COLORADO COMMUNITY COLLEGE SYSTEM
SYSTEM PRESIDENT’S PROCEDURE

Electronic Communications Management and Retention Procedures


SP 3-125d

EFFECTIVE: June 14, 2009

REFERENCE: BP 3-125, Electronic Communication Policy

APPROVED:

/ Nancy J. McCallin /
S/ Nancy J. McCallin, Ph.D.
System President

Scope

This procedure applies to all faculty, staff, and students and other authorized persons with access to electronic communications within the CCCS System.

Basis

BP 3-125 authorizes the System President to adopt any needed procedures to implement the Electronic Communication Policy. The purpose of this policy is to regulate retention and destruction of all electronic communications.

Definitions

Electronic Communications (also referred to as “e-communications”) includes, but is not limited to, the use of CCCS , electronic mail (aka “email”), telephones, hand held portable e-communication devices, voice mail, pagers, modems, fax transmissions, video conference, multimedia, and all other computer related communications provided by CCCS. Facilities technologies and television systems are not included as part of this procedure.

Electronic Mail (also referred to as “email”) is defined as any message sent or received through or stored on CCCS’ Central System Servers. Such email may include, but is not limited to, correspondence and attachments, calendar schedules, voice mail attachments that are forwarded from the recipient to someone else via the email system and forms submitted electronically.

Official Institutional Record is defined as the final form of a document, contract, correspondence or decision that is important to the business of the organization or a legal record of a contract, activity or decision. As such, it should be retained as a permanent record. These official records should be stored in archive folders specific for this purpose and tagged for the appropriate retention period.

Process or Decision-making Record refers to emails and attached document(s) that demonstrate the process of arriving at a decision or action. In this record, all the associated emails may be required to be retained and should be stored in archive folders specific for this purpose and tagged for the appropriate retention period.

Archive Folder is a folder set up within the archiving software for the specific purpose of storing certain types of emails and/or documents for a specific length of time. Archive folders may have individual or group access and can have varying attributes in terms of security, retention, access and content.

Transitory Communications is defined as casual and routine communications.

Purpose

Students, faculty, staff, and administration within CCCS rely significantly on electronic communications as a result of the business and operations of the Colleges. These communications document ideas and activities, help the College’s better serve their mission, assist management in its decision making and act as the archive of the College’s and surrounding community’s history with the College. These kinds of communications, like any vital resource, also have an intangible monetary value. Because of the tangible and intangible value of these records, it is critical that they be part of a comprehensive records management program that ensures all CCCS Records are properly and securely managed, replaceable, and disposed of, preserved and/or archived.

An electronic communications management program serves other purposes as well. It improves office efficiency, facilitates administrative access to inactive as well as active records, ensures the consistent maintenance of records, decreases operational costs, increases staff productivity and assists CCCS in meeting legal and regulatory standards. Obsolete records impede access to current records, pose a possible legal liability, and waste valuable space.

The purpose of this procedure is to:

  1. Outline CCCS’ requirements for its Electronic Communications Management Program, including Retention and Destruction schedules;
  2. Guidance on records creation and classifying documents into types;
  3. Establish retention and use practices;
  4. Provide for schedules of records retention and disposition; and
  5. Outline criteria for the conversion of retained or archived records to a different medium (e.g., email to hard copy).

This policy does not apply to systems and services not operated by CCCS.

Willful violations of the following policies may result in disciplinary action following normal Human Resources procedures and guidelines in consultation with the appropriate supervisor, which may result in actions up to and including termination and necessary legal action. Willful violations on the part of students would also be subject to the CCCS Student Disciplinary Procedures, SP 4-30.

Electronic Communications Management

Electronic communications management is a joint responsibility of the record creator and users. All CCCS employees who handle CCCS records are responsible for knowing and following laws (e.g., Public Records, FERPA, and Schedule 8-Higher Education Retention Schedule).

Records Management consists of 3 basic stages:

  1. Creation;
  2. Retention and Use; and
  3. Disposition

When a record is created, the creator should consider the following:

  1. Is the new record an Official Record?
  2. What is the type of data included in the record being created?
  3. How should the record be handled or stored?
  4. Do any laws or regulations dictate a specific retention period?
  5. Barring any legal/regulated retention period, when will the information on the record be no longer useful?

Based on the answers to these questions, the record creator shall decide whether the communication is:

  1. Official Institutional Record
  2. Process or Decision-making Record
  3. Transitory Communications

Neither the format of the record (e.g., memo, email, voice recording, etc…) nor the medium on which it resides (e.g., paper, electronic, audio, etc…) determines the classification. For example, email may be just as confidential as formal, typed letters.

Many records are created during normal administrative practices and are either for extremely short-term (transitory communications) or contain unimportant information. Additionally, many records are received from external resources (e.g., vendors) that have no significance to CCCS or its records needs and therefore retention of these materials is unnecessary.

The majority of administrative practice records will be considered transitory, which include, but are not limited to:

  1. Outlook calendars;
  2. Rough drafts of reports, contracts, correspondence, notes,
  3. Strings of emails;
  4. Routine email or telephone messages not including any data other than unclassified data;
  5. Communications determined to not have any historical value;
  6. Work procedures, office assignments, and work schedules;
  7. Personal email;

Records that are on the CCCS e-communications system and are already in the public domain and are available via a web site or published document such as mission statements, charters, constitutions, statutes, regulations, procedures, published directories, published reports, press releases, timetables, presentation material, and published course catalogs are considered transitory.

If there is any doubt about which category some communication is, please contact the appropriate staff at the College who oversee the content

Records Retention and Use

Records retention is a necessary tool for the administrative and business use within CCCS. How long a record is retained depends largely on legal, fiscal, and administrative requirements.

The retention periods prescribed in the Record Retention and Disposition Schedules are based on fiscal years (July 1st to June 30th). As a result some records may be retained slightly longer than their given retention period in order to complete the fiscal year’s records.

All CCCS employees will be held responsible for keeping and maintaining an organized e-communications system.

Employees shall maintain archive folders with the appropriate access and permission.

Employees are expected to transfer emails from their inbox to an .archive folder if after creation or receipt of the email, they deem it necessary to keep.

Due to the establishment of retention policies, the implementation of email archiving and concerns regarding E-discovery, employees are to use the Archive system and archive folders to retain emails and to comply with both retention and destruction policies. Employees are not to keep separate .pst folders, save emails to a hard drive or flash drive or to forward emails outside of the CCCS email system to avoid compliance with this policy. Employees are not to print paper copies of emails to be saved in physical files unless the printed emails are a part of the permanent record relating to a printed, physical document and to not have the printed email and the printed document together would adversely impact the business of the colleges or system.

Record Retention and Disposition Schedules

It is important that disposition of electronic records is performed on a timely basis as failure to do so can lead to unnecessary expenditure of resources and liability.

1. General Processes

Emails and any attachments not tagged for retention by moving into an archive folder will be deleted after 180 days.

Emails and any attachments tagged for retention by moving them into an archive folder with retention criteria shall be retained for the length of time associated with the archive folder. The retention time is based on the receipt or sent date of the email. Once the length of time has expired, the email and its attachments will be automatically deleted.

2. Specific Retention Periods and Processes

a. All Transitory Communication shall not be archived and should be deleted within the 180 day retention window outlined above

b. Process or Decision Making Records, as well as final correspondence and other electronic communications about administrative, academic or institutional decisions should be retained according to the determination of the creator or receiver for up to 3 or 5 years, depending on the position of the staff member and how important the email is, as outlined below:

i. CCCS Executive Staff, College Presidents, College Senior Staff, and any staff deemed necessary by the System President or College Presidents shall retain all final correspondence and any electronic communications about administrative, academic, or institutional decisions for 5 years.
ii. Otherwise, staff at the System Office and Colleges may retain electronic communications, for no longer than 3 years, except for

c. Official Decision Making Records, Official Institutional Records and appropriate supporting documents shall be retained permanently. Each college will determine the official owner of records pertaining to a specific area. If the Department authorizes that communication to be an Official Record of the College, they will maintain care, custody, and control of that record. All other copies of that record will be deemed process or decision making records or transitory.

3. Electronic Records involved in litigation, criminal, civil or audit investigations, and necessary for ongoing administrative purposes shall be retained. Employees involved with maintaining records pursuant to one of these exceptions shall coordinate with Human Resources, Legal and/or Information Technology staff on the proper procedures to follow.

Conversion of retained or archived records to a different medium
The purpose of these procedures is not to transfer electronic records into another medium. In general, electronic records should not be transferred with the intent to maintain process or decision-making records or transitory communications beyond the disposition date.

If an electronic record has been classified as official institutional record following the proper procedures discussed above and is required to legally exist beyond the disposition limit, the College may transfer the document into another medium using the standard practice followed at the institution.