AP 580: Division Record Management

Business & Finance

Background

Records of Parkland School Division shall be consistently managed meeting the identified requirements of the Freedom of Information and Protection of Privacy Act (FOIP), the Education Act, and this Administrative Procedure.

The purposes for retaining records include:

  • Supporting effective decision making and operational requirements;

  • Supporting the sharing of, and access to, information by those who require it, subject to legal and policy constraints; and

Identifying and preserving information of value to showcase the work of the Division and its activities.

When electronic records are created they are named with a file name that supports retrieval, stored based on the functional classification scheme of the Records Retention Schedule, and managed in an endorsed repository. Processes and training are provided to staff to promote consistency for the Records Management Program.

At Parkland School Division digitization serves to improve access and preserve records with a goal of replacing the original source records in hard copy format. Records are scanned and uploaded to an endorsed repository.

Definitions

a)  Control: shall mean the decision-making authority over the records.

b)  Intrinsic value: shall refer to the usefulness or significance of a record derived from its physical or material qualities, inherent in its original form and generally independent of its content, that are integral to its nature and would be lost in reproduction. Intrinsic value is often associated to the rarity or age of the support as well as its quality.

c)  Legal Hold: shall refer to a hold placed on the disposition of records due to a foreseeable or pending litigation, government investigation, audit or special organizational requirements as identified by the Division or the Board.

d)  Personal information: shall refer to information about an identifiable individual such as name, home address, telephone number, race, national or ethnic origin, colour, religion, political beliefs or associations, age, sex, marital status, family status, identifying numbers, fingerprints or blood type.

e)  Record: shall refer to information in any recorded form including documents, letters, handwritten notes, completed forms, reports, personnel files, meeting minutes, agendas, policies, emails, voice mails, electronic files, maps, drawings, photographs, student records, audio recordings, and school calendars.

f)  Records Disposition: shall mean the plan for retention or destruction of records. While some records are intended to be transferred for permanent retention in Archives, others are to be securely disposed of.

g)  Records Disposition Authorization: is used by department and school sites to document and approve records disposition while certifying that destruction or transfer has occurred. Once complete, the form becomes a permanent record of the Division.

h)  Record Retention Schedule: shall refer to the timetable that identifies the records of the Division, the action that triggers the closure of a record, the length of time a record is retained before disposition, and the final disposition of records (archives or destroy).

i)  Source record: shall refer to the original hard copy record from which a digitized version has been created.

j)  Transitory records: shall refer to records of short term use not required to meet statutory obligations. Examples include supplier catalogues, promotional materials on products and services, upcoming training workshops and conferences, working papers, research materials and notes. Transitory records generally have only temporary usefulness, are not identified as records in the Records Retention Schedule, and are not filed in a records system.

Procedures

1. All records are created, maintained and stored to support access and retrieval with protection against unauthorized access;

1.1.  Records are managed by an approved Records Management Program; and

1.2.  Procedures and training shall support consistency and compliance to the Program.

2. The Associate Superintendent, Corporate Supports and Services, holds responsibility for the Records Management Program.

3. A Retention Schedule, (Schedule 580A – Records Retention), shall identify what records are kept and for how long;

3.1.  The Retention Schedule shall be reviewed annually to ensure it identifies required records of the Division;

3.2.  The Retention Schedule shall have a classification scheme that supports the organization of information; and

3.3.  The Retention Schedule shall apply to records in all formats.

4. Once a record has met the termination of its retention requirement, the disposition of records shall be subject to approval based on submitted inventories.

4.1. Processes shall be followed to ensure the complete and secure destruction of records, or

4.1.1. The transfer of records to archives for permanent preservation.

5. Departments and schools shall:

5.1.  Adhere to approved processes;

5.2.  Hold responsibility for managing records according to the Records Retention Schedule; and

5.3. Hold responsibility for preparing inventories for review and approval.

6. As much as possible, when a record is created as electronic or digital, it will remain digital, and be stored in an endorsed repository.

7. Student Records, as mandated by the Student Record Regulation, shall be stored in a secure manner and treated as confidential at all times;

7.1. Specific information regarding managing Student Records is identified in AP 320 – Student Record Management.

Electronic Records Management and Destruction of Source Records

This section applies to records under the control of Parkland School Division as listed by Administrative Procedure 580, and in particular, Schedule 580A.

8. This Disposition Authorization excludes:

8.1.  Any source record identified as having archival value specifically in its original format;

8.2.  Source records with intrinsic value, which may include proclamations, charters, and agreements;

8.3.  Documents requiring a “blue ink signature,” such as an employee beneficiary form;

8.4.  Records with corporate seals affixed;

8.5.  Cartographic, architectural or technical drawings, particularly with those stamped with an Engineer’s seal;

8.6.  Photographic material, including, but not limited to, slides and negatives;

8.7.  Original artworks; and/or

8.8.  Source records required to be retained in their original format by law, regulation or government policy.

9. Parkland School Division shall comply with all requirements described in the Canadian General Standards Board’s CGSB-72.34-2017;

9.1. Electronic records as documentary evidence, and similarly identified provisions, such as the Government of Alberta’s technical requirements for digitizing student records.

10. Parkland School Division shall document its actions to comply with industry standards through the creation of endorsed procedures and processes to support compliance for digitizing records.

11. Staff shall receive guidance, as prudent to do so, when scanning documents;

11.1. Quality assurance shall be performed and re-scanning conducted as required.

Authorization of Disposition

12. ParklandSchoolDivisionshalldestroydigitizedsourcerecordsaccordingtotherequirements outlined above.

13. Electronic records disposition shall occur such that an audit trail is generated for the disposition of records held in repositories.

14. Nothing in this Authorization authorizes the transfer, destruction or other disposition of any record in contravention of an Order of a Court, a provision in any Act, or content of a FOIP request.

Records Disposition Process

This section identifies the approved process to prepare records for final disposition (destroy or transfer to Archives for permanent preservation). Once the criteria for disposition is met based on Schedule 580A, disposition occurs following this process.

15. Once a record has met its retention requirement it shall be reviewed and inventoried by the person responsible for the record.

16. Records are kept for the timelines identified in Schedule 580A and managed throughout the record’s lifecycle.

17. For each record being proposed for disposition:

17.1.  Identify the Record Number and the Record Series (found on the Records Retention Schedule);

17.2.  Submit inventories of records with similar retention periods or final disposition together;

17.3.  Using the Records Disposition Authorization Form, describe the records being submitted. Transitory records are not inventoried;

17.4.  Identify the current date for the inventory, the school site or department location, along with the name and contact details of the person preparing the inventory.

17.5.  Provide a complete description of the records being proposed for disposition. (It is essential to describe the records in enough detail so they can be identified and approved for disposition).

17.6.  Provide the Record Number and Record Series description from the Records Retention Schedule;

17.6.1. For a case file series, such as SI-06 for Student Records, it is important to identify the content being destroyed. This means providing a listing of names. Provide the start date and the end date for the records being submitted. Identifying the month and year is sufficient;

17.7.  Utilize Schedule 580A to identify the retention period for the required records and provide this information on the Records Disposition Authorization;

17.8.  For the notes section, identify any additional information to support the disposition process;

17.9.  Once completed, submit the form for signature to the Principal for school sites or to the Department Head for review;

17.9.1. The reviewer shall determine if there is any need to retain the records to support a business requirement for the organization beyond the time period of the Records Retention Schedule;

17.9.2. The reviewer shall determine that the records met their disposition as specified in the Records Retention Schedule, and there is no operational need to extend the time period for retention.

17.10.  Once signed off by the Principal / Department Head, the form shall be submitted to the Executive Assistant, Corporate Supports & Services, Centre for Education);

17.10.1. Thisindividualshallensurethereisnoorganizationalrequirement(e.g.FOIP request, Legal Hold) requiring further retention of the records.

17.11.  Once approved, the records are either transferred for permanent preservation to an Archive or destroyed:

17.11.1. Electronic records shall be expunged; and

17.11.2. Paperrecordsshallbesecurelydestroyedbasedoncontractedservicesfor secure shredding.

17.12.  Measures shall be in place for the secure destruction of all records so that personal information is secure and protected.

18. The approved Records Disposition Authorization is a permanent record and filed in the recordkeeping system.

signature

Date Approved:  May 12, 2020

Reference: Education Act: 52, 53, 56, 65, 67, 69, 141, 205, 222
Freedom of Information and Protection of Privacy Act
FOIP Regulation 186/2008
Student Record Regulation 97/2019

Reviewed or Revised:
Executive: May, 2020
Business & Finance: May, 2020

References shall be updated as required and do not require additional approval.