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Board Policy #160.0

Records and Information Management

1. Policy Statement

The York Region District School Board’s Records and Information Management policy supports efficient and effective program and service delivery, fosters informed decision making, facilitates accountability, transparency and collaboration and helps to ensure an authentic and reliable record of Board actions is maintained. 

2. Application

This policy and associated procedure apply to all Board information and records which are in the custody or under the control of the Board. All records are collected, used, disclosed and disposed of only in accordance with relevant legislation and regulations.

3. Responsibilities

3.1 The Board of Trustees is responsible for:

1. reviewing the Records and Information Management policy and procedure in accordance with the priorities in the Board’s Multi-Year Strategic Plan and the approved policy review cycle; 
2. maintaining Board records and information in a secure, reliable, and trustworthy manner for current and future access; and
3. contacting the Records Management Office with questions or community inquiries regarding this policy.

3.2 The Director of Education is responsible for:

1. implementing and operationalizing the Records and Information Management policy;
2. maintaining Board records and information in a secure, reliable, and trustworthy manner for current and future access; 
3. allocating staff and resources to support the Records and Information Management policy and procedure; and
4. making the decision to disclose information where there is a compelling public interest, such as where grave environmental, health or safety hazards exist.

4. Definitions

4.1 General Information

Information in the Board’s custody or control that is not of a personal nature and is not exempt from public access under the Municipal Freedom of Information and Protection of Privacy Act (MFIPPA) or Personal Health Information Protection Act (PHIPA). Examples of General Information that can be routinely released include, but are not limited to, policies, Ministry guidelines and memoranda, travel expense statements, collective agreements, Board plans, public minutes, or school events and programs.

4.2 Personal Information

Any information about an individual. This includes information that can be used to identify an individual, either alone or in combination with other information. Examples of Personal Information include, but are not limited to, anything included in an Ontario Student Record, report cards, student or staff investigation documents, letters of suspension, health, biographical or demographic information, resumés, or hearing files.

4.3 Non-records

A Non-record has no bearing on the organization’s functions, operations, or mandate. Non-records are typically used, if ever, only for a very limited period of time. They do not have to be collected and maintained. These documents are not required to be retained and therefore do not appear on a records retention schedule. Examples of Non-records include but are not limited to reference books and published legislation from other boards, municipalities or government agencies.

4.4 Official Record

Official Records document or provide evidence of activity, and/or provide legal proof of a transaction or decision. They have continuing value and must be protected, managed, and retained according to the established retention schedule. They are often, but not necessarily, original.

4.5 Record

Any information however recorded whether in print form, on film, by electronic means, or otherwise. Records can be in many formats: paper, video, audio, microfilm or electronic. Examples of Records include but are not limited to emails, text messages, digital media, websites, and electronic document management systems.

4.6 Transitory Records

A Transitory Record is useful only for a short time and has minor importance. When its use is over it should be deleted or destroyed. Examples of transitory records include personal messages, general notices and announcements, copies of documents and emails, cc, bcc, or FYI emails kept only for convenience, drafts and working documents to prepare final records with a few exceptions such as agreements/contracts and drafts in developing legislation.

4.7 Records and Information Management

The planning, directing, controlling and evaluating of information assets to assist in the efficient delivery of Board programs and services. It applies to all business and program applications and information technology systems.

5. Contact

Administrative and Legal Services

6. History

Approved: 1993

Revised: 1999, 2004

Working Document: June 2014, December 2023

Revised: March 2015, October 2024

Final Approval: December 2024

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Board Procedure #160.1, Records and Information Management

1. Procedure Statement

This procedure supports the management of records and information in a disciplined, coordinated and strategic manner. 

2. Application

This procedure applies to all records within the custody and control of the York Region District School Board that are made or received in day-to-day operations, regardless of the medium in which those records are stored and maintained. It helps to ensure that records are available as evidence of Board functions and activities and supports operational and legislative requirements.

3. Responsibilities

3.1 Administrative Services shall:

1. establish, implement and maintain a records and information management program that manages information optimally and best serves the interests of schools and departments;
2. ensure requests for access to General and Personal information are processed in accordance with relevant legislation;
3. represent the Board and respond to Access Appeals made to the Office of the Information and Privacy Commissioner of Ontario; 
4. prepare any required reporting in accordance with legislative requirements; 
5. notify staff or other stakeholders to preserve records that may be relevant to an investigation, lawsuit or other legal proceeding. This practice is referred to as a Legal Hold; and
6. advise staff once the Legal Hold is no longer required. 

3.2 Principals and Superintendents shall:

1. acknowledge Access Requests and related complaints and refer to the Records and Information Management Office, as appropriate;
2. respond to parent’s requests to access or correct personal information belonging to themselves or their child; and
3. ensure staff at their school(s) understand their roles and responsibilities as they relate to record keeping practices. 

3.3 The Records and Information Management Office shall:

1. assess school and department practices and processes to ensure best practices are followed;
2. generate and maintain documentation to support records and information management including, but not limited to, procedures, guidelines, classification schema, records inventories, and record retention schedules;
3. oversee the management of inactive records storage;
4. oversee the management of expired records destruction;
5. provide schools and departments with guidance and tools for managing archives, filing records, determining appropriate and applicable retention periods, and understanding legal, ethical, security and quality/integrity issues;
6. create training materials, offer training opportunities, and assist staff members in their workplaces to manage records and information; 
7. conduct audits to ensure compliance with the policy and procedure;
8. process formal Access Requests in accordance with the legislative requirements, seeking guidance and input from the Privacy Office as appropriate;
9. communicate the public’s right to access General Information and an individual’s right to access their Personal Information;
10. provide consultation and support regarding information access for staff and members of the public;
11. identify suitable documents for the archives in collaboration with the Museum and Archives Curator;
12. oversee the application of Legal Holds to records and information, as required; and 
13. continue to incorporate all electronic records into the records and information management program.

3.4 Staff members shall:

3.4.1 General Requirements:

1. maintain Board records and information in a secure, reliable, and trustworthy manner for current and future access; 
2. limit access to all Board records and information under their control to those who are allowed to access it;
3. only access and use Board records and information as required to fulfill their job duties;
4. assume responsibility for the information and records they create and maintain on behalf of the Board in accordance with legislative and operational requirements;
5. handle and protect records and information consistent with the Information Security and Privacy Classification;
6. follow the “Filing and Storage Requirements” and “Legal Hold Requirements” set out below;
7. destroy copies of any Board records or information that is not stored in an approved location;
8. only destroy Official Records in accordance with legislative requirements and in consultation with the staff member’s Administrator or Manager;
9. not alter or destroy any document subject to a Legal Hold;
10. not destroy or remove Board records and information unless in accordance with Board retention schedules or Board policy; and
11. contact the Records and Information Management Office with questions or concerns.

3.4.2 Access Requests:

1. refer formal Access Requests to the Records and Information Management Office; 
2. refer requests for access to a student’s personal information to the appropriate school’s principal’s office;
3. refer any requests referencing MFIPPA, or those that are large, extensive and/or complex to the Records and Information Management Office;  
4. refer complaints regarding Access Requests to the Records and Information Management Office; and
5. consult with the Records and Information Management Office when the staff member is unsure how to handle or respond to an Access Request.

3.4.3 Filing and Storage Requirements:

1. only store Board records and information, including student or staff personal information in Board approved locations. Examples include, but are not limited to: secure network drives, collaboration tools, Board-approved email, locked filing cabinets or other Board-approved applications; and
2. review electronic (including email) and paper files annually to ensure they are stored securely and/or destroyed in accordance with the Board’s Records Retention Schedule. 

3.4.3 Legal Hold Requirements:

1. preserve any records that may be relevant to an investigation, lawsuit or other legal preceding when notified by the Administrative and Legal Services department; and
2. do not destroy or alter any record subject to a Legal Hold until notified that the Legal Hold has been rescinded, at which time, standard retention periods resume.

4. Definitions

4.1 Access Request

A formal application made under MFIPPA for general or personal information or requesting a correction or deletion of one’s own personal information. Access Requests are supported by the Records and Information Management Office.

4.2 Access Appeal

The process to appeal the decision of the Board on an Access Request by contacting the Office of the Information and Privacy Commissioner of Ontario. 

4.3 Archives Management

Archives Management is the identification and preservation of records and information that promote the history of public education in York Region as well as the application of preservation techniques to ensure enduring accessibility.

4.4 Classification Schema

Classification Schema is the descriptive information for an arrangement or division of records and information into groups based on common characteristics which are, in this schema, subjects, for example finance and administration.

4.5 Forms Management

Forms Management involves documenting information handling instruction on blank forms to ensure the proper management of the collected data.

4.6 Legal Hold

Legal Hold is a process used to preserve all forms of relevant information when litigation is reasonably anticipated. It overrules the prescribed period of retention until the concern passes.

4.7 Retention Schedule

The Retention Schedule charts the prescribed lengths of time for keeping various classes of records.

5. Contact

Administrative and Legal Services

6. History

Approved: 2009

Working Document: June 2014, December 2023

Revised: March 2015, October 2024

Final Approval: December 2024