TITLE: RECORD DESTRUCTION POLICY
ADOPTED: December 2, 2008
The proper disposal of information and data is important to minimize
the use of valuable space, promote efficiency, assist in the day-to-day
operations of Waynesboro Area School District, reduce the cost of
storage of unneeded records, and reduce the risk of identity theft
and/or breaches of privacy, computer fraud and related harms. The
School District employees must take reasonable measures to protect
against unauthorized access to or use of records and information/data,
and properly dispose of paper and electronic records, information and
Authority: The within Records Destruction Policy has been formulated and approved by the Board of School Directors.
Delegation of Responsibility:
The Assistant Superintendent is responsible for the destruction of the
School District records. Delegation of responsibilities may be made by
the Assistant Superintendent if clear guidance is provided to those with
delegated responsibility while maintaining the ultimate authority to
enforce this policy.
The Assistant Superintendent must use due
diligence when hiring a document destruction contractor to dispose of
material. Due diligence could include (a) reviewing an independent
audit of a disposal company’s operations and/or compliance with various
defined destruction laws; (b) obtaining information about the disposal
company from references; (c) requiring that the disposal company be
certified by a recognized trade association; and (d) reviewing and
evaluating the disposal company’s information security policies and/or
of all paper and electronic records must be by shredding, erasing, or
otherwise modifying the information of the record to make the record
unreadable, undecipherable or nonreconstructable through generally
available means. Other means include, but are not limited to, burning
or pulverizing the records. Information that is stored electronically
must be made irretrievable before disposal.
include discarding and abandoning information, as well as the sale,
donation, and/or transfer of computers or other media where that
information is stored.
- Records must be destroyed
within seven (7) days of the period designated in the Waynesboro Area
School District Retention Schedule, unless an exception is granted by
the Assistant Superintendent, or a litigation hold is relevant.
- Destruction of the records (original and copies) may not occur without the approval of the Assistant Superintendent.
records that are retained must be retained in a preserved
record-keeping system along with the transmission data. In this case,
e-mail messages in users mailboxes have little or no continued value and
may be deleted. The records in the preserved record-keeping system are
governed by this policy and the School District Record Retention Policy
Training employees to ensure
compliance with this policy, and the proper disposal methods for
information, data, media and hardware is necessary.
the School District has been given notice that a legal action is either
pending or imminent or a government investigation will occur,
destruction of records (documents) must be suspended immediately.
Notice could occur before the filing of a Complaint, and assumes that
the School District is previously aware of an incident or event that is
subject to a suit.
Groups or classes of records must be destroyed
in the ordinary course of business under the approved School District
Records Retention Policy and Schedule, which is designed to meet the
legitimate needs of the School District. Selective destruction of
records (documents) in anticipation of litigation is forbidden.
Assistant Superintendent must be made aware of events or incidents that
are likely to lead to legal action. Counsel must be notified
immediately. Counsel will be responsible for evaluating the defenses
available to the School District, identifying the records (documents)
that may be relevant to a legal action, and responding to the suspension
of the retention and destruction policies and schedule.
Consequences for Violation
must be aware that violations of this policy may result in a variety
of disciplinary actions, including but not limited to, warnings, loss
of privileges, position reassignment, oral and written reprimands,
suspensions (with or without pay), dismissals and/or legal proceedings.
of this policy may be reported to appropriate legal authorities,
whether local, state, or federal law enforcement. The School District
will cooperate to the extent legally required with authorities in such