NORWICH FREE ACADEMY
DOCUMENT RETENTION POLICY
This Policy applies to all departments of The Norwich Free Academy (the "School").
The objectives of this Document Retention Policy are to:
A. establish a consistent policy for managing, retaining, storing and
disposing of Documents, regardless of the media in which they are stored;
B. ensure the preservation of Documents relevant to any pending, threatened, reasonably foreseeable or contemplated legal action or proceeding or government investigation;
C. ensure that Documents required for the School's operations are maintained in an efficient manner so they can be readily accessed when necessary;
D. comply with applicable legal requirements for retaining documents;
E. reduce the volume and cost of storing Documents that are no longer needed by the School; and
F. ensure an appropriate and orderly Document disposal process.
The general policy of the School is to retain for an appropriate time all documents that are needed to operate the School or required by law to be retained. Documents should be retained or routinely disposed of in accordance with the time periods indicated by state and federal regulations. These time periods apply to all documents regardless of how or where they are maintained. The time periods do not apply, however, where the Head of School specifically has indicated through the issuance of a Litigation Hold Notice that certain documents or categories of documents should be retained. This policy will be consistently and uniformly applied throughout the School.
Documents related to any reasonably foreseeable or contemplated (i) legal action or proceeding (e.g., a civil lawsuit) or (ii) government investigation (e.g., an IRS audit), should not under any circumstances, be altered, mutilated, concealed, deleted, destroyed or otherwise disposed of without the specific authorization of the Head of School. Under the circumstances described above, routine document disposal must be suspended pending authorization by the Head of School to resume routine document disposal.
Every employee is required to manage documents in such employee's possession or control in accordance with this Document Retention Policy.
The Head of School (or designee) is responsible for the overall implementation and maintenance of the School's Document Retention Policy. The Head of School’s responsibilities include:
1. As may be necessary or appropriate from time to time, notifying employees (through a Litigation Hold Notice) regarding Documents that must be retained because they are reasonably likely to be relevant to a pending, threatened, reasonably foreseeable or contemplated legal action or proceeding or government investigation;
2. Interpreting for employees any provisions of the Document Retention Policy as such provisions may apply to specific situations; and,
3. Advising employees of material changes in the laws, regulations, and amendments governing the retention or disposal of documents.
Documents that are being retained should be stored in a secure storage area that is reasonably safeguarded against theft, inappropriate access, misuse and damage (including events such as fire and flood).
Access to records will be in accordance with the following laws: the Connecticut Freedom of Information Act, C.G.S. § 1-200 et seq.; the Health Insurance Portability and Accountability Act of 1996; the Individuals with Disabilities Education Act; the No Child Left Behind Act; the Family Educational Rights Privacy Act; and the Federal Rules of Civil Procedure, including, but not limited to, any rules concerning electronic discovery and preservation of documents.
Definition: “DOCUMENT” means any communication, memorandum, report, record, data compilation or other similar item generated, received, transmitted or maintained by the School or any School employee for or on behalf of the School (including informational, working and personal copies), regardless of the format or storage method of or medium used to store the item, including, but not limited to, any paper, chart, card, book, photograph, microfilm, microfiche, magnetic media, daytimer, electronic calendar, computer tape, floppy disc, zip cartridge, computer hard drive, email, electronic image or CD-ROM, and any copy, back-up or printout thereof.
Adopted: May 18, 2010