School records management 101: Deciding the what, when and how

School districts generate a variety of paper and electronic records on a daily basis that must be managed on a routine basis. Office administrators and other personnel have the responsibility to safeguard records and to maintain them in appropriate filing structures and locations. This ensures easy retrieval, in addition to meeting state requirements for document retention for both public and confidential records.

The benefits of having a good record-keeping process are:

• The school district is able to fulfill its mission and obligation to its students, families and employees by having appropriate documentation of all public school business.
• Cost-effective use of organizational resources required to generate, maintain and retain vast amounts of information.
• Promoting open and accountable public services.
• Student Educational and Health Records are safeguarded in accordance with applicable laws.

All public records generated during the normal course of school business are property of the State of Washington under (RCW 40.14.020).

For the purpose of determining whether to keep or to shred a record that falls under the scope of a public record, two criteria must be met (RCW 40.14.010):

1. The record must be made or received in connection with the transaction of public business.
2. Regardless of what format it is in (paper, digital, tape, disc, film, microfiche, email, etc.).

If you use your personal computer, phone or other device to conduct school district business, you are accessing and may be creating a public record.

Improper destruction, alteration, or falsification of public records can result in a $5,000 fine and is considered a Class B Felony punishable by imprisonment up to ten years, or both. (RCW 40.16.020).

How do I know what to keep?
State school districts and Educational Service Districts (ESD) in Washington typically utilize two retention schedules that the state publishes and updates on a frequent basis:

Local Government Retention Schedule (CORE) which covers typical “bucket” retention items generated by most all governmental agencies related to: Business transactions, HR, Payroll, Worker’s Compensation, Benefits and Health;

Public Schools (K-12) Retention Schedule which covers retention items that are specific or unique to public schools such as student records containing transcripts, grades, assessments, employee and student misconduct, permanent records and cumulative folders.

Retention schedules contain groups of records by subject that are assigned a specific number, a description and a retention timeframe. Records are also classified as “Essential for Disaster Recovery” or “Archival” indicating that the record may have longer retention or require special handling and preservation.

Federal Retention Schedules may apply for specific grant funded programs and projects or to support expenditures for certain district operations.

Things to consider when managing your school or department’s records
There are basically two options and one exception for managing your records from creation to the end-of-life cycle. When it comes time to purge your files, consider the following:

1. Destroy records once the retention period has been met

(Washington State records retention schedules; Chapter 40.14 RCW Preservation and Destruction of Public Records; Chapter 434-662 WAC Preservation of Electronic Records; and Chapter 434-663 WAC Imaging Systems, Standards for Accuracy and Durability).

• Electronic records created in a system must be maintained in that system throughout the retention period before they can be deleted.
• Printing out and retaining a copy of the electronic record is NOT a substitute for the electronic record (WAC434.662.040).
• Paper records can be scanned and uploaded to a digital records format in place of the paper format using the Scan & Toss approach. To be eligible for Scan & Toss the following must be true:

A. You must determine whether the records are designated as “Archival” or “Non-Archival.”
B. “Archival” records must be appraised by the state before the district can destroy them; “Non-Archival” records may be destroyed after verification of successful scanning and upload to a digital format.

2. Transfer the records for review and archiving at the district or state level

• Some records with long retention periods such as student permanent records relating to attendance histories, academic summaries, and final transcripts which are maintained in various formats including cards, paper, microfiche and digital format.
• Records with historical value that tell a story about a school or district are retained for special events and reference.
• Records that contain information that would be essential in the event of a disaster.
• Records of a legal nature or that document certain benefits, injury claims, or mitigate dangerous situations.

3. Legal Holds

• There are times when even though a record has met its retention period, that it may need to be kept longer in situations where there has been litigation hold requiring the district to keep certain records until a resolution has been made.
• In cases of an open public records request where documents exist that are beyond their retention period but have been the subject of a public records request and cannot be destroyed until a period of time after the request has been fulfilled

Best Practice when it comes to shredding documents
Never destroy any record without pointing to a retention number authorizing you to do so. When in doubt, consult your district’s Vital Records Manager first.

For helpful tips, guidance, and information consult the District’s new website at Records Management & Retention or contact David LaGarde, Digital Records Supervisor at dlagarde@osd.wednet.edu, or submit a help request to help-records@osd.wednet.edu.