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Policy 3050 - Records Management

The purpose of this records management policy is to establish systemwide standards and procedures as well as provide guidance to schools and administrative offices regarding the maintenance, retention and disposition of records.

Policy Document

I. Policy Statement

The Board of Education of Howard County is committed to managing and maintaining a uniform, systemwide records management program that communicates expectations regarding the creation, maintenance, retention and disposition of Howard County Public School System (HCPSS) records. The Board recognizes that effective records management provides significant benefits to HCPSS, including the efficient and timely retrieval of records, the preservation of historical and vital records, the promotion of transparency, and the protection of the legal rights of students, staff, citizens and the government.

The records management program is regulated by this policy, by the implementation procedures, as well as the Records and Information Disposition Schedules (RIDS). The RIDS set the Board’s classification and retention standards for HCPSS records.

II. Purpose

The purpose of this records management policy is to establish systemwide standards and procedures as well as provide guidance to schools and administrative offices regarding the maintenance, retention and disposition of records.

III. Definitions

Within the context of this policy, the following definitions apply:

  1. Administrative Record – A record that documents business decisions and that documents compliance with regulations or statutes (such as, but not limited to, site plans, building permits and drawings, official meeting agendas and minutes, circulars, and annual reports).

  2. Certificate of Records Destruction – Formal assertion, in writing, that signifies records have been destroyed.

  3. Confidential Record – An HCPSS record not intended to be shared with unauthorized users.

  4. Destruction – The disposal of records through shredding, deletion or other methods once the record has passed its retention period.

  5. Disposition – Processes associated with implementing records retention, destruction or transfer as documented in RIDS.

  6. Documentary Material – Any materials in which information is recorded.

  7. Fiscal Record – A record that documents financial decisions and practices, including but not limited to, procurement documents, contracts, licenses, general ledgers, and audit reports.

  8. Historical Record – An HCPSS record that documents the source, development, structure and procedures over time that are considered by rule, school system officials, or the State Archivist to have administrative, fiscal, legal or other archival value. Examples include, but are not limited to, policies, organizational charts, Board meeting minutes, and strategic plans.

  9. Inactive Record – Documentary material that is no longer needed for the conduct of business.

  10. Legal Record – A record that documents business decisions or procedures that relate to compliance with law or are specific to potential or actual litigation, including but not limited to, evidence of HCPSS’s legal rights or obligations to students and employees.

  11. Litigation Hold – A process used by an organization to preserve all records relevant to potential or actual litigation.

  12. Preservation – The act of protecting records against damage or deterioration.

  13. Public Record – Any documentary material that is not considered confidential and generally pertains to the conduct of the HCPSS.

  14. Record – Any material created or received by the Board, an HCPSS school or office, or a school system official in connection with the transaction of HCPSS business. A record includes any form of documentary material, including but not limited to paper documents, electronic documents, microfilm, drawings, maps, pictures and any other documentary material in any format, in which business information is created or maintained.

  15. Record Series – A group of files or documents kept together because they relate to a particular subject or function, result from the same activity, document a specific type of transaction, take a particular physical form, or are related through their creation, receipt, maintenance or use.

  16. Records and Information Disposition Schedules (RIDS) – The official document that identifies all HCPSS records and specifies which records should be preserved permanently and which are deemed temporary and can be destroyed after a certain period of time because they are obsolete or superseded. The RIDS provide ongoing authorization for the transfer of HCPSS records from offices and schools to storage facilities, along with the destruction instructions for obsolete records and the preservation of historical and/or vital records.

  17. Records Custodian – A school system official responsible for maintaining a public record and adhering to maintenance and disposition, consistent with state and federal requirements.

  18. Records Liaisons – School system officials selected to be the primary contacts for the Records Officer (RO) and who coordinate records management activities for their offices, departments or schools.

  19. Records Officer (RO) – The person designated by the Superintendent whose responsibilities include, but are not limited to, coordinating the HCPSS records management program and monitoring records management activities.

  20. Retention Period – The duration of time for which a record series will be retained before final disposition. The final disposition is based upon the administrative, legal, fiscal, and historical value of the records.

  21. School System Official – A person employed by the HCPSS or a person or organization contracted by the HCPSS to perform a special task (such as an attorney, auditor, school resource officer, medical consultant, or therapist).

  22. Vital Record – A record in any format containing information that is:

    1. Essential to the operations and/or survival of the HCPSS in the event of a natural or other disaster;

    2. Necessary to recreate the HCPSS’ legal and financial position; and

    3. Necessary to preserve its interests and rights of the Board members, school system officials and students.

IV. Standards

  1. All school system officials are responsible for HCPSS records in their custody which are the property of the HCPSS.

  2. HCPSS will manage and maintain a records management program that aligns with state and federal laws and regulations.

  3. To manage and maintain a records management program, HCPSS will:

    1. Establish uniform, systemwide guidance and procedures for the creation, maintenance, use and disposition of HCPSS records;

    2. Provide information to support decision making and to respond to inquiries from internal and external sources in a timely manner;

    3. Develop and maintain state approved RIDS in accordance with state and federal laws. This includes changes in the legal retention of records, new record series being created, and other changes that may affect the retention of HCPSS records;

    4. Identify, preserve, and protect vital records necessary to continue operations in an emergency;

    5. Identify and transfer any records in the custody of school system officials to appropriate Records Custodians, or the person assuming responsibility for the work when individuals have a change in employment status or role in the HCPSS;

    6. Provide guidance and procedures for storing inactive records in off-site records facilities;

    7. Provide guidance and procedures for the destruction of inactive records that have met their retention and have no archival value; and

    8. Require annual records management training for all HCPSS school system official as appropriate to their responsibilities.

  4. All HCPSS Board members and school system officials will comply with the RIDS as their systemwide tool to identify and manage records created and maintained by the HCPSS.

  5. HCPSS offices and departments will identify and protect HCPSS vital records.

  6. HCPSS Records Custodians will complete an Off-site Transfer Request or Retrieval Form and obtain approval from the RO prior to transferring or receiving records from an off-site storage facility.

  7. HCPSS offices, departments and schools will notify the Records Management Office (RMO) for any upcoming office/department relocations, to start the planning process to transfer, relocate and disposition records well ahead of time.

  8. All HCPSS Board members and school system officials will follow procedures for off-site storage, transfer, and retrieval of HCPSS records.

  9. School system officials will follow Board policy and state law to allow for efficient compliance and timely responses to any requests for records pursuant to the Maryland Public Information Act (MPIA), litigation hold notices, internal or external investigations, court orders, or other requests for HCPSS records.

  10. HCPSS Board members and school system officials who fail to maintain the confidentiality of confidential records are subject to disciplinary action.

V. Responsibilities

  1. The Superintendent will designate an RO to serve as liaison to the Howard County Records Management Division and to the Maryland State Archives.

  2. The Superintendent/Designee will develop and administer protocols related to the HCPSS records management program.

  3. The Superintendent/Designee will initiate appropriate action to recover records removed unlawfully or without authorization.

  4. The RO will serve as the primary records management contact for all of the HCPSS.

  5. The RO will provide oversight, leadership and management of the HCPSS records management activities in coordination with HCPSS officials, including records management training.

  6. The RO will develop, maintain, and update the RIDS in accordance with state and federal laws for HCPSS records.

  7. The RO will submit a Certificate of Records Destruction Form to the Maryland State Archivist to allow the disposal of authorized records that have met their retention period.

  8. Each HCPSS office, school and department will identify an individual to serve as Records Liaison. The Records Liaison will assist the RO in the coordination of records management activities.

  9. All HCPSS Board members and school system officials will:

    1. Adhere to the records management program requirements and RIDS concerning the HCPSS records they create, use, maintain and destroy;

    2. Adhere to the RIDS for records retention, unless a specific record is subject to litigation hold as defined, has been subpoenaed, or is the subject of a public information request pursuant to the MPIA;

    3. Contact the HCPSS RO if records retention requirements have changed and need to be updated in the RIDS;

    4. Report any actual or threatened unlawful removal, defacing, alteration or destruction of records to the Superintendent/Designee; and

    5. Follow the systemwide procedures for the disposition of HCPSS records in accordance with the RIDS and the Maryland Student Records Manual.

VI. Delegation of Authority

The Superintendent is authorized to develop all necessary and appropriate procedures to implement and monitor this policy.

VII. References

  • Family Educational Rights and Privacy Act (FERPA)

  • Health Insurance Portability and Accountability Act (HIPAA)

  • Maryland Public Information Act, Annotated Code of Maryland, General Provisions Article, Title 4

  • COMAR 14.18.02 Records Retention and Disposition Schedules

C. Relevant Data Sources

D. Other

  • ARMA Glossary

  • Certificate of Records Destruction Form

  • HCPSS Box List Form

  • HCPSS Off-Site Transfer Request or Retrieval Form

  • HCPSS Records and Information Disposition Schedules (RIDS)

  • HCPSS Records Condition Assessment Form

  • HCPSS Request to Transfer Form

  • HCPSS Transfer Inventory Worksheet

  • Maryland Student Records Systems Manual

VIII. History

ADOPTED: October 4, 2011

REVIEWED:

MODIFIED: May 9, 2013

REVISED: June 8, 2017

EFFECTIVE: July 1, 2017