The Records Retention Schedule is a diocesan policy that lists all the records commonly maintained by archdiocesan schools and describes how long they must be kept and what to do with them at the end of that period.

• It applies to records in all formats (paper, photographs, electronic files, etc.) and in all storage locations (including file cabinets, cloud storage, email servers, web applications, and mobile devices).

• The following guidelines are meant to help you understand how to apply retention policies to the records of your office or work area.

1. Orient Yourself

a) First familiarize yourself with how the retention schedule is organized. Records are grouped together by the administrative functions they relate to, not by the type/format of records (i.e., correspondence, reports) or by office or ministry creating them. For example, there are sections of the schedule devoted to financial administration, personnel management, liturgy, etc.

b) Each of these 13 functional areas is broken down into sub-categories to make it easier to find the exact policies that apply to the records you are looking up. From the example below, you can see that records produced through the Financial Administration function are divided into 7 sub-categories.

c) Policies relating to individual records series are found within these sub-categories.

Example:   FINANCIAL ADMINISTRATION

- Accounting
- Authorization
- Banking
- Budget Development
- Development & Fundraising
- Payroll
- Tax

2. Match Records to the Appropriate Policy in the Schedule

a) Think about the records you have a question about in terms of the work function they relate to, and then match them to the closest sub-category within that area.

Example:   Wondering how long to keep old time sheets? These have to do with paying employees (a financial activity), so you would first refer to the Financial Management section of the schedule. Drilling down a bit, which sub-category within the Financial section do they specifically pertain to? (ANSWER: Payroll)

b) Once you’ve identified the right section, scroll down to that part of the schedule until you find the correct record category ("series”). Don’t just rely on series titles though. In a lot of cases, you will need to read the series descriptions because often several types of related records have been grouped together into one series.

Example:    Continuing from the example above, there are 5 types of payroll records listed in the schedule. Read through them, and you will find the last one is “Timecards.”  Eureka!

c) Now refer to the retention period (how long to keep the records) and disposition policy (what to do with the records when they’ve expired) for that particular record series.

3. Understand the retention periods and disposition types

a) Retention periods have 2 parts. Think of them as the “trigger” and the “countdown.”

• The trigger, the first part, tells you when to start counting down to the expiration date. These are usually time-based (end of fiscal year; end of calendar year), but sometimes they’re event-based (sale of building, end of project, etc.).

• The second part of the retention period is the countdown. This just tells you how many years after the trigger you need to keep the records.

Examples:

• Fiscal year + 6 means retain for 6 years after the fiscal year in which record was created.
• Calendar year + 1 Retain for 1 year after the calendar year in which record was created.

b) Dispositions policies tell you what to do with the records after their retention period has expired. There are 5 disposition types for school records.

• • Shred: Records contain private/sensitive information.
  • Recycle: Records do not contain private/sensitive information.
  • Delete: Means just that!
  • Archives: Records have long-term value to the Archdiocese and need to be securely stored in your archives, whether physical or electronic.
  • Archival Review: Consult someone in Chancery Archives to make a final determination.

There are no retention requirements for the following types of materials. These can be disposed of as soon as they have served their immediate purpose. Shred, recycle, or delete as appropriate. 

Document Errors 

• Incorrect versions of documents, forms, or reports that had to be recreated to correct errors in typing, data entry, spelling, grammar, or format 
  

Drafts and Working Materials   

• Preliminary or incomplete drafts that do not contain significant comments, approvals, or substantial changes that give insight into the development of the final version. Can be disposed of when a subsequent draft or finished records has been developed.
  

Duplicates  

• Extra copies used only for reference or informational distribution    
• Electronic documents which are used to produce a hard copy (official) version which is maintained in the hard copy files  
• Email CCs (carbon copies) and BCCs (blind carbon copies) where you have been copied for informational purposes only and are not expected to take action yourself  
  

External Materials 

• Publications, promotional material, etc. from external sources once these have served their purpose. 
  

Information or Forms Used to Create or Update another Record 

• Will become obsolete once the update or data entry is validated.  
• Includes paper forms where the data is entered into an electronic system, spreadsheet, or database.
  

 Informal Communications or Notifications 

• Can take many forms (e.g. email messages, chat messages in online collaboration tools, social media postings, facsimile [fax], voice/video message recordings). 
• Acknowledgements, form-letter thank you notes 
• Announcements of meetings or social events 
• Answers to routine requests for information do not require administrative action or policy decisions 
• Memos and postings that do not relate to the main purpose or responsibilities of an office 
• Personal communications 
• Requests to call someone 
• Reservations, confirmations, itineraries 

When litigation, an audit, or investigation occurs or is reasonably anticipated, a written notice (referred to as a “Litigation Hold Notice” or “Legal Hold”) will be issued to appropriate staff. All records, whether official records, information copies, working documents, or transitory records, potentially relevant to the matter must be retained until the Litigation Hold is terminated. The effect of this notice is to freeze or suspend the destruction or alteration of records, electronically stored information, and other materials identified in the notice.  

Records relevant to the matter may not be destroyed – even if the retention period in this retention schedule has expired or expires during the Litigation Hold – until the action is resolved and a notice terminating the Hold has been issued. There are serious legal consequences for individuals that destroy or alter records under a Litigation Hold or know of a pending issue and do not halt destruction.  

This is an at-a-glance tool to help staff, volunteers, and IT support quickly identify the permanent records of your school. It is NOT a substitute for using the Records Retention Schedule for Archdiocesan Catholic Schools, which describes retention and disposal requirements for all school records.   

For more information, please refer to the schools retention schedule or contact a records manager at archives@seattlearch.org. 

Accident Prevention/Safety Manuals

Final, adopted versions

Board, Committee, Council & Lay Group Records

• Constitutions & bylaws
• Meeting agendas, minutes, handouts, surveys, and audio or video recordings.

Course Planning & Development Records

• Academic annual calendars
• Course catalogs
• Curriculum summaries & guides
  

Establishing Records

• Articles of incorporation
• Canonical appointments
• Decrees of establishment
• Power of attorney

Financial Records

• General ledgers
• Budget, final
• Bequests, trusts & endowments
• Payroll vendor reports (ADP, pre-2014): retain all pre-2005 reports and the last master control report of each calendar year.

Insurance records purchased before 1990

Legal Records

• Legal counsel’s advice and opinions
• Litigation work product files

Liturgy Records

• Calendar of liturgies
• Liturgical minister’s schedule
• Orders of celebration/ordos
• Programs/handbills
• Repertory calendar

Marketing Records

• Logos
• Marketing materials

Musical and Theatrical Performance Records

• Repertory calendars
• Theatrical/music programs

Personnel Files

Includes, but not limited to*:

• Teacher contracts/covenants
• Background checks, positive criminal history results
• Employee performance evaluations
• HIPAA training certificates
• Safe environment training proof of completion
• Terminated employee records

*Please see the following section Personnel Files: Employees and Volunteers for a complete list of documents which must be kept in an employee personnel file. 

Policies, Guidelines, Procedures

Final approved policy documents developed and implemented by Archdiocesan Catholic Schools

Principals/Presidents’ Correspondence

Includes email mailboxes in addition to paper correspondence.

Property and Construction Records

• Blueprints & architectural plans
• Property & construction project files (Records relating to the design, permitting, and construction or additions/remodels affecting the structure of the building/facility)
• Hazardous material safety data sheets (MSDS) & asbestos reports

Public Statement

Press releases & public service announcements

Records Destruction Certificates

Records certifying the physical disposal/deletion of records that have completed their retention period

Research and Planning Records

• Annual reports
• Census records (faculty and student)
• Surveys, studies, reports & recommendations

School Publications and Memorabilia

• Anniversary books and videos
• Baccalaureate & commencement programs
• Bulletins, newsletters, newspapers & mass mailings
• Historical newspaper clippings
• Historical photographs
• Parent & student handbooks
• Periodicals published by the school
• School directories
• Scrapbooks
• Website records
• Yearbooks/annuals
• Yearbooks/annuals photographs

Sexual Abuse/Misconduct Notifications

Include, but not limited to, letters, electronic messaging (emails, text messages, voice messages), and documentation of verbal conversations.

Student Evaluations

• Cumulative record cards
• Graduate lists

Training Records

Training materials, final version – (training programs such as conferences, seminars, certifications, classes, workshops, and similar educational gatherings. Does not include academic instruction. May include, but not limited to: course curricula, reference publications, manuals, booklets, syllabi, outlines, agendas, handouts, and readings.

The following information is from Human Resources at the Archdiocese of Seattle:

Personnel files should contain:

• Safe Environment Program Church Personnel Agreement
• Background check, completed within the last 3 years (can be kept in vendor software, see SS505-05)
• HR Policies Agreement Form
• Employee emergency contact information
• Documentation of the current fiscal year employee pay rate (authorized, amount, effective date, and reason)
• Documentation of current Safe Environment Training

For regular employees and temporary employees on benefits, the file is also to contain:

• Letter of Employment Agreement
• Job description, signed by the employee and supervisor
• Performance evaluation completed within the last year

Form I-9 Employment Eligibility forms should not be filed in employee files, but rather in a separate binder or file.

The following policy is from the Archdiocese of Seattle Office for Catholic Schools:

Because of the confidential nature of some information regarding employees, and to meet with federal regulations, more than one file should be established for each employee. Three files are listed below. It is recommended that each file for an employee be a different color, to designate the purpose of the file. For proper management of files, all files regarding an employee should be housed in one location. If for any reason a file is housed in a different location, the main file (personnel file) should indicate where the other file is housed. In case of subpoena, all files must be produced. If files are subpoenaed, one person should be given responsibility for assembling and presenting the files.

1. Personnel file for current employees:

a. Directory of Information:
• Date of hire *
• Assignment; any subsequent changes in assignment *
• Address *
• Phone *
• Date of end of employment *

b. Employee Selection Data:
• Resume
• Archdiocesan application (includes: WSP form, employee disclosure statement and INS Employee Eligibility Verification form)
• Correspondence related to hiring (if any)
• Skill test results* (where applicable)

c. Certification:
• Signed “Safe Environment Church Personnel Agreement Form”
• Certificate for Safe Environment training.
• Teaching certificate
• Any required job permits (health card for kitchen worker, 1st aid card for daycare, etc.)
• Catechetical Certification

d. Academic Record:
• Record of college/university courses (transcripts). Do not keep the rest of the placement file.
• Transcripts for any additional coursework that determines salary increases

e. Notation of significant achievements

f. Performance documentation:
• Formal, signed evaluations
• Signed employee improvement plans

g. Miscellaneous:
• Record of accrued sick leave
• Current contract
• Copy of any employment dispute settlement that may have been assigned

* Only these items should be kept on file permanently after employment ends. The rest of the file should be kept for 6 years after employment ends.

2. Principal’s File:

a. Records from employee application interview
b. Pre-employment reference checks, indicate person contacted, phone number and summary statement
c. Documentation regarding complaints, performance issues, etc.
d. Any notes compiled as the result of possible or pending litigation. When an attorney has been contacted, these notes constitute a “work product file.” Once a settlement agreement has been signed, these notes and the agreement are retained until the file is no longer active and for 7 years thereafter. At this point the agreement is placed in the personnel file. All supporting documentation is destroyed.

Note: These items do not belong in an employee’s personnel file, which may be viewed by various supervisors. At the same time, it is important to note that the above items should be factual and may be subpoenaed. Destroy this file upon termination of employment unless legal action is pending.

3. Employee Medical File:

a. All medical data
b. Any materials related to FMLA or ADA
c. Injury reports
d. Disability leave reports

Note: These items must be kept separate from the employee’s personnel file. Destroy this file upon termination of employment unless legal action is pending.