Records Management Policy Framework

[ Approved 11 Nov. 2008 ]

Preamble

This policy institutes a records management program framework, as the basis for G.B.C. to:

    • Establish criteria for the retention and ultimate disposition of records of the College, and any programs or activities under its jurisdiction (other than records retained for archival use)
    • Provide for the archival retention of records considered by the College to have enduring evidential or informational value

1. Principles

George Brown College's physical and electronic records are its corporate memory. They contain the information that is evidence of how the College performs its functions, and why decisions were taken; and they are a vital asset for its on-going operations. Effective records management ensures that the records maintained are:

    • Authentic, reliable, complete, and accessible
    • Protected and preserved, to satisfy operational needs, ensure current and future accountability, and support future decisions and actions
    • Disposed of accountably, and as legislation requires


2. Official records [See also 11. Terminology, below]

All records created or received in the course of conducting G.B.C.'s business are official records of the College. These records exist as originals (or duplicates) in any physical form or medium, including paper and microform, or on electronic media such as computer-based systems, data tapes / disks, or audio / video recordings.


3. Records management

Controls are applied to the creation, maintenance, use, and disposal of G.B.C.'s records. These include retention scheduling, vital records protection, storage and administration of inactive records, management of record conversion programs, archival preservation, research access, disaster planning, and the certified records destruction required under the Privacy laws of Ontario and Canada.


4. Rationale for records management

Effective records management ensures that G.B.C. creates and maintain records to:

    • Conduct business effectively, in an efficient and accountable manner
    • Deliver reliable service performance, consistently and equitably
    • Facilitate productive, timely inquiry handling, concerning College functions
    • Ensure management consistency, and administrative continuity
    • Support policy formulation, and document management decision-making
    • Preserve an adequate record of G.B.C.'s vital activities and transactions
    • Provide evidence of personal and business rights and responsibilities
    • Meet legislative / regulatory accountability requirements, including audit, Freedom of Information and Privacy Protection, entitlement, validation, individual rights, and oversight activities
    • Minimize the risks to records safekeeping, and provide continuity in the event of disaster
    • Provide protection and support in litigation, including risk management associated with the existence (or lack) of evidence of organizational activity and compliance
    • Protect the interests and rights of the College, and its employees, students, and clients; and satisfy present and future stakeholder expectations
    • Maintain corporate, personal and collective memory
    • Support current and future institutional research and development activities
    • Assist academic post-graduate scholarly research
    • Document the College's contribution, achievements, and cultural identity


5. Purpose and objectives of the Records Management Policy Framework

5.1 This Policy is established to ensure that authentic, reliable, complete, and usable records

    • capable of supporting G.B.C.’s functions and activities – are effectively and accessibly maintained, for as long as they are required.

5.2 The objectives of the Policy are to:

    • Provide a statement of intent, declaring the records management standards for the administration of College records
    • Establish and maintain records management routines within the College
    • Ensure the preservation of permanent-value records
    • Support College-wide compliance with legislation, and College regulations
    • Set out the criteria to assure and maintain continued access to appropriate historical records of the College


6. Scope of the Policy

6.1 G.B.C.'s official records consist of all the recorded information – regardless of format created or received by the G.B.C. Board of Governors, College officials, and employees, in performing official duties or functions on the College's behalf. These records are held as evidence of G.B.C.'s organization, policies, decisions, operations, functions, procedures, and internal or external relationships or transactions.

6.2 All G.B.C. official records are the property of the College, and subject to its overall control. They must be created, used, maintained, and disposed of only in accordance with the guidelines and procedures approved by the appropriate College authority – the College Records Management Working Group.

6.3 This Policy applies to all aspects of the College's work, in all governance, academic, and administrative areas and locations where the College does business, encompassing official records that are held by the College, or other records that are under the College's control.

6.4 Employees leaving the College, or changing positions within the College, must leave all official College records in-place and intact, for their successors.

6.5 This policy provides the overarching framework for any other G.B.C. records management policies, practices or procedures.


7. Responsibility for College records management

7.1 All official records must be retained as long as necessary, to meet the legal, administrative, financial, and operational requirements of the College. Afterwards, they are either to be destroyed, or transferred to the College Archives, under the appropriate policy applicable.

7.2 Operational responsibility for G.B.C.' s records rests locally with each department head, including staffing and resource allocation support. Assistance is provided (through the Records Management Working Group), by the College Archivist, who provides advice regarding records management procedures and records retention and disposal support services.

7.3 The individual College offices are responsible to ensure locally that appropriate security measures are respected for maintaining any records containing personal or other confidential information, by supporting and monitoring staff compliance with this policy.

7.4 All records approved for destruction must be completely disposed of in a manner that safeguards the confidentiality of any information they may contain.

7.5 Destruction through the College Archives is mandatory for all G.B.C. records types that are "Listed" in Ontario's Freedom of Information and Protection of Privacy Act Directory of Records as "Personal Information Bank" records. The College Archives ensures proper "Head of Institution" authorization signatures are obtained prior to the destruction, ensures it is carried out properly, and retains permanently the necessary "Certificate of Destruction" required by the legislation / regulations.

7.6 Final authority over the disposition of records held by G.B.C. rests with the College Archivist.

7.7 All official records that are permanently preserved must remain readily assessable to the relevant officers and employees of the College


8. College Records Management Working Group

8.1 The Records Management Working Group is established to develop the practical implementation of the G.B.C. Records Management Policy, and provide for its oversight. This includes the:

    • Development of a policy for the creation, management, and disposition of official records
    • Production of guidelines for the foregoing
    • Establishment of appropriate supervisory arrangements for the implementation of records management
    • Decision-making in relation to any particular issues concerning the retention or disposal of official records
    • Authorization of records retention / disposal schedules submitted by the creator offices
    • Providing or commissioning of assistance for G.B.C. departments or members of the College, regarding records management

8.2 The Records Management Working Group reports to the G.B.C. Senior Management Committee

8.3 The Records Management Working Group's concern encompasses all G.B.C. records, other than those which are under the control of the College Archives. The policies and procedures relating to the administration and operation of the College Archives are the responsibility of the College Archivist.

8.4 At College policy-setting sessions, the membership of the Records Management Working Group consists of the following:

    • Vice-president Corporate Services, Chair
    • Chief Information Officer (Information Systems), when electronic records are considered
    • College Archivist, Deputy Chair
    • Freedom of Information and Privacy Co-ordinator
    • Others co-opted by the Committee as necessary, from time to time

8.5 At working sessions, to consider or review specific records, the membership of the Records Management Working Group consists of the following:

    • College Archivist, Chair
    • Dean and/or Director of the office(s) whose records are being reviewed
    • Archivist (College Archives)
    • Topic-specific specialist advisors (e.g., Web Master, Manager of Academic Records, etc.)
    • Others co-opted by the Committee as necessary, from time to time


9. Other records management requirements

The following documents are required to give effect to the Records Management Policy, and are developed under the Records Management Working Group's supervision:

    • A Records Management implementation plan
    • Records retention schedules [ See 11. Terminology, below ]
    • A Records Management procedures manual
    • Guidelines for the management and archiving or destruction of electronic records


10. Legislation

10.1 The College acknowledges the laws, directives, guidelines, and agreements listed in Appendices A, B, and C to this policy that relate to records and information.

10.2 The College will develop record keeping systems that capture and maintain records with appropriate evidential characteristics in accordance with its obligations under their requirements.


11. Terminology

Records

Ontario's Freedom of Information and Protection of Privacy Act (R.S.O. 1990 Chap. F.31), gives the following definition:

"Record" means any record of information however recorded, whether in printed form, on film, by electronic means or otherwise, and includes:

(a) correspondence, a memorandum, a book, a plan, a map, a drawing, a diagram, a pictorial or graphic work, a photograph, a film, a microfilm, a sound recording, a videotape, a machine readable record, any other documentary material, regardless of physical form or characteristics, and any copy thereof, and

(b) subject to the regulations, any record that is capable of being produced from a machine readable record under the control of an institution by means of computer hardware and software or any other information storage equipment and technical expertise normally used by the institution; ("document")

G.B.C.'s By-Law Number 8 - Article 2.7 Books and Records, states:

"The Secretary shall ensure that all necessary books and records of the College required by the Corporations Act, the OCAAT Act, the by-laws of the College, or by any other applicable statute or law, are regularly and properly kept.

“ The minutes of meetings of the Board of Governors or of committees of the Board of Governors, all by-laws and resolutions of the College, the register of all Members of the College or those who have been, within ten years, Members of the College, the register of Governors of the College with the several dates on which each became or ceased to be a Governor, and all other records of the College required to be open to the public for inspection shall, during normal office hours, be available to the public or to Members generally for inspection.

“Where possible, the by-laws of the Board of Governors shall be available to the public at no charge on a website on the internet. Each Governor shall be provided with a copy of the minutes of meetings of the Board of Governors and of committees of the Board of Governors and of such documents or records of the College as her or she may reasonably request.”

Records Retention Schedules

A Records Retention Schedule is a control document that describes the College's corporate records at a series level, and indicates:

    • The length of time each series shall be retained as active, before transfer to semi-active storage
    • The length of time each series should be retained as semi-active, prior to final disposition
    • The final disposition of each series
    • The signed approval of the College officials, at the appropriate levels

This document serves as the College’s formal declaration for the retention and disposal of records.


APPENDIX A

Legislation /Regulations bearing on G.B.C. records and information

Ontario and Canada statutes (current, and historical) and/or regulations under them, municipal by-laws, and regulated professional organizations guidelines affect the records that the College creates, maintains, or destroys.

These Ontario and federal laws, and professional guidelines include (but are not limited to):

    • Ontario Colleges of Applied Arts and Technology Act [ Ontario ]
      [ Establishes G.B.C., and defines it as an agency of the Crown and as a non-share corporation, bound by policy directives issued by the Minister and subject to Regulations limiting the powers that may be exercised by the College under the Ontario Corporations Act]
    • Freedom of Information and Protection of Privacy Act(F.I.P.P.A.) [ Ontario ]
    • Personal Information Protection and Electronic Documents Act(PIPEDA) [ Canada ]
    • Building Code Act [ Ontario ]
    • Business Records Protection Act [ Ontario ]
    • Canada Pension Plan [ Ontario ]
    • Canada Student Financial Assistance Act [ Canada ]
    • Canada Student Loans Act [ Canada ]
    • Charities Accounting Act [ Ontario ]
    • Consumer Protection Act [ Ontario ]
    • Copyright Act [ Canada ]
    • Corporations Act [ Ontario ]
    • Corporations Information Act [ Ontario ]
    • Criminal Code [ Canada ] (re: Records, documents, invasion of privacy, etc.)
    • Day Nurseries Act [ Ontario ]
    • Employer Health Tax Act [ Ontario ]
    • Employment Insurance Act [ Canada ]
    • Employment Standards Act [ Ontario ]
    • Evidence Act [ Ontario ]
    • Evidence Act [ Canada ]
    • Excise Tax Act [ Canada ]
    • Hazardous Materials Information Review Act [ Canada ]
    • Hazardous Products Act [ Canada ]
    • Health Insurance Act [ Ontario ]
    • Income Tax Act [ Canada ]
    • Income Tax Act [ Ontario ]
    • Limitations Act [ Ontario ]
    • Liquor License Act [ Ontario ]
    • Ministry of Community and Social Services Act [ Ontario ]
    • Ministry of Health and Long-term Care Act [ Ontario ]
    • Ministry of Skills Development Act [ Ontario ]
    • Ministry of Colleges and Universities Act [ Ontario ]
    • Occupational Health and Safety Act [Ontario ]
    • Pension Benefits Act [ Ontario ]
    • Post-secondary Education Choice and Excellence Act [ Ontario ]
    • Retail Sales Tax Act [ Ontario ]
    • Statistics Act [ Canada ]
    • Statistics Act [ Ontario ]
    • Teachers' Pension Act [ Ontario ]
    • Trades Qualification and Apprenticeship Act [ Ontario ]
    • Workplace Safety and Insurance Act [ Ontario ]

APPENDIX B

G.B.C. Policies and/or Procedures bearing on records and information

    • By-Law Number 8
    • Academic Policies, Guidelines and Codes of Conduct
    • Information Technology Policies
    • Administrative Policies and Procedures
    • Divisional Academic Policies and Procedures
    • Integrity in Scholarly Research and Scholarship Policy
    • Prevention of Discrimination and Harassment Policy

APPENDIX C

Other Directives, Guidelines, Agreements, etc. bearing on records and information

    • Ontario. Department of Education / Department of Colleges and Universities / Ministry of Colleges and Universities / Ministry of Education and Training / Ministry of Skills Development / Ministry of Training, Colleges and Universities
      - Numbered Memoranda ( 1968+ )
    • The Ontario Council of Regents for Colleges of Applied Arts and Technology / The College Compensation and Appointments Council for the Colleges of Applied Arts and Technology
      - Numbered Memoranda ( 1968+ )
      - Academic (Faculty) Employees Collective Agreement
      - Support Employees Collective Agreement
    • Royal College of Dental Surgeons of Ontario
      - Guidelines: Dental Record Keeping
    • [ Education- and training-related Federal-Provincial agreements ]