File: EFA
SECTION: BUSINESS MANAGEMENT
TITLE: RECORDS MANAGEMENT POLICY
ADOPTED: 12.15.08
REVISED:
1. Purpose
2. Authority
SC 518
Open Records
Law
3. Definitions
4. Delegation of
Responsibility
SC 433
5. Guidelines
The Board recognizes that its records should only be retained as long as determined necessary to comply with federal, state and local law and regulations, as well as, the
District’s audit and management needs.
The Board sets forth the policy herein to inform all District employees of the requirements and responsibilities for the management of District records.
All District records shall be retained in accordance with federal, state and local law and regulations, as well as, District policies.
All District employees shall comply with this policy, the Records Retention Schedule and any rules, regulations or procedures promulgated hereunder.
The District shall make a good faith effort to comply with all proper requests for record production.
Litigation Hold : A communication ordering all records and data related to the subject of a dispute being addressed by current or impending litigation be preserved for possible production in the litigation.
Record : Any recorded information, regardless of form and including electronic records, that documents a transaction or activity that is created, received or retained in pursuance to law or in connection with the transaction of official business.
Record Retention Schedule : A comprehensive listing stating retention periods and proper disposition of records.
The Superintendent or his/her designee shall promulgate rules and regulations implementing this policy, including a Records Retention Schedule.
The Superintendent shall designate a Records Coordinator who shall be charged with the day-to-day application of this policy and the Record Retention Schedule and the development and implementation of records management procedures. The Records
Coordinator may delegate responsibilities as necessary to effectively carry out his/her duties.
Records Management Plan
The Records Coordinator shall implement records management procedures for the retention, retrieval and disposition of District records.
The procedures shall include at a minimum, but is not limited to:
1.
A system for storage and retrieval.
2.
Preservation methods to protect the integrity of records and data.
3.
Security measures to protect records and data.
4.
Provisions for the storage and retrieval of records in the event of an emergency.

RECORD MANAGEMENT POLICY
5.
Procedures relating to litigation holds.
6.
Procedures for the destruction of records.
File: EFA
Training
Employees shall be provided with this policy and Record Retention Schedule annually.
Employees shall periodically receive training regarding its application.
FERPA General Record Management Procedures
1. Storage. A storage and retrieval system shall be created that will allow for easy accessibility, management, searching, retrieval, production and destruction. The ability of the District to easily respond to requests and educational and business needs should be considered in developing a storage and retrieval system, as well as the destruction obligations of the District. Off-site storage of records shall be permitted.
2. Preservation. Proper preservation of documents shall be considered in the creation of a storage and retrieval system. A environment conductive to maintaining the integrity of the records is critical. This may include, but is not limited to, secure software, electronic security protection, acid-free folders, climate control, antimagnetic interference, and fire protection. Special disaster procedures shall be developed for records with permanent retention periods or whose loss would be damaging to continuity of the District
3. Security. Security of District records shall be critical. Security shall be taken into consideration in the creation of a storage and retrieval system. Anti-virus, antispyware, anti-spam and other software necessary for security purposes shall be maintained and update regularly. Procedures shall be developed regarding employees authorized to access records.
4. Electronic Records. Records transmitted through e-mail systems and other electronic records have the same retention periods as other formats that are related to the same program function or activity. Electronic and e-mail records shall be scheduled for destruction in conjunction with any other related records.
Litigation Holds
If an employee becomes aware of the reasonable likelihood of litigation, the employee shall immediately inform his/her supervisor, who will immediately take appropriate action to contact the solicitor and the Records Coordinator. If an administrator becomes aware of the reasonable likelihood of litigation, the administrator shall immediately contact the solicitor and the Records Coordinator. All record destruction shall be suspended immediately, even if the retention time period has passed. Selective destruction of records in anticipation of litigation shall be prohibited. The solicitor shall evaluate the need for a litigation hold. In the event that a litigation hold strategy is deemed necessary, the solicitor and the Records Coordinator shall develop a litigation hold strategy.
The Records Coordinator shall implement the litigation hold strategy. All records related to the litigation hold shall be retained during the pending litigation or proceeding.
Employees shall be notified and educated regarding the litigation hold. All employees

RECORD MANAGEMENT POLICY
File: EFA shall comply with the litigation hold strategy.
General Destruction Procedures
1.
Proper disposal or destruction of records shall be required.
2.
Records shall be destroyed within seven (7) days of the period designated in the
Record Retention Schedule, unless an exception is granted by the Records
Coordinator or a litigation hold is in place.
3.
The District may hire a document destruction contractor to assist in the disposal of records. The hiring of a document destruction contractor shall comply with all
District contracting requirements and obligations.
4.
Destruction of all records shall be by shredding, erasing or otherwise modify the information of the record to make the record unreadable, undecipherable or nonreconstrutable through generally available means.
5.
In the event that equipment in/on which electronic records have been stored is to be disposed of, any electronic record shall be transferred to meet the requirements of the Records Management Schedule, after which the information shall be made irretrievable prior to the disposal of the equipment on which it was originally stored.
6.
A record should be kept of the identity, inclusive dates, and the approximate quantity of records that are disposed of.
Review
This policy, the Record Retention Schedule and procedures developed hereunder shall be reviewed at least annually for effectiveness and compliance with law and amended as necessary.
Compliance
An employee’s failure to comply with this policy, the Record Retention Schedule, or any other rule or procedure promulgated hereunder may result in discipline up to and including discharge.
In the event the employee’s failure to comply violates federal, state or local law, the
District may report the violation to appropriate law enforcement officials. The District shall cooperate as required by law with such investigations.
New policy developed to address changes in Federal Rules of
Civil Procedure.
West Chester Area School District, West Chester, Pa