COLORADO COMMUNITY COLLEGE SYSTEM
SYSTEM PROCEDURE

Electronic Communications and Records Management and Retention

SP 6-30a

APPROVED: May 12, 2009
EFFECTIVE: June 14, 2009
REVISED: December 13, 2023
RETITLED: December 13, 2023
RENUMBERED: December 13, 2023

REFERENCE(S): Board Policy (BP) 6-30, Electronic Communication and Technology Use

APPROVED:
/ Joseph Garcia /
Joseph A. Garcia, Chancellor

Application

This procedure applies to all employees, students, and authorized users within the Colorado Community College System, including its Colleges (CCCS or System), and all CCCS-owned and/or -supported electronic, network, and software systems.

Basis

BP 6-30 authorizes the Chancellor to adopt any needed procedures to implement the Electronic Communication and Technology Use policy. This procedure outlines regulations for electronic communication and records, and the retention and destruction of all electronic data.

Definitions

“Archive Folder” or “Archive Mailbox” is a designated location set up within the electronic mail or software system for the specific purpose of storing electronic mail and related data for a specific length of time. The Archive Folder/Mailbox may have individual or group access and can have varying attributes in terms of security, retention, access, and content.

“Electronic Communications” includes, but is not limited to, electronic mail, phone calls (and voice mail), fax transmissions, text messages and digital transmissions via messaging systems, video conferences and messages, social media, and any multimedia or computer-related communication.

“Electronic Mail” (also referred to as “email”) is any message sent or received by electronic means from one computer or electronic user to another via a network. Email includes, but is not limited to, attachments, calendar events, voice-mail attachments, and forms or documents submitted electronically.

“Electronic Records Management” (ERM) is the efficient and systematic control of the creation, receipt, maintenance, use, and disposition of records and data maintained for administrative, business, and institutional activities and transactions.

“Official Institutional Record” is a complete, final, and authorized document, contract, correspondence, meeting minutes, paper, photograph or video, publication, record, or report that is made, produced, executed, or received in connection with transactions and activities, establishing some official fact, policy, procedure, or institutional position or decision for use or conduct of CCCS administration, business, or educational service, regardless of physical form or characteristic. Official records should be stored in  designated locations, assigned the appropriate retention period, and, when necessary, retained as a permanent record.

“Process or Decision-Making Record” refers to, but is not limited to, any activity, document, function, record, or transaction produced in the course of everyday operations, that demonstrate the process of arriving at a decision or action. These records, and any associated attachments, may be required to be retained and should be stored in a designated location specific for this purpose and assigned the appropriate retention period.

“Transitory Communications and Documents” are casual and routine communications and documents created for short-term use, with no fiscal, historical, or legal value. Transitory data has no retention requirements and, unless associated with a legal hold, may be deleted at any time.

Procedure

Employees, students, and authorized users within CCCS significantly rely on electronic communications and records in the course of everyday business and operations. These communications and records (electronic data) document ideas and activities, help the System better serve their mission, assist management in its decision-making, and act as the historical data of CCCS. This electronic data has an intangible value and may have legal retention requirements. It is critical that CCCS electronic data be part of a comprehensive records management system that ensures all CCCS Records are properly and securely managed, replaceable, disposed of, preserved/retained, and/or archived.

An electronic records management system improves office efficiency, facilitates administrative access to active and inactive records, ensures the consistent maintenance of data, mitigates risk, decreases operational costs, increases staff productivity, and assists CCCS in meeting legal and regulatory compliance. Obsolete records impede access to current records, pose possible legal liability, and waste valuable space. CCCS Information Technology (IT) has an established records management system to ensure all departments and Colleges follow proper electronic data protocols.

The purpose of this procedure is to:

• Outline CCCS’ requirements for Electronic Records Management, including disposition (retention, destruction, and conversion).
• Give guidance on records creation and classification into types.
• Establish retention and use best-practices, and destruction timelines.
• Outline criteria for the conversion of retained or archived records to a different medium (e.g., email to hard copy or document to archival storage).

This procedure applies to systems and services operated, owned, or supported by CCCS. All electronic communications and records systems provided by CCCS are the property of CCCS. All systems, including, but not limited to, emails, digital messages, voicemail, and all electronic documents, may be monitored for compliance and system maintenance purposes and may be subject to Open Records requests.

Violations of this procedure may result in disciplinary action including reprimand, loss of access, suspension, or termination.

Electronic Communications and Records Management:

Electronic communications and records (electronic data) management is a joint responsibility of the record creator, users, and CCCS Information Technology. All CCCS employees, students, and authorized users who handle electronic data are responsible for knowing and complying with applicable laws, regulations, and guidelines (e.g., Public Records, FERPA, Schedule 8-Higher Education Retention Schedule, and System procedures).

Records Management and Disposition consists of three (3) basic stages:

1. Creation
2. Retention and Use
3. Destruction or Conversion

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

• Is the new record an Official Record?
• What type of data is included in the record?
• How should the record be handled or stored?
• Do any laws or regulations dictate a specific retention period?
• Barring any legal or regulated retention period, when will the information in the record no longer be useful?

Based on the answers to these questions, the creator shall decide whether the record type is a(n):

• Official Institutional Record
• Process or Decision-Making Record
• Transitory Communication or Document

Neither the format of the record (e.g., document, email, voice recording, etc.) nor the medium on which it resides (e.g., paper, digital, audio, etc.) determines the classification. For example, an email may be just as confidential or critical as a formal, typed letter.

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

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

• Electronic and hard-copy calendars;
• Rough drafts of reports, contracts, correspondence, and documents;
• Routine electronic communications, digital or telephone messages containing unclassified data;
• Data determined to not have historical value;
• General work or institutional procedures, office assignments, and schedules; or
• Personal electronic data

Records that are on CCCS systems or networks and are in the public domain, available via a website or published document, such as mission statements, charters, constitutions, statutes, regulations, procedures, published directories, reports, press releases, timetables, presentation materials, and published course catalogs are considered transitory.

If there is any doubt about which category a communication or record is, please contact the appropriate staff at the System Office or College who oversee the content.

Records Retention and Use:

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

All CCCS employees and authorized users are responsible for keeping their electronic data, across all System software and networks, organized and maintained.

Barring other legal retention requirements, the general retention period of electronic communications for employees, students, and authorized users is no longer than 2 years. Certain user accounts are given retention limits beyond 2 years based on need.

Employees are expected to move email messages from their “Inbox” to an “Archive” folder if the email requires retention. Due to retention policies and rules regarding discovery of electronic data (e-discovery), employees must use the supported electronic mail system and designated Archive folders or Archive mailbox to retain required emails and to comply with both retention and destruction policies. Employees should not print paper copies of emails to be saved in physical files unless the emails are part of the permanent record relating to a physical document or have other needs requiring a physical copy.

Electronic records stored on a user’s computer, a CCCS cloud-based system, or System network, shall only be retained as long as there is an ongoing use or legal requirement.

Electronic data involved in litigation or audit investigations shall be retained pursuant to BP 3-100 and SP 3-100a, Evidence Preservation, and as directed by Legal Affairs or Audit leadership. Employees, students, and authorized users involved with maintaining records pursuant to this exception shall coordinate with Human Resources, Legal Affairs, and/or IT staff on the proper procedures to follow.

Records Disposition:

All electronic records shall be maintained according to legal, fiscal, and administrative requirements. Any record no longer needed for reference and free from any retention requirement, shall be deleted. It is important that destruction of electronic records is performed on a timely basis as failure to do so can lead to unnecessary expenditure of resources and liability.

CCCS follows a fiscal year (July 1^st to June 30^th).  As a result, some records may be retained slightly longer than their given retention period in order to complete the fiscal year’s records.

Electronic Communications

Emails and any attachments not tagged for retention by moving into the Archive folder or Archive mailbox will be deleted after 180 days.

Transitory communications shall not be archived and should be deleted as soon as no longer needed for reference. All non-archived transitory communication will automatically be deleted after 180 days.

Emails and any attachments tagged for retention by moving them into the Archive folder or Archive mailbox shall be retained for the required length of time. The chosen 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.

Process or decision-making communications, 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, receiver, System ERM schedule, and any applicable legal requirements.

CCCS Executive staff, College Presidents, College Senior staff, and any staff deemed necessary by the Chancellor or College Presidents shall retain all final correspondence and any electronic communications about administrative, academic, or institutional decisions as legally required, and will have extended retention limits placed on their user accounts.

Employees, students, and authorized users shall not store email messages on any computer’s local storage, external storage device of any kind, or forward email messages outside of the CCCS system to avoid compliance with this procedure.

Electronic Records

Official institutional records, process or decision-making records, records necessary for ongoing administrative purposes, and appropriate supporting documents shall be retained as legally required, which may be short-term or permanently.

CCCS Executive staff, College Presidents, and College Senior staff will determine the official owner of records pertaining to each specific department. All electronic records authorized as an Official Record of the System, shall be maintained accordingly. All other copies of that record will be deemed process or decision-making records or transitory and shall be deleted as soon as no longer needed for use or reference.

Conversion of Records:

In general, electronic records should not be transferred with the intent to maintain process or decision-making records or transitory communications and documents beyond any scheduled or required retention date.

If an electronic communication or record has been classified as an Official Record following the proper procedures and/or is legally required to be retained beyond the retention limit, the System Office or College may transfer the record into another medium using the standard practice followed at the institution for archival storage.

Revising this Procedure

CCCS reserves the right to change any provision or requirement of this procedure at any time and the change shall become effective immediately.