SAMPLE

Retention Procedure Development and Implementation Checklist

NOTE: Review all retention and destruction schedules and procedures with your school’s leadership and attorney for
advice and approval. Requirements and standards vary by state and by school. This webinar and sample
documentation do not constitute legal advice or supersede the advice of your school’s legal counsel.

AFTER your Document Retention and Destruction Schedule is developed, then reviewed and
approved by your legal counsel…

 Apply the Document Retention and Destruction Schedule to your existing paper archive,
destroying any documents which are “expired” already according to the checklist.

 Prepare remaining stored records for scanning to archive records digitally. Deleting is easier
to centrally control when the retention period expires.

o Organize remaining stored records according to destruction periods.

o Mark records with creation dates which can be incorporated into the scanned file
name.

o Don’t mix records with different destruction dates in the same file folder.

o If you are using flat pdf scans (not searchable scans), scan records with the box title
as the major file name, with file labels within the box as subfolder names, and with
contents of each file scanned as one pdf file. It makes searching and using flat pdf
files the same as searching through paper boxes during the retention period.

o Decide if you are scanning in-house or outsourcing. Outsourcing is helpful and

probably cheaper
 to document the conversion of paper records to digital records,
 to avoid wear and tear on school copier/scanner machines (remember that
leased machines with a service contract are usually charged per page run
through the machine),
 to reduce use of staff resources to prep files for scanning (removing
fasteners, taping receipts and other non-standard sized papers to feed
through the scanner, and
 to move and organize scanned files onto whatever medium the school
chooses for archival purposes and for ease of access and use during the
retention period.
 to transfer the risk of document conversion (or destruction if you outsource
that as well) to a third party which invests in training, tools, and resources

Retention Procedure Development and Implementation Checklist Page 1 of 5

 to be experts in compliance and thereby to help the school’s compliance by
meeting those standards.

o Decide if you need “smart,” searchable scans which require software to enable
searching scanned files based on keywords, OR if you need simple, flat pdf files.
(HINT: You can do both.)

Considerations:
 Searchable scans are a little more expensive and involve the purchase of
software,
 Some records are already organized in a way that makes simple, flat pdf files
fine to use (example: payable files),
 Some records need searchable scans due to the structure and nature of the
files (example: board documentation, looking for a particular discussion in
minutes, but you don’t remember the date, it was discussed in several
meetings, and you need all discussion history),
 Flat pdf file storage, access, and use requires less storage space, since no
software has to be hosted.
 Destruction of flat pdf files without document management software
requires more manual intervention to select and delete files, whereas
document management software is capable of query for isolation of files to
be deleted, file deletion controls/approvals, and documentation of file
deletion. Without software to do this, a manual control and logging
process is needed.
 Management software can be added and can manage the conversion of your
existing scanned archives to a managed platform, but it might cost a little
more to convert later rather than adopting management software upfront.

 Develop and implement your digital archive storage, usage, and back-up plan to ensure you
have
o server space,
o controlled access management for users to search records during the retention
period,
o appropriate security for school records to protect confidential and private
information records,
o regular back-up for disaster recovery,
o protection against modification or inadvertent deletion, and
o provision for conversion to new databases or systems so that old systems and system
access/use instructions remain available for whatever period is necessary to support
compliance of records which do not convert.

 Define your document retention and destruction procedure on which all school staff must
be trained annually. Consider that:
o Simplicity of the program fosters compliance.

Retention Procedure Development and Implementation Checklist Page 2 of 5

 o Anticipating staff problems and fears with records handling fosters compliance, and
solving them by
 Getting inactive paper files out of their way,
 Making scanned archives secure, but accessible and easy to use,
 Planning employee procedures and communication to
 Communicate the logic of the requirements:
o legal compliance (remember Enron?),
o liability protection by proving appropriate practices,
o data and research needs of the school, and
o changing technologically savvy culture that is more
information-aware.
 Assure staff that nothing will be destroyed without administration
review each year, so new processes or extended use of expired
documents must be flagged to the staff’s area administrator,
 Explain that this process is a protection of them since everyone has skin
in the game, helping them to remain personally compliant with
school policy, with liability practices, and with legal requirements,
 Encourage them to work smarter during the year to avoid prep work
of files for archive at year-end,
 Provide them a simple way to move “inactive” files out of their
workspace at each year-end for central, digital archive,
 Identify and prepare an Information Officer point of contact for staff
to ask questions, consult, and notify of concerns,
 Clarify the expectations and positive impact of compliance versus
negative impact of non-compliance on the school, students,
employees, leadership, and overall reputation of the school, and
 Engage staff to be an “information-aware” culture.

o Draft the procedure, thinking through Day One changes and reasonable,
sustainable ongoing practices.

o Submit the schedule and procedure to the auditor, insurance broker, attorney,
leadership, and appropriate board committee for review, feedback, and approval.

o Incorporate the approved policy/procedure in the employee handbook.

o Developing a digital means to distribute short, relevant training and document

training completion will be more successful due to varying staff schedules.

(HINT: Creating a prezi or powerpoint with embedded engaging, simple video clips
and a link to a survey to test knowledge and send results to HR will provide a
document for the employee to keep for reference, a training tool that can sit on the
intranet for access by employees at any time, a way to ensure and document that all

Retention Procedure Development and Implementation Checklist Page 3 of 5

 employees receive and complete the training, and a simple tool to update and re-
distribute for annual training requirements.)

 Create a master list of documents to be destroyed as a checklist each year, which can be
adapted to identify newly “expired” documents.

(HINT: Easy to do if you use your Document Retention Schedule, eliminating all
“permanent” retention documents, and add a blank date column to be changed each year).

 Use your original Document Retention and Destruction project team (HR, Registrar, IT,
business office, and who else??) as a committee to meet annually; two or three meetings will
be typically needed to
o request an update from legal counsel and your insurance broker on significant,
relevant changes in the past year which could affect your school,
o review any changes to legal or liability standards or practices which were collected
and filed during the year and provided by reliable sources,
o review the school’s procedure and retention schedule to make updates as needed,
o review the list of documents to be deleted/destroyed for that year, including any
records for which retention was previously extended due to project use or legal
necessity,
o distribute, collect, and review a document retention and destruction notice to
school administrators to:
 request that year’s “inactive” files (providing a list from the document
retention schedule) to be organized and transferred to the Information
Officer for digital archive by ____ date,
 notify them of changes to legal or liability standards or practices,
 identify the list of documents to be deleted/destroyed for that year with the
date of deletion/destruction,
 identify and integrate any new school processes, forms, data systems, or
other functions which create records not defined already in the school’s
Document Retention and Destruction Schedule,
 identify and mark any discontinued school processes, forms, data systems,
or other functions which have records defined in the school’s Document
Retention and Destruction Schedule (they must not be removed from the
schedule as long as there are applicable documents in an “active” retention
period),
 obtain written confirmation that an exception is not necessary to retain any
“expired records” due to research project use or legal necessity,
o document exceptions for records held beyond the retention period with new
destruction dates established and specially managed, and
o review the procedure for needed updates/clarifications,
o ensure that documents ready for deletion/destruction are destroyed after the
expiration date, which should be the latest date of the period the various records

Retention Procedure Development and Implementation Checklist Page 4 of 5

 represent. (Example: payable records from July 1, 2002, through June 30, 2003,
with a 7-year retention period would not be destroyed until one day after June 30,
2010.)
o document authorization for deletion/destruction and for exceptions to
deletion/destruction.

DO WHAT YOU SAY YOU ARE GOING TO DO, or you can expose your school and void your
insurance.

Remember, this is a living document and process which MUST change and adapt over time to fit
your school and to fit the changing regulatory and technology environment! It will take work to
get it set up, but it will be MUCH easier and less costly to live with than the alternative.

Retention Procedure Development and Implementation Checklist Page 5 of 5