TITLE: RECORD RETENTION POLICY
ADOPTED: December 2, 2008
It is the policy of the Waynesboro Area School District that its
records, including both paper and electronic, be retained only as long
as determined necessary to meet legal, audit and management
requirements. In each case, the official retention periods shall be as
short as possible in order to minimize the use of valuable space,
promote efficiency, assist in the day-to-day operations of the School
District, and reduce the cost of storage for unneeded records inventory.
Authority: The within Records Retention Policy and Schedule has been formulated and approved by the Board of School Directors.
Delegation of Responsibility:
This Record Retention Policy and Schedule shall be under the day-to-day
supervision of the Assistant Superintendent, who may delegate
responsibilities to others while maintaining the ultimate authority to
enforce the Policy and Schedule.
will be provided a copy of the Records Retention Policy and Schedule
and periodically receive training on how it should be applied.
Litigation hold requirements must be a predominant topic in the training
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.
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.
Assistant Superintendent will be responsible for interpreting any
portions of this Policy statement or the School District Records
Retention Schedule as they may apply to specific situations. Any
communication involving specific records retention requirements should
be checked against the School District’s required ethical conduct.
for exceptions from this Policy should be submitted to the Assistant
Superintendent. In order to obtain an exception from this Policy, there
must be a program that will assure compliance with the basic objectives
stated above, at least as effectively as the School District’s Records
The Assistant Superintendent
and Administrative Team must review this Policy and the Records
Retention Schedule annually. Suggested changes should be submitted to
the Superintendent. Changes in the Records Retention Schedule made
necessary by changes or addition to the law must be communicated
directly by the Assistant Superintendent to the Superintendent who must
cause appropriate changes to be made in the Records Retention Policy and
The Administrative Team is responsible for
auditing the existence and content of the written records retention
program and schedule. The Assistant Superintendent is responsible for
auditing the actual implementation of the Policy and Schedule.
School District may hire an outside party to conduct an audit on
compliance with this Record Retention Policy and Schedule and prepare a
written audit report.
storage is an important consideration. Documents must not only be
preserved, they must be reasonably accessible. A storage system should
permit the necessary records to be easily located, managed, searched,
retrieved, and produced.
Storage is a critical consideration in
responding to subpoenas, discovery requests, investigations, regulatory
requests, educational and business needs. Accessibility can also
facilitate the document destruction component of the records retention
Security of the records is critical for confidential
records, particularly records pertaining to some transactions, financial
and tax records; employee records such as personnel files, medical
records, compensation records and insurance forms; student records; and
government records designated as confidential and having restricted
accessibility and protected privacy.
Preservation is an important
storage consideration. A proper environment conducive to maintaining
the integrity of the records is critical. This includes, but is not
limited to, secure software, electronic security protections, acid-free
folders, climate control, anti-magnetic interference, and fire
protection. Off-site storage of vital records is permitted.
Anti-virus, anti-spyware, anti-spam, and other software should be
maintained and updated regularly.
Document Retention Program seeks to identify and preserve documents for
disaster recovery where the informational value to the School District
is so great, and the consequence of loss is potentially so severe to the
continuity of the School District, that special protection is
warranted. Records that qualify as disaster recovery records are:
- Legal, financial, tax and organizational status records;
- Obligations to employees, vendors, and students;
- Ownership of assets and inventory;
- Intellectual property and achievements not recognized elsewhere; and information on critical decision-making.
that have value beyond their original purpose because they document
significant business activities, or services should be safeguarded as a
permanent resource. The following considerations should apply to the
preservation of records:
Records Retention Due to Pending Litigation
- An archival collection should be
prepared that includes, among other things, the minute books, each
annual auditor’s report, each annual financial report, trademarks,
copyrights, deeds, financial records, and photographs.
- Special consideration should be made to evaluate whether in-school or outside protection is best.
- Loaned or gifted archival materials to other sources should be maintained by the Assistant Superintendent.
School District records that need to be retained due to pending
litigation or government investigations must be reviewed frequently.
Contact must be made with the Assistant Superintendent to verify
possession of the most current list of records that should be considered
protected (i.e. not to be destroyed) due to pending litigation or in
litigation or subject to government investigation. Be aware that the
court considers all recorded information as a record regardless of the
medium of storage of the information. All records that relate to
pending litigation or regulatory proceedings must be retained during the
pending litigation and/or proceeding.
disposal or destruction of paper and electronic records is required.
Records must be destroyed by shredding, erasing, or otherwise modifying
the information of the record to make the record unreadable,
undecipherable or nonreconstructable through generally available means.
See Destruction Policy.