Policy: JCS, Inc. generates, receives, and stores many documents and records of a confidential nature. If confidential documents and records are not securely maintained and periodically destroyed/shredded, there is a potential danger that individuals’ confidential information can be obtained and/or misused. It is the purpose of this policy, therefore, to specify the methods and responsibilities for the secure storage and destruction/shredding of confidential documents and records. Definitions: Confidential documents and records are those containing any or all of the following information: * Anything containing a social security number. * Anything containing a name and date of birth. * Anything containing a credit card number. * Academic information including, but not limited to, test scores and transcripts, where individuals are identified by name and/or social security number. * Other information regarding students including, but not limited to, records of disciplinary proceedings. * Medical records. * Any other information considered confidential in accordance with the provisions of the Federal Educational Right to Privacy Act and applicable state statutes and education code. Document Storage and Shredding Procedures: 1. Collect and store all documents and records containing confidential information, as defined above, in a secure location. A secure location shall be any storage area that can be securely locked, is supervised throughout the business day, and which is not readily accessible to persons not authorized to move about freely within the facility. 2. At the discretion of the Executive Director, confidential documents and records may be destroyed by shredding by designated individuals, without first being securely stored, if: 1. The records/documents have met the retention requirements set forth by the School and any applicable statutes or regulations and they are not involved in any on-going audit, litigation or academic or administrative process and/or if the document(s) or record(s) are no longer needed after having been reviewed, read or otherwise processed within a one-week period of time. 3. Confidential documents and records shall be destroyed by shredding, provided all retention requirements, as discussed above, have been met. 1. Copies of confidential documents and records supplied to administrators, teachers, or other staff for administrative purposes should be shredded after they have been reviewed, read or otherwise processed. 2. Copies of student files and records for withdrawn students, maintained by administrators, teachers, or other staff for the purposes of documenting student attendance, conduct, work samples, academic growth or other learning period/yearly documentation, should be shredded at the end of the school year after ensuring that all original documents and records have been forwarded to the main administrative office. 4. Confidential records found by any employee in a location other than where they are to be properly stored should be brought to the attention of the Executive Director for further action consistent with this policy. Policy: This policy specifies how important documents (hard copy, online, or other media) should be retained, protected, and eligible for destruction. The policy also ensures that documents are promptly provided to authorities in the course of legal investigations or lawsuits. Document Retention Schedule The following types of documents will be retained for the following periods of time. At least one copy of each document will be retained according to the following schedule. Corporate Records Articles of Incorporation Permanent Corporate Bylaws Permanent IRS Form 1023 to file for tax-exempt and/or charitable status Permanent IRS Letter of Determination granting tax exempt status Permanent State Application for Tax Exempt Status (Form 3500) Permanent State Determination Letter granting tax exempt status Permanent Board Policies/Resolutions Permanent Board and Committee Meeting Minutes Permanent Sales Tax Exemption Documents Permanent Tax ID Number Designations Permanent Annual Corporate Filings Permanent Financial Records Chart of Accounts Permanent Fiscal Policies and Procedures Permanent Audits Permanent Financial Statements Permanent General Ledger Permanent Check Registers/Books 7 years Business Expense Documents 7 years Bank Deposit Slips 7 years Cancelled Checks 7 years Invoices 7 years Investment Records (deposit, earning, withdrawals) 7 years Property and Asset Inventories 7 years Petty Cash Receipts/documents 3 years Credit Card Receipts 7 years JCS, Inc. Document Retention and Destruction Page 1 of 5 Tax Records IRS Annual Tax Filing Form 990 Permanent FTB Annual Form 199 Permanent Payroll Registers Permanent IRS Form 1099 Filings 7 years Payroll Tax Returns and Withholding Returns 7 years Earnings Records 7 years W-2 Statements 7 years Personnel Records Employee Offer Letters Permanent Employment At-Will Agreements 7 years after Term Confirmation of Employment Letters Permanent Benefits Descriptions Per Employee Permanent Pension Records Permanent Employee Applications and Resumes 7 years after Term Promotion/Demotion/Letter of Reprimand/Letter of Termination 7 years after Term Job Descriptions, Performance Goals 7 years after Term Workers’ Compensation Records 5 years after date of injury and 2 years after claim has been closed I-9 Forms 5 years after Termination Time Reports 3 years after Termination Insurance Records Property Insurance Policy Permanent Directors and Officers Insurance Policy Permanent Workers’ Compensation Insurance Policy Permanent General Liability Insurance Policy Permanent Insurance Claims Applications Permanent Insurance Disbursements/Denials Permanent Contracts All Insurance Contracts Permanent Employee Contracts/At-Will Agreements Permanent Construction Contracts Permanent Legal Correspondence Permanent Loan/Mortgage/and Real Estate Documents Permanent Vendor Contracts/Agreements 7 years Warranties 7 years JCS, Inc. Document Retention and Destruction Page 2 of 5 Donations / Fundraising Grant Dispersal Contract Permanent Donor Lists 7 years Grant Applications 7 years Donor Acknowledgments 7 years Management Plans and Procedures Strategic Plan 7 years Staffing, programs, marketing, finance, fundraising and evaluation plans 7 years Vendor Contracts 7 years Comprehensive Safety Plan (Updated Annually) 7 years Pupil Records Mandatory Permanent Student Records (Original or copy) which shall consist of the following: Permanent* Legal name of student Date of Birth Method of Verification of Birth Sex of student Place of Birth Name and Address of Parents of Minor Student Address of minor student if different than above An annual verification of the name and address of the parent and the residence of the student. Entering and leaving date of each school year and for any summer session or other extra session. Subjects taken during the year, half-year, summer session, or quarter. If grades or credit are given, the grade or number of Individual Student Injury Record for Which a Claim was Filed. 1 year after the claim has been settled or after the statute of limitations have run. Mandatory Interim Student Records which shall include the following: 3 years after usefulness ceases. JCS, Inc. Document Retention and Destruction Page 3 of 5 (A) A log or record identifying those persons (except authorized school personnel) or organizations requesting or receiving information from the record. The log or record shall be accessible only to the legal parent or guardian or the eligible pupil, or a dependent adult pupil, or an adult pupil, or the custodian of records. (B) Health information, including Child Health Developmental Disabilities Prevention Program verification or waiver. (C) Participation in special education programs including required tests, case studies, authorizations, and actions necessary to establish eligibility for admission or discharge. (D) Language training records. (E) Progress slips and/or notices as required by Education Code Section 49066 and 49067. (F) Parental restrictions regarding access to directory information and related stipulations. (G) Parent or adult pupil responders to challenged records and to disciplinary action. (H) Parental authorizations or prohibitions of pupil participation in specific programs. (I) Results of standardized tests administered within the preceding three years. Permitted Student Records which shall include the following: 6 months after usefulness ceases. (A) Objective counselor and/or teacher ratings. (B) Standardized test results older than three years. (C) Routine discipline data. (D) Verified reports of relevant behavioral patterns. (E) All disciplinary notices. (F) Attendance records not covered in the Administrative Code Section 400. Independent Study Records1 3 years minimum and 1 Independent study records are mandatory interim student records which must be compiled and maintained for the stipulated period of time and are then destroyed in accordance with state law, regulation or administrative directive. (5 CCR 430). JCS, Inc. Document Retention and Destruction Page 4 of 5 may be kept electronically (A) Adopted written Board Policies. (B) Written Learning Agreement (C) Daily Attendance Log (D) Work Assignments and Work Records (E) Representative Student Work Products (F) Teacher Records (apportionment and academic) (G) School Apportionment Records *Option to electronically in cloud storage and destroy original Document Protection To ensure that documents (hardcopy, online or other media) are available when needed, documents will be stored primarily on site but if needed, off-site storage will be used. The Corporation may contract with vendors for cloud computing services, digital storage, and educational software related to pupil records if they comply with the requirements of Education Code section 49073.1. With respect to document retention, the third-party contractor must certify that pupil records shall not be retained or available to the contractor upon completion of the contract. Failure to comply with the requirements in Education Code section 49073.1 may void the contract. Document Destruction At the end of each school year, hardcopy documents that are eligible for destruction shall be removed from the current-year filing systems and boxed with their potential destruction date and type of records clearly marked on the outside of the storage box. When the destruction date is reached, hardcopy of documents will be destroyed by shredding after they have been retained until the end of the Document Retention Schedule. Online copies will be destroyed by proven means to destroy such media after they have been retained until the end of the Document Retention Schedule. Provision of Documentation for Investigation or Litigation Documents requested and subpoenaed by legally authorized personnel will be provided within the time period legally provided, and in accordance with any applicable Charter School policies. The Board President and Executive Director shall authorize provision of these requested documents. No documents will be concealed, altered or destroyed with the intent to obstruct the investigation or litigation. Original Policy 09/12/06 Revised Policy 09/08/17 Revised Policy 05/08/2020 3004.1 JCS, Inc. Confidential Documents and Records Disposal Policy Page of 2