6900P RECORDS AND E-MAIL RETENTION (PROCEDURES)
Original Date: 1/11/1995 * Last Revision Effective: 9/24/2012
Policy Contact: Vice President, Administrative Services
The following procedures are established to meet the requirements for implementing policy #6900 Records and Email Retention.
All offices, departments and divisions of the college will work with the vice-president of administrative services to ensure that:
- Only active records are stored in valuable office space.
- Non-current records are regularly shifted to the records storage center.
- Historically valuable records are preserved.
- Records are destroyed at the end of the retention period specified on the retention schedule.
- Records essential to college authority and operations are adequately protected from damage and loss.
- The college will be prepared to recover or replace records damaged by fire, flood or other disaster.
- All information systems, including hard copy, microfilm, and electronic, shall preserve the integrity and accessibility of the public records they hold for the duration of the established retention periods.
Records will be made accessible for public inspection and their security will be maintained according to the provisions of the public disclosure act.
Instructions for Archiving Printed/Hard Copy Documents
- Use the retention schedules link in the records management portal site to determine record series codes and retention periods for documents to be archived. After determining the correct records series code, double-check the exceptions to retention schedules document for further information.
- Sort the records by retention period and order records storage boxes from material resources.
- When boxing records always keep records with matching retention periods together (do not do one box that is half six (6) years retention and half three (3) years retention).
- For each box, complete a records retention form located in the forms library. Include the disposal date (based on the retention period), the record series code and a complete description of each type of file. Forms WILL NOT be accepted without record series codes.
- In the lower left-hand corner of the form is an empty box. Mark the form and the box using a character of your choosing (can be a number, letter, symbol, etc.). This is to ensure that the proper form ends up with the proper box.
- Email completed forms to Kathi Hutchins in administrative services.
- Administrative services will assign numbers to the forms and print them out in triplicate. Once the forms are completed, you will be sent two copies of the form (yellow and pink) and a storage card.
- Place the pink copy of the form inside the corresponding box and tape the card to the front of the box over the top of the square marked “records center box label here”. Use regular office scotch tape and tape the four sides of the card. Do NOT use packing or other tape. Please do not cover the center of the card – apply tape to the four edges only. Use request center to have material resources pick up the box(es).
- File the yellow copy. This is your department’s record of the archiving and may need to be referred to in the event that archived information needs to be retrieved.
Instructions for Archiving ELECTRONIC RECORDS
All electronic public records must be identified, scheduled and retained just like records in other formats.
General Electronic Records Retention Expectations
- Units and individuals will ensure that retained information remains accessible for the entire retention period of the record series. Retention procedures must take into account the security and retrieval requirements of both the current and the future users of the records when establishing archival methods. These users may include unit personnel, researchers and the public.
- Units and individuals will develop and use appropriate strategies to preserve retained data by migration from one generation of technology to another, when required. If data is not migrated, access to the records requires preserving the data, the storage medium in which the data is kept, and whatever hardware, operating system, and software applications are needed to view and use the data until the retention period has been met.
- When storing electronic media containing retained or archival materials, campus units should observe the published state “Environmental Standards or Best Practices for Storage of Electronic Media” (WAC 434-663-760), ensuring :
- Temperature ranges meet standards and best practices recommended for the media stored.
- Humidity ranges meet standards or best practices recommended for the media stored.
- Media is stored in a closed container to protect from dust and fingerprints.
- Magnetic tape should be rewound in accordance with de facto or industry standards, or to best practices.
- As determined by unit managers and supervisors, based on unit requirements and needs, individuals and units must regularly transfer electronic public records to an organized, secure and accessible filing system. Retained electronic records must be stored in a manner which protects them from subsequent alteration. Access to stored or retained data needs to be limited to only those authorized to access the data in its native state.
Applicability of Records Retention Requirements to E-mail
E-mail communications that are used as a means of conducting official business between the college and its correspondents may be subject to public records disclosure and may carry legally mandated retention requirements before being destroyed, deleted or erased.
Some messages may be of a transitory nature and have no retention value. Others may contain brief notes, may be formal and substantive documents, and may also have separate documents transmitted with the message as an attachment, all of which may need to be appropriately archived.
Essentially, it is the content of any electronic record and any attachments that may be associated with it which determines whether any specific message or document needs archived and how long the archival record will be maintained.
Samples types of e-mail content that are usually public records are listed below; this list is not comprehensive:
- Policy and procedure directives
- Correspondence or memoranda related to official Bellevue College business
- Agenda and minutes of meetings
- Documents related to legal or audit issues
- Messages which document Bellevue College actions, decisions, operations and responsibilities
- Documents that initiate, authorize or complete a business transaction
- Drafts of documents that are circulated for comment or approval
- Final reports or recommendations
- Executive appointment calendars
For the purpose of satisfying public record laws, e-mail is defined as not only the messages sent and received by e-mail systems, but all transmission and receipt data (known as meta-data), as well. This includes the content of the message, transactional information, and any attachments associated with the message—all of which are considered a part of the retainable record.
Retained e-mail messages should be indexed in an organized and consistent pattern reflecting the manner in which the records are used and referenced. Messages should be stored in a filing system that is logical and searchable.
Generally, the sender is responsible for retaining the primary record copy of e-mail within the college. The recipient is responsible for retaining e-mails that originate outside the college.
In addition to individual responsibilities regarding e-mail retention, each campus unit must individually identify those classes of e-mail messages for which it has primary retention responsibilities and which must be appropriately retained as records of the unit’s specific official and/or public activities.
Retained e-mail messages must be protected from inadvertent loss or destruction through compliance with backup requirements and procedures.
If another state agency or Bellevue College office has the primary responsibility for keeping the record copy of an electronic message or document and a unit has no business need to retain it, any copy of the document within the unit is considered an informational copy and is subject to deletion/destruction at will.
An e-mail message that is considered to have no administrative, legal, fiscal or archival requirements for its retention should be deleted as soon as it has served its purpose. Types of content sent via e-mail which typically have no retention value and may be destroyed when no longer needed include, but are not limited to:
- Transitory administrative records
- Personal messages and announcements not related to official business (though these types of e-mail may contain evidence or historical material, which then should be retained)
- Information-only copies or extracts of document distributed for convenience of reference
- Published reference materials
- Uncirculated preliminary drafts of documents
- Copies of inter- or intra-agency memoranda, bulletins or directions of a general information and non-continuing nature.
- Announcements of social events, such as retirement parties or celebrations.
Instant Messaging Correspondence Retention and Destruction
Instant messaging files may be saved with logging function of instant messaging, or copied into a file and saved. To the extent that these files are saved and/or subsequently destroyed, the same retention criteria apply to instant messenger files as to e-mail, as described above.
Encrypted communications of confidential information should be stored in a manner consistent with College policy, but in general, information retained for records purposes should be stored in a decrypted format unless it is confidential personnel, business, or protected educational or health information. Please check with the information resources through the help desk to obtain the appropriate licensed encryption software, if needed.
Recovering Deleted E-mail via Backup Media
While information resources creates backups of both websites and e-mail as a part of normal disaster recovery strategies, such back-ups are regularly overwritten and are not useful for records retention purposes. Backup tapes will only be accessed for document retrieval in response to a bona fide emergency as identified by the college president, the vice-president of administrative services and/or his/her designee, or as required by law.
Website Retention Requirements
Because some college websites can contain and/or generate public records as defined by law, archives of websites must often be retained for the period established by approved retention schedules, as determined by supervisors of units maintaining websites. Archived records of websites must be able to meet any legal obligations and must be able to provide evidence of present and past positions, advice, guidance, transactions or instruction on any particular matter throughout the retention period.
Full backups of websites on appropriate storable media may be used to create archival copies of web content. Such website records may also document both the structure and the public face of Bellevue College and—thus having historical value—may need to be transferred to the State Archives at the end of their retention period.
Responsibilities of Units with College Websites
Unit supervisors and individual employees must work with the college records officer to inventory and include unit web content when meeting retention schedules. As needed, units will develop their own procedures for meeting these requirements, but must also comply with the following:
- Decisions regarding which individual websites must be retained need to be made by the campus unit responsible for the site, and must be based on the content of the particular website. Units generating public records with or through websites should inventory these sites and include electronic records of them when conforming to their records retention schedule.
Violation of any of the provisions of this, or any Bellevue College IT policy, standard or procedure will be dealt with immediately and may result in disciplinary review. In such a review, the full range of disciplinary sanctions is available, including:
- Permanent loss of computer use privileges;
- Denial of future access to Bellevue College IT resources;
- Disciplinary action – any disciplinary action will be taken in accordance with appropriate procedures as established by the vice president of human resources (for employees) or the dean of student success (for students);
- Dismissal from the college; and/or
- Legal action.
Those users who misuse or abuse any computing or network resource may have their login accounts closed and access to the systems immediately terminated. Some violations may also constitute a state, local or federal criminal offense.
RELEVANT LAWS AND OTHER RESOURCES
- RCW 40.14
Revisions 1/11/2005; 5/10/2005; 5/21/2009, 8/31/2010, 11/30/2010; 9/24/2012