Many factors have contributed to the need for a records management plan at Northfield Mount Hermon. The dramatic increase in the volume of records output by NMH, privacy
considerations, legal requirements, and management of electronic records are but some of these factors. As the records of the school expand and record retention becomes more complex, so does the creation, maintenance, protection, and preservation of records. The science of records management includes the creation, maintenance, protection, and preservation of these records and seeks to assist records custodians in the maintenance and disposal of records.
Records management is an administrative plan in which records are logically categorized for easy retrieval, use, destruction, and protection. Where there is records management, there are systematic procedures for the creation, utilization, disposition, and protection of records. These procedures facilitate the rapid and economic retrieval of data for the administration of the school. The objectives in managing records are to make the records serve the purpose for which they were created as cheaply and effectively as possible, and to make proper disposition of them after they have served their purpose.
NMH recognizes the importance of maintaining records properly. This recognition strongly encourages the creation, adoption, and implementation of a formal, written Records
Management Program that includes specific standards for both paper and electronic records.
Proper management of records serves several important functions. It ensures that NMH and authorized personnel have immediate access to information for the full period of time it is needed to conduct daily business, financial transactions, litigation, maintenance of property, and development and implementation of policy. It ensures protection of employees’ and students’
rights to privacy. It ensures that historical records are identified archived and protected. Also, it ensures organization and disposition of records in an efficient and effective manner.
NMH has numerous types of records in many forms. A comprehensive policy requires addressing all of these types of records and their forms. NMH has historical records that must be
safeguarded and appropriately archived. NMH has personnel and student files that must be adequately protected. Furthermore, NMH has business records that must be properly maintained and organized for the benefit of the school. The following plan addresses these issues.
“Records” refers to all books, maps, photographs, recorded tapes, financial statements, statistical tabulations or other documentary material or data, regardless of physical form or characteristics, made or received by NMH. This includes all records generated, received, or maintained
electronically, including computer records, electronic mail, video, and audiotapes. “Custodian of Records” refers to a person having routine access to or control of public records.
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Inventory
The basis of any records management program is effective reference and security control of records. The means to establish this control is a thorough records inventory. With the
completion of an inventory, the custodian will have definite knowledge of the types of records held, their inclusive dates, volume, the type of information they contain, and the location of the records. Annual updating will keep the inventory current. Therefore, the inventory can be used in conjunction with the applicable retention schedules to ensure that:
1. departmental records are safely stored and readily available;
2. long-term records are preserved; and 3. obsolete records are disposed of properly.
Appraisal of records is one of the most significant steps in a records program, as it is the point at which definitive judgments are made about the enduring values of records. These judgments will lead to decisions on the retention of the records. NMH will perform necessary appraisal of records and modify policies and practices as needed. NMH has created a
retention schedule for records based on Massachusetts General Laws and the interest of the school. Certain records need to be retained for specific periods of time or permanently, while others may be disposed of within a short period of time. Records possessing one or more of the following values have recommendations to be preserved permanently, or for a period of time until an event, or until a combination
of an event and a time period.
1. Administrative value: A record possesses administrative value if it helps the office perform essential functions now or in the future.
2. Legal value: A record possesses legal value if it documents a legal right or obligation of the school.
3. Fiscal value: A record possesses fiscal value if it uniquely documents or verifies the spending or receipt of monies.
4. Historical value: The application of this value is fundamentally a search in the records series for possible cultural values to posterity or the already archived records of the school.
Generally, records that document the operation, procedures, policies, or organization of the school or contain significant factual information will possess historical value. This value must be tested against such other considerations, such as uniqueness of the records, the volume of the records, importance of the information, and likelihood that future historians or other researchers will actually use the material.
Records Disposition
The disposal of records in accordance with the NMH records retention schedule will result in the removal of large quantities of obsolete records from among the many records series at the school that are being retained for their value or because it is legally required. A well-thought-out program of records retention and disposition will:
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1. Ensure that records are kept as long as they are required;
2. Result in the destruction of obsolete material;
3. Facilitate the rapid retrieval of information;
4. Clear space for more productive use and prevent the accumulation of unnecessary records;
and
5. Provide cost savings for storage of the records and staff time to manage them.
Legal Requirements
A list of legally required records’ policies and statutorily required content will be developed to assess compliance of each category of records with the law. For example, M.G.L. c. 149, section 52C details the content requirements of personnel records. Section 52C states in part: “all of the following written information ... shall be included in the personnel record for that employee: the name, address, date of birth, job title and description; rate of pay and any other compensation paid to the employee; stating date of employment; the job application of the employee; resumes or other forms of employment inquiry submitted to the employer in response to his
advertisement by the employee; all employee performance evaluation, including but not limited to, employee evaluation documents; written warnings of substandard performance; lists of probationary periods; waivers signed by the employee; copies of dated termination notice; any other documents relating to disciplinary action regarding the employee.” In addition, M.G.L. c.
149, section 52C has recently been amended to require an employer to notify an employee within ten (10) days of the employer placing in an employee’s personnel record any information to the extent that information has been or may be used to negatively affect the employee’s qualification for employment promotion, transfer, additional compensation, or the possibility that the
employee will be subject to disciplinary action. Current NMH practice and policies conform to the content and notification law described above. M.G.L. c. 93H requires a written policy to protect the identity and financial information of staff, students, parents, vendors, and other third parties. NMH currently has compliance guidelines.
I. Record Retention:
NMH records of every type should be retained according NMH records retention guidelines. Any employee or officer of the school who creates or receives a technology document must review said document for content. Once a determination has been made regarding the subject matter involved in the document, the employee or officer must consult the retention schedules for the school in order to determine the life cycle of that particular record. The employee or officer must then cause the record to be stored according to these guidelines. Emails made or received are records. All email users must screen and evaluate email messages for content and retain emails in hard copy according to Records Retention Guidelines. All other records will be deleted or destroyed according to the school’s Records Retention Guidelines.
II. Custodians:
Every department is required to have a Records Custodian. Custodians must provide proper care and management of records. Records Custodians have the authority to direct personnel
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who control or hold records. Records Custodians must know:
• what records the department makes or receives;
• who makes or receives the records;
• when the records can/should be destroyed according to the Records Retention Schedule;
• where the records are stored; and
• how the records can be accessed during the retention period
Custodians of Records must keep an inventory of records held within their department. This inventory will include what records are within the department, where they are kept, by whom, and in what format, and will also include a list of persons likely to contribute records to the department, such as those employees or officers who received electronic records.
A litigation hold on electronic records is required under the law if these records are relevant to the subject of the litigation. Emails or other electronic records cannot be destroyed once a litigation hold is in place.
Records Custodians must ensure that no records or emails are destroyed, even if the retention period is passed.
Records Custodians must be able to retrieve records subject to litigation hold upon request within the time provided for by law.
Records must be maintained and stored by the Custodian of Records for each department within the school so that production of the record is possible within a reasonable time or as required by law.
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RECORDS RETENTION GUIDELINES