6900 Records and E-mail Retention
Original Date: 11/30/2010 * Last Revision Effective: 9/24/2012
Policy Contact: Vice-President, Administrative Services
Washington state law requires that all public state records are retained, stored, archived and disposed of appropriately after their active business use is completed, in accordance with schedules approved by the state records committee. Bellevue College procedure #6900P Records and Email Retention (Procedures) describes the processes used to archive public college records.
It is the policy of Bellevue College that all employees review and familiarize themselves with the established record retention schedule and with all retention procedures specific to their department or division programs and responsibilities.
Records which exist in printed, hard copy form are to be archived according to Bellevue College procedure #6900P Records and Email Retention (Procedures) and by the State Board for Community and Technical Colleges (SBCTC) record retention policy.
Electronic records are bound by the same provisions as paper documents, so if required records are in electronic form, they should also be retained appropriately by employees pursuant to state requirements. In addition, some electronic records are required to be formally transmitted to the state archives once their retention period is completed.
This means e-mail, instant messages, websites, and any other document stored electronically which contain public records must be identified, managed, protected, and retained by employees as long as needed for ongoing operations, audits, legal proceedings, research, or any other purpose.
Messages created or received in the transaction of public business and retained as evidence of official policies, actions, decisions or transactions are also retainable public records.
The proper length of retention for messages and attachments sent or received electronically is based on considering each just as if it were conveyed on paper. Each must be managed according to the approved retention schedule for the information contained within them.
Just as they were in their actively-used format, all records, printed or electronic, retained in compliance with state law or Bellevue College policy must continue to meet confidentiality requirements, including those required by Bellevue College policy #2550 Federal Privacy Act: Disclosure of Social Security Numbers, and policy #2600 Family Education Rights and Privacy Act: Disclosure of Student Information.
Sensitive and confidential data must also be protected from disclosure in accordance with the Bellevue College IT security standard addressing Data and Information Security.
This retention policy is secondary to the SBCTC retention policy, any current public record requests for specific public records, and any legal hold notices for records in response to potential litigation. Records produced in the execution of federally-funded grants and contracts must be retained in accordance with 45 CFR 74.53. Specific questions about the proper classification of a specific piece of information should be addressed to the office of the vice president of administrative services.
- Administrative Services
The vice-president of administrative services has responsibility for maintenance and administration of this policy, including for drafting any updates and changes to the policies and procedures.
- Data Users
All individuals who create data or information using Bellevue College computers, networks or systems has a personal responsibility for following this policy and for following the procedures that are in place to implement this policy.
- Campus Units
Each individual campus unit has responsibility for implementing the records retention procedures described under Bellevue College policy, and for establishing means for verifying employee compliance.
- Information Resources (IR)
Information resources has a dual role in the retention of electronic records. First, IR is a campus administrative unit and must meet the requirements for records retention of their own records, just like any other campus unit. In addition, IR has the responsibility of assisting campus users in the retention of their individual and unit electronic records and in helping to preserve the means to access any stored electronic records during their retention period.
Information resources will also advise and assist the college records officer and campus units regarding any technical aspects of retaining electronic records.
- Any paper, correspondence, form, book, photograph, film, sound recording, map, drawing or other document, regardless of physical format or characteristics made by any agency of the state of Washington or received by it in connection with the transaction of public business.
- Records as defined above that are stored, transmitted or shared via either electronic mail (e-mail) or instant messaging (IM) technologies which are stored in machine readable file formats. This includes e-mail or messages themselves which meet that definition of “records.” Electronic records may also include college web sites which contain and generate public records as defined by that procedure and by state law.
- Records identified as being of historical value to the state and the college. These records must not be destroyed; rather they must be transferred to the regional branch of the state archives serving Bellevue College.
- Records identified by the state board for community and technical colleges as essential for the continuity and restoration of college operations after a disaster.
Transitory administrative records
- Records which have no administrative, legal, fiscal, or archival requirement for their retention. These records include, but are not limited to:
- personal messages and announcements not related to business;
- information-only copies;
- copies of published materials;
- duplicate copies;
- preliminary drafts;
- internal requests for information;
- transmittal memos;
- reservations and confirmations;
- routine college admission letters.
- Routine correspondence concerning day-to-day office administration and activities. These records include, but are not limited to:
- intra-agency correspondence;
- routine correspondence with other agencies;
- correspondence with the public on routine matters.
This category does not include executive level correspondence or correspondence concerning policies and procedures.
Executive level documentation
- These are records which include, but are not limited to:
- correspondence and memos generated by the college president to and from public officials, the public, and others, concerning policy issues, concerns, actions, or issues.
Non-executive planning and working files
- These records include, but are not limited to:
- project design plans,
- survey forms,
- preliminary analysis reports,
- research materials,
- drafts, and
- other documentation related to management studies, non-fiscal audits, surveys, and planning studies.
RELEVANT LAWS AND OTHER RESOURCES
- Chapter 40.14, Revised Code of Washington, “Preservation and Destruction of Public Records”
- Chapter 434-662 WAC – Preservation of electronic public records
- General Retention Schedule for Washington’s Community and Technical College System, State Board for Community and Technical Colleges, 1998
- Bellevue College Policy #2550 Federal Privacy Act: Disclosure of Social Security Numbers
- Bellevue College Policy #2600 Family Education Rights and Privacy Act: Disclosure of Student Information
- Bellevue College Procedure #6900P Records and Email Retention (Procedures)
- Bellevue College IT Security Standard: Data and Information Security
Revisions 12/20/2011; 9/24/2012