Records Retention Operating Procedure - 219.01
Purpose: These Operating Procedures are written to establish the process for implementation of and compliance with the College’s Records Retention Policy.
These Operating Procedures apply to all College employees and College Records (as defined in the Records Retention Policy) for all JCCC Departments.
Each Department shall be responsible for maintaining documentation on Records maintained and purged in their Department and ensuring that employees within the Department comply with the Records Retention Policy and these Procedures.
Purging of Records in accordance with these Procedures and the Policy will be accomplished on a Department by Department basis as each Department is trained and prepared to conduct purging of the appropriate Records.
A “Records Retention Schedule” is a document that guides decisions related to the maintenance and purging of College Records. A Records Retention Schedule contains, at minimum, a list of categories of Records and the length of time that each category of Records must be retained by the Department responsible for the Record. The retention periods contained in a Records Retention Schedule shall be, at minimum, the length of time required by law. Longer retention periods may be established to meet the business needs of the College.
A “Records Custodian” is the College employee in each individual Department that is responsible for overseeing and providing reports on the Department’s Records management as may be necessary or required for College operations.
Records are generated as a result of College processes. Once trained, each Department is responsible for ensuring proper retention and purging of the Records for which they are responsible.
It is imperative that JCCC knows which Records have been retained and which Records have been purged. Therefore, extra files, including correspondence, notes, emails, memoranda, computer discs, tapes, etc., are to be maintained as determined by the Department’s management, and even if authorized to be maintained in individual offices, at home or any other off-site location are subject to the Records Retention Policy and these Procedures and should not be retained in excess of the guidelines set forth in the Department’s Records Retention Schedule.
- Records Retention Schedule. A Records Retention Schedule will be developed and implemented by each Department in coordination with the College’s Office of General Counsel (OGC). In order to reduce the high cost of storing, indexing and handling the vast amount of Records that would otherwise accumulate, the Records Retention Schedule should set retention periods that appropriately allow for Records to be purged as soon as they are no longer required or necessary for legal or business reasons.
- Records Custodian. Every Department will designate a Records Custodian. The Records Custodian may delegate retention and purging tasks, but will be ultimately responsible for compliance with the Policy and these Procedures.
- Records Review. In most instances, Departments should schedule a Records review no less than once every six months. During this review, the Department will identify new Records to be purged since the previous review, unless an exception to purging applies as specifically set forth below.
- Purging. Records that are ready for purging and not subject to an exception should be purged in the following manners:
- Electronic Records should be deleted from the file in which they reside. JCCC will continue to evaluate new technologies as they become available in an effort to identify technology that will better assist with accurate and efficient electronic retention and purging of Records.
- Paper Records of a confidential nature (such as student records, personnel records, etc.) will be disposed per JCCC’s confidentiality guidelines for each Department.
- All other Records will be disposed of in any reasonable manner, considering the nature of the Records, as deemed appropriate by the Department.
- Exceptions to Purging. Records that are no longer subject to retention may need to be retained due to otherwise unusual circumstances, such as litigation or government investigation. If a litigation hold or other hold has been placed on a Record by the OGC, the department responsible for the Record will be notified, and will be responsible for labeling the Record for indefinite retention, until further notice is received by or on behalf of the OGC.
- Electronic Record Retention (Digital Imaging) Departments may elect to maintain Records in an electronic format, such as digital imaging. Digital imaging and other electronic record retention shall be utilized in a manner that will ensure confidentiality, reasonable accessibility and long-term preservation of Records in accordance with these Procedures and the Department’s Record Retention Schedule. The use of digital imaging and electronic record retention shall be consistent with all applicable laws, regulations and guidance as may be issued from the Kansas Historical Society and other governing agencies.
Requests for exceptions from the Policy or Procedures should be submitted in writing first to the Department’s Records Custodian and then to the OGC. In order to obtain an exception from the Policy or Procedures, there must be justification that will assure compliance with the basic objectives stated above.
The OGC and internal audit will be responsible for interpreting any portions of these Procedures or the Policy as they may apply to specific situations.
JCCC will take all reasonable steps to respond appropriately to any suspected intentional violation of the Policy or these Procedures and will discipline any violating employee through appropriate disciplinary mechanisms, including, as appropriate, discipline of individuals responsible for the failure to detect or report a violation.
Signature on File in Policy Office
Joseph M. Sopcich