Information Management
101
Arkansas School Business Officials
October 25, 2010
Presented by:
L. Freeman Wish, CPA
Clarksville School District
1701 Clark Road
Clarksville, AR 72830
479-705-3200
Freeman.Wish@csdar.org
Why Record Management?
Important to the way the school operates
Evidence of decisions, transactions, operations
School history
Strategic Planning
Components of Record Management
Archive
- A place where records of permanent value (inactive
data) are kept for legal, compliance, historical or
research purposes.
Records Management Center
- A place where semi-active data are kept for legal,
compliance, historical or research purposes and are
accessed frequently.
Records Management
- The systematic control of recorded information from
creation to final disposition.
What is a Record?
Recorded information, regardless of medium or
characteristics, received by an organization that
is evidence of its operations, and has value
requiring its retention for a specified period of
time.
Information created, received and maintained by
an organization or person in pursuance of legal
obligations or in the transaction of business.
What is a Record?
Information, often detailing business
transactions, that is preserved because of
the value of its data.
Sources of Information/Records
Correspondence
 Invoices
 Purchase Orders
 Payroll Records
 School Board Meeting Minutes
 Bond Issues
 Elections
 E-Mail
 Telephone Calls

Let’s Talk About E-Mail
Types of E-Mail
1.
2.
Non-Record Material
Official Records
Non-Record Materials

Personal Correspondence
 Any e-mail not received or created in the course of
school business, may be deleted immediately,
since it is not an official record: the “Let’s do
lunch” (not a school business lunch) or “Can I
catch a ride home” type of note.
 Other examples would include any personal
messages not conveying school business.
Non-Record Materials

Transient Correspondence
 E-mail that is determined to have insufficient value
to warrant its preservation may be deleted upon
receipt.
 Examples are list serve messages, announcements
regarding departmental bake sales and other
agency memos without legal, administrative, fiscal
or historical value
Non-Record Materials

Non-State Publications
 Publications, promotional material from vendors,
and similar materials that are “publicly available”
to anyone, are not official records unless
specifically incorporated into other official records.
 Examples are unsolicited promotional materials
(spam), files copied or downloaded from internet
sites, etc.
Non-Record Materials

Non-State Publications
 However, for example, if you justify the purchase
of a particular filing system by incorporating the
reviews you saved from a list serve in your
proposal to your supervisor, those list serve
messages become official records and must be
retained in accordance with the retention schedule
for purchasing proposals.
Non-Record Materials

Duplicate records are not normally
considered records and do not have to be
retained.

Duplicates may become the only official
record if the original is destroyed or lost.
Official Records

Transient Retention
 Much of the communication via e-mail has a very
limited administrative value and is deemed
transient. For instance, an e-mail message
notifying employees of an upcoming meeting
would only have value until the meeting date has
been attended or the employee receiving the
message has marked the date and time.
Official Records

Transient Retention
 The user may delete these types of e-mail
messages immediately after they have served their
intended purpose.
 Other e-mail messages that have limited
administrative value would include: telephone
messages, drafts and other limited documents that
serve to convey information of temporary
importance in lieu of oral communication. It would
only be necessary to retain these records until no
longer of administrative value.
Official Records

Intermediate Retention
 E-mail messages that have more significant
administrative, legal and/or fiscal value but are not
scheduled as transient or permanent should be
categorized under the appropriate record series.
Official Records

Intermediate Retention
– These may include (but not limited to)
 General Correspondence: Includes internal
correspondence (letters, memos): also,
correspondence from various individuals,
companies, and organizations requesting
information pertaining to agency and legal
interpretations and other miscellaneous inquiries.
 This correspondence is informative: it does not
attempt to influence agency policy.
Official Records

Intermediate Retention
– These may include (but not limited to)
 Routine Correspondence. Referral letters, requests
for routine information or publications provided to
the public by the agency, which are answered by
standard form letters.
 Monthly and Weekly Reports: Document status of
on-going projects and issues; advising supervisors
of various events and issues.
Official Records

Intermediate Retention
– These may include (but not limited to)
 Minutes of Agency Staff Meetings: Minutes and
supporting records documenting internal policy
decisions.
Official Records

Permanent Retention
– E-mail messages and other memorandums
having significant administrative, legal and/or
fiscal value and are scheduled as permanent
should be categorized under the appropriate
record series.
Official Records

Permanent Retention
– These may include (but not limited to):
 Executive Correspondence: Correspondence of the
head of an agency dealing with significant aspects
of the administration of their offices.
Correspondence includes information concerning
agency policies, program, fiscal and personnel
matters.
Official Records

Permanent Retention
– These may include (but not limited to):
 Department Policies and Procedures: Includes
published reports, unpublished substantive reports
and policy studies.
 Reflect official actions taken.
 Convey statements of official policy or rationale for
official decisions.
What is Record Management?
File Plan Implementation
Records Retrieval
Retention and Disposition
Preservation of Significant or Historical
Records
Auditing
What is Record Management?
The systematic control of all records
from their creation or receipt,
through processing, distribution,
organization, storage and retrieval
to their ultimate disposition.
Why Do I Need Record Management?
Comply with Government Regulations
 Reduce Legal Liability
 Control Valuable Company Assets
 Reduce Record Archive Size

Essential Elements of
Record Management
Record
 File Plan
 Retention Schedule
 Records Retrieval
 Disposition

File Plan
A system for categorizing records, divided
into categories.
Each category has its own retention
schedule.
All records in the system are assigned to a
category.
Retention Schedule
The amount of time a record should
remain in the system.
 When (and if) the record should be
disposed.
 How the record should be disposed.

Record Retrieval
Structured query, full text search, or a
combination of both.
 Export records into their native formats.
 Print or e-mail records.
 Version records.
 Add notes or comments to original record.

Disposition
The method by which a record is removed
from the system.
 Disposition is based on time, event, or a
combination of time and event.
 The process is generally either transfer or
destruction.

Why Dispose of Records?
Not all records are permanent records.
 Non-permanent records may have set
retention rules.
 Enforcing retention rules removes records
when they become obsolete.
 Example: Destroy employee personnel
records seven (7) years after retirement.

Record Retention Policy

Lack of a formal Arkansas School Record
Retention and Disposal Plan.

West Virginia Records Retention Schedule

Michigan Public Schools Record Retention Plan

Recommend that each school adopt a Record
Retention Plan and follow it.
Legislative Action
19-4-1108. Retention of documents.
(a) The original evidences of indebtedness, including documents prepared in connection with
purchasing procedure, and all original contracts, invoices, statements, receipts, petty cash
tickets, bank statements, cancelled checks drawn upon bank accounts, and other original
supporting papers shall be retained in the permanent file of the business office of each
state agency. These documents shall be kept in a safe place subject to audit and shall not
be destroyed until authorization is given for their destruction by the Legislative Auditor.
(b) With the approval of the Legislative Auditor of the state, a state agency may retain
evidences, to satisfy record retention policies, of indebtedness and other contracts,
invoices, statements, receipts, petty cash tickets, bank statements, cancelled checks
drawn upon bank accounts, and other supporting papers by microform or a form of
stored images in a computer system or other form of computer technology in lieu of
retaining the originals of such documents.
History. Acts 1973, No. 876, § 15; A.S.A. 1947, § 13-341; Acts 1997, No. 541, § 2;
2001, No. 1453, § 33.
DFA Interpretations
R1-19-4-1108 Public Records
The law defines public records as writings, recorded sounds, films, tapes,
electronic or computer-based information or data compilations in any medium
required by law to be kept or otherwise kept and which constitute a record of
the performance or lack of performance of official functions which are or should
be carried out by a public official or employee, a governmental agency or any
other agency wholly or partially supported by public funds or expending public
funds.
All public records shall be open to inspection and copying by any citizen of the
State of Arkansas during the regular business hours of the custodian of the
records, except as otherwise specifically provided by law.
Refer to Arkansas Code ACA 25-19-105 for exceptions, charges for providing
copies of records and required response time to requests for copies and ACA 2519-109 for special requests for electronic information.
R2-19-4-1108 Records Retention
All records that are public property are required to be maintained by the agencies
that generate the documents. The type of business record in question and the
business process it supports determines the length of retention. Generally, all
records should be maintained a minimum of three fiscal years. All records and
supporting documentation must be maintained until they have been audited and
may not be destroyed until permission has been granted by the Division of
Legislative Audit. Other records such as records for grants are maintained
according to State or Federal laws.
Public records can only be destroyed after permission is granted by the Division
of Legislative Audit.
Storage of records in electronic form is permissible in some cases. Refer to
Arkansas Law ACA 19-4-815, 19-4-1108, 25-32-112, 13-4-203, 25-32-117, 25-32118.
Effective January 1, 2006, the Executive Chief Information Officer shall
promulgate rules and guidelines governing the retention and management of
public records and issue periodic updates as necessary. Each State agency shall
comply with these rules and guidelines by the earlier of July 1, 2007, or when the
line item appropriation is established to comply with this requirement.
ACT 918 of 2005

Applies to all cities, county or local
governments in Arkansas

Requires the development of rules and
guidelines for the retention of public
records commonly found in state agencies

Requires rules and guidelines to be
effective July 1, 2007
Arkansas Record Retention
Schedule

Agency Directives,
Internal Policies and
Procedures

Keep until superseded
plus three years
Arkansas Record Retention
Schedule

Meeting Agenda and
Minutes of Governing
Bodies

Permanent
Arkansas Record Retention
Schedule

Employee Benefit
Records and
Employee Personnel
Records

5 years after
separation or until
closure of unresolved
personnel issues,
whichever is greater

Workers
Compensation
Accident Reports

3 years from date of
injury
Arkansas Record Retention
Schedule



Until authorized by
the legislative auditor
(as required by
Arkansas Code)

Until authorized by
the legislative auditor
(as required by
Arkansas Code)
Accounts Payable
Accounts Receivable
Let’s Take A Look At A Few
Examples of Record
Retention Periods
(Comparing West Virginia,
Michigan and Arkansas)
Accounting
Records
Bank Statements, Deposit Slips

West Virginia – Audit + 3 years

Michigan – Current FY + 7 years

Arkansas – Until authorized by legislative
auditor
Cash Receipts/Receipt Books

West Virginia – Audit + 3 years

Michigan – Current FY + 7 years

Arkansas – Until authorized by legislative
auditor
A/P Invoices/Purchase Orders

West Virginia – Audit + 3 years

Michigan – Current FY + 7 years

Arkansas – Until authorized by legislative
auditor
Journal Entries

West Virginia – Audit + 3 years

Michigan – Current FY + 7 years

Arkansas – Until authorized by legislative
auditor
Bonds

West Virginia – Permanent

Michigan – Expiration + 7 years

Arkansas – Expiration + 5 years
Audit Reports

West Virginia – Permanent

Michigan – Permanent

Arkansas – Until the next audit report is
issued by Legislative Audit
Let’s Talk Payroll Records
Employment History Records
Payroll History (Annual Earnings)

West Virginia – 50 years

Michigan – Current Fiscal Year + 50 years

Arkansas – Permanent
Unemployment Compensation
Records

West Virginia – At least 4 years

Michigan – Current Fiscal Year + 1 year

Arkansas – 5 years after case closed
Forms W-2

West Virginia – At least 4 years

Michigan – Current Fiscal Year + 7 years

Arkansas – Not Addressed in Arkansas
Record Retention Schedule
Time and Attendance Records

West Virginia – Not Addressed

Michigan – Current Fiscal Year + 3 years

Arkansas – Until authorized by legislative
auditor
Salary Schedules

West Virginia – 25 years

Michigan – Creation Date + 6 years

Arkansas – Not Addressed in Arkansas
Record Retention Schedule
Case Study of Record Retention
Policies That Don’t Work
Carlucci vs. Piper Aircraft
A Piper Cheyenne crashed in Ireland – 3 men
died as a result
Clara Carlucci sued Piper for design defects
that caused the pilot to lose control and
crash
Records were subpoenaed from Piper
2 Employees in Flight Test Department had been told
by supervisor to “selectively” purge hundreds of
records that might be detrimental to Piper in future
lawsuits.
Carlucci vs. Piper Aircraft
Piper claimed these records were destroyed
under retention procedures
Piper could not demonstrate that these
procedures were in place or that they
were being followed.
Judge entered default judgment against
Piper for $10 million – for selective
destruction of records.
Carlucci vs. Piper Aircraft
Judge did not even consider merits of case
Milestone decision about destruction of
records – courts will not tolerate selective
destruction of records
Major Issue – Piper could not document to
court that it destroyed its records in the
regular course under an approved records
retention schedule
The Andersen Lesson

After a 6-week trial and 10 days of
deliberation, a jury found Arthur Andersen
guilty of obstruction of justice when it
destroyed Enron Corp. documents while
on notice of a federal investigation by the
SEC.
The Andersen Lesson

The jury rejected Arthur Andersen’s
defense that the documents were
destroyed as part of its housekeeping
duties and not as a ruse to keep Enron
documents away from the regulators.
The Andersen Lesson
Arthur Andersen received the maximum
sentence of 5 years probation and a $500,000
fine.
 35,000 people lost their jobs worldwide.
 Since the initial court decision, the Anderson
Case was reversed but it was too late to save
the company

The Andersen Lesson
The lesson to be learned from the Arthur
Andersen experience is that a Document
Retention Program, an otherwise critical
part of a company’s risk management
program, will not save you from sanction
if the policy does not conform to law,
either in content or in implementation.
In Conclusion
Records and information are the key
component to the existence of any
organization.
 Good record keeping processes and
policies are imperative.
 Litigation issues.
 What happens if the organization ceases
to exist?

How to Comply

If a record retention policy
– Is reasonable, has a genuine business purpose and
establishes appropriate retention periods
– Is not selective – it wasn’t designed to destroy all records
quickly so that nothing would be available if anyone should
ever sue the organization or commence an investigation
– Is implemented in an evenhanded manner by employees
who understand the policy
– Provides for prompt cessation of destruction programs if and
when the organization learns of an investigation or litigation

Then
A company should not incur criminal liability for an innocent
failure to retain potential evidence.
Sites To Remember
The Arkansas General Records Retention
Schedule
http://www.dfa.arkansas.gov/offices/intergovernmentalS
ervices/Pages/recordRetentionSchedule.aspx
Sites To Remember
West Virginia Public School Records
Retention Schedule
http://wvde.state.wv.us/finance/manuals/
recordretentionschedule.pdf
Sites To Remember
General Retention Schedule #2
Michigan Public Schools
http://www.michigan.gov/documents/hal_
mhc_rms_local_gs2_171482_7.pdf
Thank You
For
Your Attendance
GOOD LUCK
I HOPE I HAVE HELPED
ALWAYS REMEMBER THIS!
IT IS NEVER TOO LATE
TO HAVE A HAPPY
CHILDHOOD