Information Management Policy Related Procedures Consultation Draft PROCEDURE FOR USING RETENTION AND DISPOSAL SCHEDULES The designated Information Management and Protection Lead is responsible for ensuring that Retention and Disposal schedules are established for the Unit. The Retention and Disposal Schedule prescribes retention periods and requirements for the legal disposal of Official University Records. It provides direction to ensure that Official University Records are retained for as long as necessary based on their operational, fiscal, legal and historical value. It also prescribes the appropriate disposition of Official University Records – either destruction or archival preservation. The OCIO shall provide advice and support to Units in establishing and using Retention and Disposal Schedules. A Unit must contact the OCIO (im@mun.ca) to initiate the process of creating and implementing a Retention and Disposal Sschedule. Once the Retention and Disposal Schedule is established, the Unit is responsible for adhering to it by maintaining the records for their entire retention period and disposing of them when required. PROCEDURE FOR DECLARING AN ELECTRONIC RECORD THE OFFICIAL UNIVERSITY RECORD Before declaring an electronic record the Official University Record, the Unit must consult the Office of the Chief Information Officer (im@mun.ca) and the Office of General Counsel to ensure matters including the following have been properly addressed: - Do the records need to remain in paper format for legal, regulatory or contractual reasons? - Are the appropriate scanning standards, quality assurance, system audit, and compliance monitoring measures in place to ensure the electronic records are admissible as documentary evidence? - Are the Unit’s processes and practices compliant with Section 4.1 of the Management of Information Act? The OCIO will assist the Unit in determining a best practice approach. PROCEDURE FOR DISPOSAL OF TRANSITORY UNIVERSITY RECORDS Units must develop and document a process for the identification and disposal of Transitory University Records as part of their Unit’s overall information management operations. Unlike Official University Records, the destruction of Transitory University Records does not require creation and application of a Records Disposal Schedule. Upon notice of an audit, legal inquiry or Access to Information and Protection of Privacy (ATIPP) request, disposal of Transitory University Records must cease and they are treated no different than Official University Records in that they may have to be produced. 1 A copy of an Official University Record is usually transitory. Such a copy should not be retained longer than the approved retention period for the Official University Record of which it is a copy. Transitory University Records may contain personal or confidential information. In such cases, secure destruction practices must be followed by Units when disposing of Transitory University Records. At the St. John’s campus, see the Procedure for Shredding and Disposal of Confidential Materials – St. John’s Campus. PROCEDURE FOR MANAGING UNIVERSITY RECORDS OF EXITING EMPLOYEES Units must develop a process to ensure that University Records always remain in the custody and control of the University, and that access to University Records is managed when employees change positions or transition from one Unit to another. When an employee leaves the University, changes positions within the University, or transitions from one Unit to another within the University the following questions should be answered by the exiting employee: What University Records in paper format are under your control? desktop and desk drawers filing cabinets, both in the individual's workspace and shared space records temporarily in the possession of a colleague or another Unit commercial records storage What University Records in electronic format are under your control? local hard drive (e.g. C: drive) personal drive (e.g. folder on a shared drive only accessible to the individual) cloud storage (e.g. Dropbox, OneDrive, Google Drive) social media sites (e.g. Twitter, Facebook) managed by the individual on behalf of the University email accounts (both official University email and personal email accounts if applicable) calendar accounts removable media (USB drives, external hard drives, , CDs, etc.) devices such as laptops or mobile electronic devices, whether University or personally owned Once the questions above have been answered and an inventory of University Records has been established, the Unit must ensure that if any University Records are currently not accessible by the University (e.g. on personal DropBox account) they are moved to an accessible location such as a shared drive. What types of University access do you have? University systems such as Banner, MIMS, etc. Cloud solutions used for the delivery of University services Social media sites (e.g. Twitter, Facebook) managed by the individual on behalf of the University 2 Voicemail Keys/swipe cards to University facilities Information Technology Services (709-864-4595 or help@mun.ca) must be notified immediately of the exit of an employee from the University or the transition of an employee from one Unit to another to ensure University network and system access is deactivated or changed in a timely manner. In cases where social media sites were being managed by an exiting employee on behalf of the University, the individual’s account must be deactivated (if it is a named account) or the username and password must be provided to the Unit (if it is a generic University Account). In the case of a generic University account, the password must be changed. In the case of Cloud solutions being used by an exiting employee for the delivery of University services, it is the Unit’s responsibility to terminate any access. 3