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Internal Control Tip of Week – Records Retention Practices

By Thomas Canby posted 10-20-2016 10:14

  

Public schools generate mountains of records every school year. As records are generated, all Texas school districts are required to follow rules established by the Texas State Library and Archives Commission (TSLAC) for storage, retention, and destruction of records, in addition to more restrictive requirements, if any, that may be found in certain contracts and agreements, or local policies and procedures. In the administration of the records management system, it can be challenging to keep up with the generation of records, and some districts may neglect the records destruction side of managing the system.


How good is your district in deleting records that have been stored beyond the required retention period? Is there a tendency in your district to retain records for years beyond the timelines established by the TSLAC or other legal requirements? If so, it may be time to step back and ask yourself certain questions that may lead to a more practical approach to the district’s record retention practices. Questions you may ask yourself include:



  • What are the chances that select records may be needed beyond the required retention timeline?

  • Is the information of potential interest available elsewhere?

  • How challenging would it be to organize certain information if certain records were unavailable 1, 5 or 10 years beyond the legal timeline for destruction of the records in question?

  • Would the incremental costs in relation to the challenges to recreate certain information be reasonable to justify keeping select records for extended periods of time?


Electing to store documents for extended periods of time may introduce avoidable internal control risks not to mention substantial incremental attorney fees to review such records prior to their release under an open information act request. It is recommended that districts consult with their attorney-on-retainer to discuss why the district may elect to retain certain records for extended periods of time and consider the potential avoidable internal control risks for certain categories of records.

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