Policy No.

Section:

Title:

Date Adopted:

Date Last Revised:

800 OPERATIONS RECORDS MANAGEMENT 10/15/07

800 RECORDS MANAGEMENT

This Policy outlines the guidelines for the development of Administrative Regulations governing the retention, management and destruction of District records. The Superintendent or the Superintendent's designee shall work with appropriate administrative staff and the District's Solicitor to develop such Administrative Regulations which are necessary and appropriate to ensure compliance with applicable federal and state laws and regulations.

Electronically stored information includes but is not limited to emails, voicemails, draft documents, metadata, pictures, video footage, audio clips, and Auto CAD drawings. The possible sourcesllocations of electronically stored information are individual hard drives, local and remote servers, telephones, laptops, removable media and PDAs.

"Records" includes recorded information, regardless of form, that is created or received or retained in accordance with the District's official business. EmaiLm.~ssag~.s!Q~not constitute

r "re~o.rds:~~less t~e function and content of !he_~~~~&e'vV~::~etentio~e.~~der appTicablellw, policies or regulations. ···"O~"_"""~".".""_."".

Particular Records

The Board shall retain, as a permanent record of the District, minutes, annual auditor's reports

and annual financial reports. '~ n.~J,

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All other records shall be maintained in accordance with state and federal law and regulation and

the Administrative Regulations promulgated in accordance herewith.

The determination of whether a particular document or particular information will be retained as a "record" of the District depends not upon the format of the document or information (types, electronic, recorded), but on the content contained therein, whether the information is retainable and whether the maintenance of that information is necessary for the District's operations.

General Reguirements

The Regulations regarding record retention shall address the manner in which records are to be maintained and purged and must differentiate between those records that are maintained in manual form and those records maintained in electronic form.

The Regulations must set forth the purpose and guidelines for any "back up" or "archiving" system used including an archive system particularly utilized for the back upretention of emails and other email client mailbox items.

In general, appropriate hardware and software shall be used to ensure that records that are retained in electronic form are reasonably accessible; however, to the extent that information is

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9 11 07 lEar l0003965 'I J (000396541 (00039654}

Administrative Regulation No. Section:

Title:

Date Adopted:

Date Last Revised:

information being retained in electronic form is being retained in a reasonably accessible manner, (3) confidential information is being maintained in a secure manner and (4) electronic and manual records are being retained and purged in accordance with this Regulation.

800 OPERATIONS RECORD RETENTION AND MANAGEMENT 10/15107

F. lmplementation Date

This regulation shall become effective July 1, 20 10.

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Administrative Regulation No. Section:

Title:

Date Adopted:

Date Last Revised:

800 OPERATIONS RECORD RETENTION AND MANAGEMENT 10115/07

800 RECORD RETENTION AND MANAGEMENT

The School District receives and generates volumes of information in both electronic form and hard copy. Not all information received constitutes a "record" that the District will retain for an extended period. The Superintendent shall designate one or more individuals responsible for setting forth guidelines to direct and assist employees in determining what information/documents/data should be retained and what information/documents/data need not

be retained and creating guidelines for appropriate uses of ular means of communication.'

The purpose of this Regulation is to clarify how records \Y' etained and destroyed.

For the purposes of this regulation "reasonably awessible"$p\JII mean that the information is available to authorized District personnel in a m<ll1Per and format that is generally indexed or cataloged or is readily searchable for ease ofr~ft:reriCe.

A. Retention, Storage and Destruction of Records

manner of record retention, types of District records. A referred to the appropriate Dist

incorporated herein sets forth the the manner of disposal of various identified on the ehart shall be

B.

"E-!l1aiIClient Mailb{)xJterns" inc1udes but are not limited to. the following: Calendar. Conm.9tS. f:,:mai.l"..l-1Ql"lL\U1d ·Cask.§.:.

"Archived Items"

de lli.efollowino: E-mail Client Mailbox Items that have been

moved into the arch!

svstem .

':J349!s-Jl p:~m~?'l};> _e1il j)J i and not as a scarehab

. ve_.~teg\IQDi(;.I~.(;QrQ~_Tl}4jnt'!iD~.9_§QJ~]Y_JQL9i§4?L~Lr<;.QQ'!:"ry 'hive.

+:2. Archivine.Reci],ilirernents

3. All email will be archived immediately. Email remaining in an email client mailbox after a 72 hour period will be retained for a period of two years.

I These guidelines for each department (student services, personnel, facilities, etc.) should be developed in consultation with appropriate department heads.

Administrative Regulation No. Section:

Title:

Date Adopted:

Date Last Revised:

During the 72 hour period prior to archiving, no employee may delete any email which is the subject of a litigation-hold .

. >,\Hki.ml!iL£lit3flLMl!!I~Q)dl§l.ffl.~.y.'in.Q~.ilfl3_hJ.~(~g.flQ_t>..QQfl_tlL!h.l¥.1.l'n'_eflty_foHF+ . . .. . { Formatted: Bullets and Numbering and later than forty eight hOHrs. DHring this period, no employee may delete

any email which is the 5Hbject of a litigation hold.

800 OPERATIONS RECORD RETENTION AND MANAGEMENT 10/15/07

referenCl'S to student. parent, staff member or other person.

b. E-mail Client Mailbdx Items 'Nil! be archived for two vears.

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lTIail Client Mailbox archive system shall automaticaJly__purge.J\.nd overwritr, deleted information more than two vears old as an automatic function ofthe software unless litigation hold prompts retention of certain information.

baclmps will be. maintained for 30 cia.n. After 30 days. backups will be purged in accordance \"yW) the.llPQIQIJIiate methods f(jr the,given lechnoJ.Qgy.

d. [-mail Client Mailbox Items stored in the [-mail servers may be kept indefinitely at the discretion of the user. Age limitations and quotas may be required in the future to control the cost of storage, and can be implemented as

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Administrative Regulation No. Section:

Title:

Date Adopted:

Date Last Revised: necessary

800 OPERATIONS RECORD RETENTION AND MANAGEMENT 10115/07

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technologicallv available.

f. Electronic backups will be maintained for J 4 calendar days. After J 4 calendar- --gill'§_,_ back1J1?s v,jJl~Jl_l!I@gj_f!_ill:~_ordfLllc:;;_~lh th;;_:_ill)illDJ2_riate metho~_f or

the given technology.

g,_ The District' 5 archive/backup system (1)r~wails will store such information f()f no longer than six years at '-"hich p\iifIftj1e system shall automatically Fmfg-e-and-B-Yefwfi!e-sH-eh-afChtv,,~1ffi-ls-:£..lh(ormation contained on either

the archive or/_back up system e archi m other than E-mail Client

Mailbox Items is not intend e indexed or ged and is not intended

to be accessible 10 the Dist8etfor reasons other than emergency system

failure. Any requests to ac cb information on ei he archive_Qrjback

up system must be submitted Suendent or t perintendent's

Designee .. and, lll?gn)~ppr()valofthe_t?_ _ endentor the __ tiperinten~ellt 's

Designee the Dir~~(~t~FEechnologYDirector of Information Svstems shall assist in attempting to acces.~. the information.

!m!PJ.Q.Y~~ipil1aCtivatedatt.he time ofterminatio!h

em 10 with the District. The date of inactivation an Resources or desi mcc.

to ~

preeeBur§~Ele-&{,'Fibe'4if7n-Goolffi'li-are-I'e'luH'&i~OOweve-f;-lhi-s-ar~lti¥al--pef-ieJ-i&

dependent ollq'iftain f'i:9t1:JE; as explained below.

For an employee vtholeaves the District whether voluntarily or not under circ~!mstance" tltaHheg.istfic{-hel-K~s-h-as-th-to'---f*l1-Cflt-ial-te--res-ul-t--in-fffi--emp-k~y-menHH&C-'fim-inati&H elaim,{hcnlhe---emp!oyee's-eleetHlnie-aeeountshoutd-hefctaine-d-iflfa-rerioo-of-at--le-ast one (l) year.

for a former employee who had direct contact with parents in regard to student issues, t-he---l-)i-s-tri-€t-sha-l-l--ff'iain-the--ler-ffiet'-emrHe-ye-e-'-&ele-et-r-(='H-ic-<K'€O-unt-fuF--a-pe-'fi-od--ffi--a~t tv-o (2) years due to the possibility that the electronic files contain certain l10ticecl and/or requCtlts from parents regarding educational and related services, e'ial-uations, and

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Administrative Regulation No. Section:

Title:

Date Adopted:

Date Last Revised: accommodatiom.

800 OPERATIONS RECORD RETENTION AND MANAGEMENT 10115/07

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to the District's business in their District E-mail accounts as opposed to such records being retained in shared drives, networks, or printed and placed in phvsical tiles, then the former employee's E-mail and electronic account will be available for search, retrieval, fm_Q,--_~:v:h~Lt:_iJPnrQRrial~_archi viPg

at the direction of the Superintendent or Superintendent's. Such a review shall be undertaken in fiJIl comRliance with the former employee's privacv rights to the extent required bv law.

C. Legal Hold Procedures

1. Definitions

court proceeding.

t~:?.,Legal Hold Requirements

When the school District believ to litigation by or against

matters, requiring that documents anq data, including el~_ data, relating to the matter, incident, person or entity, be retained by the School District until such time as the legal hold is lifted.

of rrr~tt~rs that could lead to litigation by or against the School to identify such matters rests will all District employees.

When a School

employee has reason to believe that an incident may give rise to employee shall:

I . advise his or her immediate supervisor of the incident and prepare a written report stating the what the individual saw and/or heard, the names of the people and entities involved and the names of any witnesses and

2. preserve all documents, notes, data and information regarding the matter including, but not limited to effiaHE-mail communications, notes, letters and voice

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Administrative Regulation No. Section:

Title:

Date Adopted:

Date Last Revised:

mail messages, pending a determination regarding whether a legal hold is

800 OPERATIONS RECORD RETENTION AND MANAGEMENT 10115107

necessary.

The written report must then be forwarded to the Superintendent or the Superintendent's designee, who, in consultation with the Solicitor, will determine whether to place a legal hold on documents and data relevant to the incident(s). If a legal hold is implemented, then the I*ooiOf--flf-TeehflftlegY.!2ir.~.1QJ of Information Systems shall make all reasonable efforts to retrieve and maintain any archived electronic data before that data is purged and-in order to prevent ~reas()nablv accessible and potentially relevant information from being purged or deleted.

The Superintendent or the Superintendent's qesigneewill advise all School District employees involved with the incident(s) or-matterfs) at issweofthe legal hold and advise

them to retain all documents, notes, da,ta and information regal'ding the matter including, but not limited to em-ailE-mail communications, notes, letters andyoicemail messages pending further notice.

Incidents that may give rise to potential nugauon but are not limited to, the filing

of a grievance under a collective azreement, a request for due process under

the IDEA or Section 504, a ennsylvania Human Relations

Commission Equal Commission, an accident

(automobile, and/or property, a complaint

by a stude , racial, disability, religion, etc.)

harassment, a

If a matter issettIed or resolved or relevant statute of limitations has run or it ot\lerwise becomesapparentt\lat litigation is not likely to arise, then the Superintendent or the Superintendel1t'sdesignee, in connection with the Solicitor, will release the legal hold and the retained an¢ stored documents may be disposed of in accordance with the ordinary ddc\.lment retention policies of the District.

D. Destruction

Records shall be purged in accordance with the document retention schedule attached hereto.

E. Responsibility

Periodically, the {-I}ir-t,"etE:H,--&f__:I-eehn&legyDirector of Information Systems and the Business Administrator or designees] shall perform audits to ensure that (I) information being retained in manual form is being retained in a reasonably accessible manner, (2)

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Policy No. Section:

Title:

Date Adopted:

Date Last Revised:

800 OPERATIONS RECORDS MANAGEMENT 10/15/07

"backed up" or "m'chived" for the sole purpose of restoring the system in the case of an emergency, such information is not being "retained" by the District and need not be reasonably

accessible. Electronic information that has been deleted in accordance with this Policy and the Regulations promulgated hereunder shall be deemed not reasonably accessible.

The Regulations shall provide procedures and guidelines for implementing a "litigation hold" on records relevant to a particular matter where there is a reasonable likelihood of litigation regarding the particular matter.

The Regulations shall set forth periodic security measures to ensure the enforcement of this policy uniformly across the School District.

Reasonable safeguards will be instituted to protect the privacy of student, employee and other confidential information.

SC 518

Family Educational Rights and Privacy Act, 20 U.S.C. Sec. 1232g Fed. Rules of Civ. Proc. 34

Board Policy 007

Board Policy 216

Monday, May 10, 201OMoRsa-',', May 10, 2010TH6ssay, MaroH 09, 201~

91107 kar (00039651) (0003965'1) {00039654}