Record Destruction Policy

No. 801.2        
SECTION:  OPERATIONS
TITLE:  RECORD DESTRUCTION POLICY
ADOPTED:  December 2, 2008
REVISED:   

Purpose:  The proper disposal of information and data is important to minimize the use of valuable space, promote efficiency, assist in the day-to-day operations of Waynesboro Area School District, reduce the cost of storage of unneeded records, and reduce the risk of identity theft and/or breaches of privacy, computer fraud and related harms.  The School District employees must take reasonable measures to protect against unauthorized access to or use of records and information/data, and properly dispose of paper and electronic records, information and data.

Authority:  The within Records Destruction Policy has been formulated and approved by the Board of  School Directors. 

Delegation of Responsibility:  The Assistant Superintendent is responsible for the destruction of the School District records.  Delegation of responsibilities may be made by the Assistant Superintendent if clear guidance is provided to those with delegated responsibility while maintaining the ultimate authority to enforce this policy.

The Assistant Superintendent must use due diligence when hiring a document destruction contractor to dispose of material.  Due diligence could include (a) reviewing an independent audit of a disposal company’s operations and/or compliance with various defined destruction laws; (b) obtaining information about the disposal company from references; (c) requiring that the disposal company be certified by a recognized trade association; and (d) reviewing and evaluating the disposal company’s information security policies and/or procedures.

Guidelines:

Destruction

  • Destruction of all paper and electronic records must be by shredding, erasing, or otherwise modifying the information of the record to make the record unreadable, undecipherable or nonreconstructable through generally available means.  Other means include, but are not limited to, burning or pulverizing the records.  Information that is stored electronically must be made irretrievable before disposal. 
Records include discarding and abandoning information, as well as the sale, donation, and/or transfer of computers or other media where that information is stored.
  • Records must be destroyed within seven (7) days of the period designated in the Waynesboro Area School District Retention Schedule, unless an exception is granted by the Assistant Superintendent, or a litigation hold is relevant.
  • Destruction of the records (original and copies) may not occur without the approval of the Assistant Superintendent.
  • Electronic records that are retained must be retained in a preserved record-keeping system along with the transmission data.  In this case, e-mail messages in users mailboxes have little or no continued value and may be deleted.  The records in the preserved record-keeping system are governed by this policy and the School District Record Retention Policy and Schedule.
Training
Training employees to ensure compliance with this policy, and the proper disposal methods for information, data, media and hardware is necessary.

Litigation Hold
When the School District has been given notice that a legal action is either pending or imminent or a government investigation will occur, destruction of records (documents) must be suspended immediately.  Notice could occur before the filing of a Complaint, and assumes that the School District is previously aware of an incident or event that is subject to a suit.

Groups or classes of records must be destroyed in the ordinary course of business under the approved School District Records Retention Policy and Schedule, which is designed to meet the legitimate needs of the School District.  Selective destruction of records (documents) in anticipation of litigation is forbidden.

The Assistant Superintendent must be made aware of events or incidents that are likely to lead to legal action.  Counsel must be notified immediately.  Counsel will be responsible for evaluating the defenses available to the School District, identifying the records (documents) that may be relevant to a legal action, and responding to the suspension of the retention and destruction policies and schedule.

Consequences for Violation
Employees must be aware that violations of this policy may result in a variety of  disciplinary actions, including but not limited to, warnings, loss of privileges, position reassignment, oral and written reprimands, suspensions (with or without pay), dismissals and/or legal proceedings.

Violations of this policy may be reported to appropriate legal authorities, whether local, state, or federal law enforcement.  The School District will cooperate to the extent legally required with authorities in such investigations.
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