02-2009 - Record Retention and Destruction

I. Authority

The Executive Committee is vested with the power to adopt a policy on behalf of the Interstate Commission during periods when the Interstate Commission is not in session. The Executive Committee oversees the day-to-day activities managed by the Executive Director.

II. Applicability

This Policy applies to all physical and electronic records produced by ICAOS. This policy is not applicable to records or documents produced by member states that are maintained in accordance with policies and procedures established by their respective states.

III. Policy

The policy is to ensure that records and documents produced by the Commission are adequately protected.

IV. Administration

1. The Executive Director’s designee is responsible for the implementation and administration of the record retention schedule shown in Schedule A.    

2. Distribution of Open and Closed Session Records

   1. Open Session Records

      Approved open session minutes of the Commission and its committees shall be made publicly available, including posting on the Commission’s website, in accordance with Commission practice. Such records shall be retained permanently in accordance with Schedule A.

   2. Closed session minutes shall be maintained as confidential records and distributed only to authorized members and staff. These records shall be retained permanently and maintained separately in accordance with approved records management practices. Closed session materials shall remain confidential unless the Commission, in consultation with legal counsel, determines that confidentiality is no longer required.

3. Suspension of Record Disposal In the Event of Litigation or Claims

   In the event ICAOS becomes party to a court action, a government investigation, or audit the disposal of any and all records and documents shall be suspended until such time as the Executive Director, with the advice of counsel, determines otherwise.

4. Record Keeping

   Except in the case of electronic email records noted in Schedule A, whenever an employee disposes of records in accordance with the schedule outlined in Schedule A, the employee shall prepare a written log identifying the records and documents destroyed, the date destroyed and by whom. 

SCHEDULE A RECORD RETENTION SCHEDULE (ICAOS)

A. GRANTS

B. CONTRACTS

C. Commission RECORDS

D. CORRESPONDENCE AND INTERNAL MEMORANDA

1. Correspondence and internal memoranda pertaining to routine matters and having no significant, lasting consequences should be discarded within two years. Some examples include:

   • Routine letters and notes that require no acknowledgment or followup, such as notes of appreciation, congratulations, letters of transmittal, and plans for meetings.

   • Form letters that require no followup.

   • Letters of general inquiry and replies that complete a cycle of correspondence.

   • Letters or complaints requesting specific action that have no further value after changes are made or action taken (such as name or address change).

   • Other letters of inconsequential subject matter or that definitely close correspondence to which no further reference will be necessary.

   • Chronological correspondence files.

2. Correspondence and memoranda pertaining to nonroutine matters or having significant lasting consequences should generally be retained permanently in the file management system of the national office. Email records meeting the need for permanent retention should be transferred out of email servers for retention in the standard file management system. Some examples include sensitive or confidential correspondence affecting business processes, responsibilities, or standards. 

E. ELECTRONIC DOCUMENTS

1. Electronic Mail: shall, unless noted otherwise below, be retained for six months, after which time it can be deleted. Email attachments are to be handled according to topic as set forth in this policy.

   • Fiscal Correspondence: Includes all information related to revenue and expenses. Fiscal correspondence is retained according to the accounting guidelines set forth in this policy.

   • General Correspondence: Includes information as it relates to customer/member interaction and operational decisions. General correspondence resulting in a policy decision is retained according to the guidelines set forth in this policy.

   • Momentary Correspondence: Includes personal email, requests for recommendations and review, carbon copy emails, project development, and status updates. Momentary correspondence can be deleted at will.

2. PDF documents, Spreadsheet, and Word Processing Documents, Spreadsheet, and Word Processing Documents –PDF files are retained based upon the content of the file and the category under the various sections of this policy.

3. Faxed Documents – Fax documents are retained based upon the content of the file and the category under the various sections of this policy.

4. In the event a document is maintained in both paper and electronic form, the official document will be the electronic document.

F. LEGAL FILES AND PAPERS

G. MISCELLANEOUS

H. ELECTRONIC INFORMATION SYSTEM

All records and case information entered in the electronic information system authorized by the commission is the property of the member states and is maintained according to the laws and policies of the member states. Data entries and attachment will not be disposed of without the express written permission of the member state that provided the information. Request for record disposal will be kept permanently.

SCHEDULE B - RECORD RETENTION SCHEDULE

B. INSURANCE RECORDS

C. PAYROLL DOCUMENTS

C. PERSONNEL DOCUMENTS

D. ACCOUNTING AND FINANCE

E. PROPERTY RECORDS

F. TAX RECORDS