It's a good practice to formally train District Staff on your District’s Policies and Procedures so that you can fulfill the responsibilities outlined in your formal Records Management Policy and remain compliant.
In our first 5 articles, we’ve covered 1) making sure that you have the appropriate information on file with TSLAC, 2) identifying, assigning, and documenting Records Management responsibility among District Staff, 3) establishing a centralized Records Retention Center (RRC), 4) identifying the policy for determining when things move to your RRC, and 5) establishing a regular routine for processing and moving newly inactive records to the RRC
The next step is to formally train District Staff on your District’s Policies and Procedures so that you can fulfill the responsibilities outlined in your formal Records Management Policy and remain compliant.
The components of an effective Records Management Training Program run the gamut, from discussing the underlying records laws and regulations, to understanding retention periods, to managing inactive records. More specifically, it includes training District Staff on the following:
- What Is the Law? It is important that all District Staff involved in Records Management understand the legal requirements established by the state and “enforced” by TSLAC. A list of current publications related to Records Management laws and best practices can be found on the TSLAC website: https://www.tsl.texas.gov/slrm/pubs
- What Is a Record? Not every piece of information is a “record” that is covered by state regulations. It’s important for employees to know what constitutes a formal record so that they can process them properly and not add unnecessary documents to your retention files. The definition of a "Local Government Record" in Texas is:
“…any document, paper, letter, book, map, photograph, sound or video recording, microfilm, magnetic tape, electronic medium, or other information recording medium, regardless of physical form or characteristic and regardless of whether public access to it is open or restricted under the laws of the state, created or received by a local government or any of its officers or employees pursuant to law, including an ordinance, or in the transaction of public business.”1
- What Is the Difference Between the “Record” Copy and a “Convenience” Copy? Records must be maintained properly for the appropriate retention periods. The “Record” Copy is the official record. However, records must also sometimes be shared between Departments and with authorized constituencies. Knowing how to correctly categorize an original record and a copy is critical. According to TSLAC, “Convenience copies are all copies of the record that are not the record copy.”2 TSLAC has determined that the Records Management Officer is responsible for determining what is the “Record” copy and what is a “Convenience” copy. “Convenience” copies do not have to be retained, but they should be destroyed along with the “Record” copy when the “Record” copy becomes obsolete.
- Who Owns the “Record” Copy? The “Record” copy is the copy that is covered by State retention regulations and must be retained according to the appropriate regulations by the appropriate custodian in the appropriate file. Keep in mind that while they may not be subject to the same rules as “Record” copies, “Convenience” copies also have to be managed as a part of overall Records Management Program.1
- What is the Retention Period for Each Record? State laws define the retention period for each type of record. However, several variables may need to be considered. Often, the defined retention period also identifies or defines the specific activity that starts the clock on the retention period. For example, the record of a student’s achievement is only “permanent” if the student earns one or more high school credits while attending the district. If the student withdraws from the district before earning any high school credits, then the retention is “5 years from the date of withdrawal”. In this case the retention period for student achievement records is dependent on the grade level and the date the student withdraws or graduates. Understanding and applying the correct retention schedule to each record is critical. The Retention Schedule for Records of Public School Districts can be found online at: https://www.tsl.texas.gov/slrm/localretention.
- How Should I Organize Newly Inactive Records? Some inactive records will never be retrieved while others may be retrieved several times over their retention lifespan. Having an organized process for adding newly-active records to your inactive records file will ensure proper custodial care, successful future access, and timely retrieval.
- When Do I Send Newly Inactive Records to the RRC? Having a clearly identified schedule and process in place for the migration of records from “active” to “inactive” is essential for a smooth transition that ensures inactive records are retained and easily retrievable in the future. For example, consider records for graduating students. The records become “inactive” when the student graduates. However, it may be more efficient to maintain these records for a year or two at the high school before sending them to your RRC.
- How Do I Get a Record Back from the RRC? Establishing and training Records personnel on the proper process for retrieving a record from the Records Retention Center can help to ensure prompt compliance with records requests. Equally important is having a formal process to keep tabs on “retrieved” documents so that they are ultimately returned to the original file.
- Who do I call when I have questions? As with any complicated process, questions will arise for unanticipated issues or infrequent activities. It is important that a clear process is established and communicated regarding how to handle these situations so that personnel know who to contact. Generally, this is the RMO.
Our final edition will cover some strategies for staying current with TSLAC changes.