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Records Retention Operating Procedure 219.01

Records Retention Operating Procedure 219.01
Johnson County Community College
Series: 200 Administrative Services
Section: Records

Cross-Reference: Records Retention Policy – 219.00

Applicability: This Operating Procedure applies to all Johnson County Community College (“JCCC” or “the College”) personnel and Records, as defined in the Records Retention Policy 219.00, for all JCCC departments.

Purpose: This Operating Procedure establishes the process for implementation of and compliance with the College’s Records Retention Policy 219.00. 

Definitions:

“Records Retention Schedule” is a document that guides decisions related to the maintenance and purging of 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 least, the length of time required by law. Longer retention periods may be established to meet the business needs of the College.   

“Records Custodian” is the College employee in each department who is responsible for overseeing and providing reports on the department’s Records management as may be necessary or required for College operations.

Procedures:

Each department shall be responsible for documenting Records maintained and purged and ensuring that its employees comply with the Records Retention Policy 219.00 and this Operating Procedure.

Records retention will be accomplished on a departmental basis, as each department is trained to identify, maintain and purge appropriate Records and will occur in accordance with this Operating Procedure, Records Retention Policy 219.00, Data Classification and Security Policy 530.00, and Data Classification and Security Operating Procedure 530.01.

It is imperative that JCCC knows which Records have been retained and which Records have been purged. Therefore, copies of Records, including correspondence, notes, emails, memoranda, computer discs, tapes, etc., that are authorized to be maintained in individual offices or any off-site location should not be retained in excess of the guidelines set forth in the department’s Records Retention Schedule.

Records Management

  1. Records Retention Schedule. Records Retention Schedules will be developed and implemented by departments 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 provide for Records to be purged as soon as they are no longer required or necessary for administrative, fiscal, legal, historical or business purposes.
  2. Records Custodian. Departments will designate a Records Custodian, who will typically be the Data Custodian, as defined in the Data Classification and Security Operating Procedure 530.01. If the Data Custodian is different from the Records Custodian for a particular department, the Records Custodian will coordinate Records management with the Data Custodian. The Records Custodian may delegate retention and purging tasks but will be ultimately responsible for compliance with the Policy and this Operating Procedure. 
  3. Records Review. Departments shall review Records annually to identify new Records to be purged since the previous review, unless an exception to purging applies as specifically set forth below.
  4. Purging. Records that are ready for purging and not subject to an exception, as set out in this Operating Procedure, should be purged as follows: 
A. Records containing Sensitive and Restricted Data, as defined in the Data Classification and Security Operating Procedure 530.01, will be purged in accordance with applicable law, the Data Classification and Security Policy 530.00, the Data Classification and Security Operating Procedure 530.01, and JCCC’s confidentiality guidelines for each department. 
B. Electronic Records containing Public Data, as defined in the Data Classification and Security Operating Procedure 530.01, should be purged from the file in which they reside.
C. All other Records will be purged in any reasonable manner, considering the nature of the Records, as deemed appropriate by the department.
  1. Exceptions to Purging. Records that are past the stated time period in the applicable Records Retention Schedule may need to be retained due to otherwise unusual circumstances, such as litigation or government investigation.  If a hold has been placed on a Record by the OGC, the department responsible for the Record will be notified and will label the Record for indefinite retention, until further notice is received by or on behalf of the OGC. 
  2. Departments must maintain a record of purged Records.

Electronic Records Retention

Departments may elect to maintain Records in an electronic format, such as digital imaging or email. Digital imaging, email, and other electronic Records retention methods shall be utilized in a manner that will ensure confidentiality, reasonable accessibility, and long-term preservation of Records in accordance with this Operating Procedure, the Data Classification and Security Policy 530.00, the Data Classification and Security Operating Procedure 530.01, and the department’s Records Retention Schedule. Emails are not their own Record type and should be retained as per the retention period for the appropriate Record type as determined in a department’s Records Retention Schedule. The use of digital imaging, email, and other electronic Records retention methods shall be consistent with all applicable laws, regulations and guidance as may be issued from the Kansas Historical Society and other governing agencies. 

Exceptions

Requests for exceptions from the Records Retention Policy 219.00 or this Operating Procedure 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 Records Retention Policy 219.00 or this Operating Procedure, there must be justification that will assure compliance with the basic objectives stated above.

Interpretation

The OGC and Internal Audit will be responsible for interpreting any portions of this Operating Procedure or the Records Retention Policy 219.00 as they may apply to specific situations.

Signature on File in Policy Office
President

Date of Adoption: 06/26/2013
Revised: 01/21/2021