Records Management

Operational Standard/Purpose

Illinois Central College uses a systematic records management process that ensures compliance with legal and regulatory record keeping requirements.

The purpose of this policy is to ensure that employees consistently follow proper procedures when storing, accessing, and disposing of records. Illinois Central College’s records should only be destroyed or disposed of with authorization of the office of the Executive Vice President of Administration and Finance in compliance with the State of Illinois Managing Your Records and the Local Records Act – A Guide to Records Disposal and ICC’s Application for Authority to Dispose of Local Records listing. Complying with record-keeping laws guarantees that records are (1) disposed of at the appropriate time, (2) securely locked in a safe area, (3) properly disposed of in order to reduce storage space, and (4) managed in accordance with state laws and regulations.

Scope/Applicability

All Illinois Central College employees are responsible for following the policies and procedures set forth by the State of Illinois Managing Your Records and the Local Records Act – A Guide to Records Disposal.  To view the complete Local Records Act, visit: http://www.cyberdriveillinois.com/departments/archives/records_management/home.html

Records included in the retention schedule are original records (hard copy or digital) and official copies that are used in day-to-day transactions.

Definitions

Record: A public record is defined as information, regardless of physical form (i.e., digital or hard copy), that has been created, sent, forwarded, or received by any employee of Illinois Central College. Records may include official documentation whether on paper, computer, tape, disk, hard drive, film, or other media. For example, records may include (list is not all-inclusive):

• Email
• Faculty information
• Fax
• Employee data
• Reports
• Data
• Personnel information
• Technological information
• Administrative logs
• Contracts and policies

If you need assistance in determining whether or not your document is a record, please contact the office of the Executive Vice President of Administration and Finance at (309) 694-5522.

Convenience Copy: (State Approval Not Required) If there is a need to make copies of the original record for personal use or reference, this is a convenience copy and does not need state approval for disposal. Example: Original and Convenience Copy

However, any convenience copy that contains sensitive information (see Sensitive Information Included on a Record, below) must be disposed of by shredding. Convenience copies that do not contain sensitive information may be disposed of in office recycle bins.

Sensitive Information Included on a Record: Personal Identifiable Information (PII) is considered sensitive information. PII is any record that includes an individual’s name and one or more of the following items:

• Address
• Financial account number
• Social security number
• Medical information
• Date of birth
• Credit card numbers
• Driver’s license number
• Financial aid information
• Bank account number

Such records are private and are protected by the Family Educational Rights and Privacy Act (FERPA) and the Health Insurance Portability and Accountability Act (HIPAA). PII information should be handled with confidentiality at all times.

Note: Network Operations will conduct quarterly network scans for Personal Identifying Information (PII). Information found to be outside current storage regulations will be flagged and removed from ICC’s unsecured data storage systems. Data will be stored in an isolated, secure system. When a department member needs access to this data, it is the department’s responsibility to contact Network Operations.

Digital Record: A digital record is any record that can be generated, accessed, indexed, stored, and/or reproduced with a digital device. Digital records may be reproductions of an original document. Once the original document has been reproduced with a digital device, such as ImageNow, the original paper document can then be disposed of by following the Application for Auth to Dispose of Local Records Form. Below is a list of stored digital data records that are most commonly used in higher education institutions, regardless of their function, purpose, or sector.

Emails are commonly used as a way to handle business transactions. Emails follow the same record retention guidelines as paper records and, therefore, should be properly disposed of according to the retention timelines listed on ICC’s Application for Auth to Dispose of Local Records Form. The content of any email determines how long the record should be maintained. If you are a user of email, it’s your responsibility to facilitate correct storage of these emails. Emails containing information reflecting College business transactions should be saved as an electronic file or printed and a paper copy retained.

ImageNow: Storing paper records can take up large amounts of storage space. ImageNow can be used to capture documents electronically and store them on a central server. Once they have been captured, they are inspected for quality and indexed with document keys so they can be easily searched and retrieved. In addition to the electronic storage capabilities, ImageNow offers a powerful workflow component that can be used to process documents "electronically." Workflow can be set up to map any paper process, no matter how simple or complex, streamlining business processes for more accurate and timely results.

In the areas where we have deployed ImageNow, we have:

• Reduced paper and minimized storage needs.
• Provided greater security of documents.
• Improved services by providing quicker response time to student/employee inquiries, questions, and requests for information.
• Decreased risk of lost documents.
• Provided greater access to documents that are shared between offices and across the system.
• Eliminated time consuming tasks such as filing and copying.
• Gained efficiency in business processes by reducing processing time of paper documents.

Once an original is scanned into ImageNow, a State of Illinois Application for Auth to Dispose of Local Records Form must be filed and approved before destroying any of the original records that have been scanned.

If you have additional questions about ImageNow, please contact the Director of Enterprise Systems for more information at (309) 694-8557.

Archived (Permanent) Records: The Mission of the Illinois Central College Archives, a division of ICC’s library, is to establish and maintain a documented history of the institution that is accessible to faculty, students, and the community. ICC Archives serves as the repository for all of the College’s records and memorabilia that have historical value to the institution. An archival record maintains historical value and will be preserved by the institution on a permanent basis. Records in the ICC Archives are defined as all recorded information regardless of format or medium. This includes, but is not limited to:

• Handwritten and printed paper documents
• Photographs
• Posters
• Microfilms
• Audiovisual materials
• Electronic records

Procedures

1. There is a process for preparing records for state disposal. ICC’s Application for Auth to Dispose of Local Records Form is used as our guide for records retention scheduling. The retention schedule lists groups of records (i.e., permanent academic records, security video surveillance clips, cash receipts, etc.), retention dates of records no longer needed for business-related transactions, and other guidelines.
2. Storage: All records containing sensitive/confidential/PII information should be stored in a locked drawer, file cabinet, storage room, etc.
3. Request to Destroy Documents: If a record is not listed on the Application for Auth to Dispose of Local State Records Form, please contact the office of the Executive Vice President of Administration and Finance for assistance with locating your record on the list or getting the record added to the list for disposal approval from the state. If records are to be destroyed in less than five (5) years, departments should:
   1. Store the documents in a local storage area.
   2. Complete the State of Illinois Records Disposal Certificate at least sixty (60) days prior to the target date for disposal of records.
   3. Submit the completed Records Disposal Certificate to the Executive Vice President of Administration and Finance for approval. If there is no pending litigation or audit requirements and the retention date has been met, the Executive Vice President will sign the Records Disposal Certificate and send the certificate to the Local Records Commission for approval.
   4. Send the original copy of the Local Records Commissions completed certificate to the office of the Executive Vice President of Administration and Finance and retain a copy for the department.
   5. Proceed with destruction of records on the Local Records Commissions approved date.
4. Warehouse Inventory Storage: Warehouse inventory storage is available to all ICC departments that have records with a retention schedule and disposal date of five (5) or more years. When storing boxes at the warehouse, departments must:
   1. Assemble all records using standard Bankers Boxes for warehouse storage. Boxes may be purchased at the ICC Bookstore and ordered through the proper departmental requisitioning process.
   2. Prepare boxes for storage in the following manner:
      1. Make sure all contents are to be destroyed at the same time.
      2. Place only related items inside of the box.
      3. Label boxes with destroy date, department, and contents (Use Records Box Label Template).
   3. Issue a work order request through Maintenance Connection for pickup of boxes to be stored at the warehouse.
   4. General Operations will pick up marked boxes from the department, transport them to the warehouse, and update the warehouse inventory spreadsheet.
5. Warehouse Destruction Process:
   1. The Executive Vice President of Administration and Finance Office will review warehouse inventory and complete a records disposal certificate twice a year. If there is no pending litigation or audit requirements and the retention date has been met, the Executive Vice President will sign the Records Disposal Certificate and send the certificate to the Local Records Commission for approval.
   2. The Executive Vice President of Administration and Finance will send a copy of the approved disposal certificate to the appropriate department.
   3. The Executive Vice President of Administration and Finance Office will then put in a work order for approved records to be disposed.
   4. General Operations will pull boxes and destroy records appropriately.
6. Shredding: Illinois Central College employees are required to take accurate and safe measures when disposing of sensitive information. Records containing sensitive information must be shredded, using an approved crosscut shredder with a security rating no less than P-4 (5/32” x 1-18” cross-cut particles). Records that do not contain sensitive information may be disposed of in a recycling bin.

Additional Provisions/Information

1. If you have additional questions, contact the Facility Services Assistant Director at (309) 694-5130.
2. Questions regarding the records management process or for guidance on records not listed on the Application for Authority to Dispose of Local Records should be directed to the Executive Vice President of Administration and Finance Office at (309) 694-5522. They will provide your area with the appropriate guidelines for retention and destruction of records.