School District of Springfield Township
                                                                                                Administrative Rule

            800-AR.  RECORDS MANAGEMENT

The School District receives and generates volumes of information in both electronic form and hard copy.  Not all information received constitutes a “record” that the District will retain for an extended period.  The various departments of the School District have set forth guidelines to assist employees in determining what information/documents/data should be retained and what information/documents/data need not be retained and creating guidelines for appropriate uses of particular means of communication.  The purpose of this Regulation is to clarify how records will be retained and destroyed. 

For the purposes of this regulation “reasonably accessible” shall mean that the information is available to authorized District personnel in a manner and format that is generally indexed or cataloged or is readily searchable for ease of reference.

A.        Retention, Storage and Destruction of Records

The Records Retention Chart attached hereto and incorporated herein sets for the manner of record retention, the retention period and the manner of disposal of various types of District records.  Any records not specifically identified on the chart shall be referred to the appropriate District-level administrator for review.

B.        Archiving/Purging of Electronic Information that Is Not Retained Electronically

Electronic information in the form of email and associated attachments created on the email server, even if subsequently deleted from the email server, will be archived on a separate hardware device automatically as a function of the archiving software.

Deleted electronically stored information will be automatically purged from the system after one year.  Such purging will be an automatic function of the software.  Deleted information shall not be considered reasonably accessible.

C.        Legal Hold Procedures

When the school District believes that a matter is likely to lead to litigation by or against the School District, a “legal hold” will be placed on such relevant matters, requiring that documents and data, including electronic data, relating to the matter, incident, person or entity, be retained by the School District until such time as the legal hold is lifted. 

            1.         Responsibility

Because of the variety of matters that could lead to litigation by or against the School District, the responsibility to identify such matters rests with all District employees. 

            2.         Procedure

When a School District employee has reason to believe that an incident may give rise to potential litigation, that employee shall:

1.         advise immediate supervisor of the incident and prepare a written report stating what the individual saw and/or heard, the names of the people and entities involved and the names of any witnesses; and

2.         preserve all documents, notes, data and information regarding the matter including, but not limited to email communications, notes, letters and voice mail messages, pending a determination regarding whether a legal hold is necessary.

The written report must then be forwarded to the Superintendent or the Superintendent’s designee, who, in consultation with the Solicitor, will determine whether to place a legal hold on documents and data relevant to the incident(s).  If a legal hold is implemented, then the Director of Technology or Director of Technology’s designee shall make all reasonable efforts to retrieve and maintain any archived electronic data before that data is purged and to prevent further potentially relevant information from being purged or deleted. 

The Superintendent or the Superintendent’s designee will advise all School District employees involved with the incident(s) or matter(s) at issue of the legal hold and advise them to retain all documents, notes, data and information regarding the matter including, but not limited to email communications, notes, letters and voice mail messages pending further notice. 

3.         Release of Legal Hold

If a matter is settled or resolved or the relevant statute of limitations period has expired or it otherwise becomes apparent that litigation is not likely to arise, then the Superintendent or the Superintendent’s designee, in connection with the Solicitor, will release the legal hold and the retained and stored documents may be disposed of in accordance with the ordinary document retention policies of the District.

D.        Destruction

Records shall be purged in accordance with the document retention schedule attached hereto.
           
E.         Responsibility

Periodically, the Director of Technology and the Business Administrator or designees shall perform audits to ensure that (1) information being retained in manual form is being retained in a reasonably accessible manner, (2) information being retained in electronic form is being retained in a reasonably accessible manner, (3) confidential information is being maintained in a secure manner and (4) electronic and manual records are being retained and purged in accordance with this Regulation.