible employee(s) or  office; specify all technical characteristics necessary for reading or processing the records stored  on the system; identify all defined inputs and outputs of the system; define the contents of the  system, including records formats and database tables; identify vital records and information;  determine restrictions on access and use; describe update cycles or conditions 

  1. E-mail Records

E-mail messages, in and of themselves, do not constitute records. Retention and disposition of e mail messages depend on the function and content of the individual message. 

Records on an e-mail system, including messages and attachments, shall be retained and disposed  of in accordance with the School’s Records Management Plan. 

E-mail messages and attachments that do not meet the definition of records shall be deleted as  required by the Records Management Plan. 

E-mail records may be maintained as an electronic record or be printed and maintained as a manual  record. 

For each e-mail considered to be a record, the following information shall be retained: Message  content; Name of sender; Name of recipient; Date and time of transmission and/or receipt 

  1. Contractors

Records created or maintained by contractors employed by the Board shall be retained and  disposed of in accordance with the Records Management Plan.