586.0 Document Retention and Destruction

P-586.0

The College is subject to various federal and state laws and guidelines affecting the retention and destruction of records. Each College department is responsible for its own compliance with record retention requirements in accordance with federal and state guidelines that are applicable to the department.

Concerns that the destruction of particular records may be illegal and improper should be immediately directed to the President’s Office.

Should any of the following occur, destruction of relevant records shall cease:

• An investigation by the College;
• An investigation by outside authorities;
• The filing of a claim involving the College with a governmental agency;
• The filing of a lawsuit involving the College.

Document destruction shall not resume until authorized by the President’s Office.

 Pr-586.1

Email
The State of Missouri considers email to be a format, not a record series.  Retention of emails is based on the content of the email.  Each email user has responsibility for sorting personal from work-related messages and retaining College records as outlined in Pr-586.2.  Only the official copy of a record, including email records, must be maintained within the recordkeeping system.   Additional copies are considered convenience copies and, as such, are non-records.  Convenience copies should be disposed of when they no longer serve a purpose.   Storage of official electronic records on a PC hard drive is not an acceptable storage location, and must not occur.  Email that does not meet the definition of a record is considered a non-record and should not be retained.

To preserve an email as a record, it is necessary to retain the email in its original electronic form along with all attachments.  Electronic mail that is digitally signed must be retained electronically if the signature is important to the legal status or business usefulness of the document.

To destroy an email as a record, it is necessary to delete both the message and its attachment that may be stored in a separate location.

The Missouri Secretary of State’s Office defines General Email records as those that pertain to routine college matters, but do not contain significant information about office policies or programs, and states that retention for these types of email is one (1) year.  As such, the Email Inboxes of College employees will be preserved one (1) year, with any email older than one (1) year being automatically deleted. The Deleted Items folder within the College’s email system will automatically delete items that are older than thirty (30) days.  To preserve records for more than one (1) year, College employees must create folders within the College email system and, create a retention schedule within the folder, and then move any emails to be preserved beyond one (1) year from the Inbox to that folder.

Pr-586.2

The College’s record retention rules are in accordance with the Community College Records Manual provided by the Missouri Secretary of State. It can be accessed at http://www.sos.mo.gov/archives/localrecs/schedules/college.asp.

Disposition of Emails
Every manager is responsible for ensuring that employees are properly trained in appropriate record evaluation and retention processes consistent with the Records Disposition Schedule defined for community colleges by the State of Missouri.  Processes should be documented and applied consistently to ensure that required records are readily available, and obsolete records are destroyed promptly.

 Pr-586.3  How to Retain Electronic Records at SCC

Data owners must set up corresponding folders within Outlook to house those emails and attachments that must be retained.  A folder should be created directly under the user’s Name, or the Inbox in Outlook – never under the Archives section.  Once that is done, the Properties of the folder can be set to auto-archive emails placed there for the appropriate life cycle of the document (as mandated by Pr-586.2), and automatically delete records after the appropriate time period has passed.  To view the set up process, click here.

Employees must use the folders process described above to retain records subject to requirements under Pr-586.2.  Archiving email must not be used for record retention because IT destroys archived records after 1 year.

Preservation of Electronic Records other than Email
Electronic records that are stored on network drives rather than in the email system do not have a feature which allows auto archiving or deletion after a prescribed period.  Therefore, users must both collect those data which are pertinent to their particular area, as well as delete them when those data become obsolete, subject to Pr-586.2 

Network Computing backs up Home Directories, Shared Directories, and other data housed on the College’s data storage network.  Network Computing does not back up PC hard drives.  Data stored on PC hard drives, if lost, cannot be recovered.

The IT Department creates backup of data at intervals that will be specified in a “Backup and Restore Policy” that can be viewed at:  http://www.stchas.edu/about-scc/board-policies/800/

 D – 586.1

Record
A record is defined as any documentation created or received and used in the conduct of official College business regardless of the physical format or media in which the documentation is conveyed.  This definition includes records created, used, and maintained in electronic form.  Substantive email messages that document official College business and have future consequences which may be needed for future decisions or reports, or that are part of an audit trail that documents and clarifies a decision, should be maintained according to the approved Records Disposition Schedule defined for community colleges by the State of Missouri.  See http://www.sos.mo.gov/archives/localrecs/schedules/college.asp.   This schedule is based on federal and state mandates, record surveys, business needs, and general knowledge as to how long records should be kept. 

 Examples:

  • Policies and directives
  • Correspondence related to official business
  • Any document that initiates, authorizes, or completes a business transaction
  • Program development and review memoranda
  • Reports of official activities
  • Authorization of expenditures
  • Agreement negotiations and finalization
 D-586.2

Non-record with an Official Context
A non-record is recorded information or a message that may have an official context but is not a part of a business transaction, and has only transitory value beyond reference.  Non-records should not be retained within a recordkeeping system and do not require retention scheduling or destruction authorization or reporting.  They should be destroyed immediately after they are no longer useful.

Examples:

  • Announcements, invitations, and responses
  • “for your information” copies on which no action is taken
  • Informational requests and responses
  • Meeting notices
  • Unsolicited resumes and inquiries
  • Blank forms

Email messages that do not relate to College business are non-records and should be disposed of immediately.

Policy Code Key
P Policy PR Procedure D Definition S Supplement

Content Owner: Donna Davis — ddavis@stchas.edu
Page Updated by: Jessica Trimborn
Date Issued:
Date Revised: 01/17/2012