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17.3.3.1 General Provisions


Follow Applicable Retention Schedules

Archdiocesan documents shall be maintained according to the guidelines established in the Record Retention Schedule (sorted by category and record type). Please see Directions for Using the Record Retention Schedule and Document Management Tips

Filing Method

Locations should file and retain documents in a manner that permits ready application of the retention period for particular records. For example, documents or records of a uniform or like type and date range should be stored in boxes bearing a written designation "Destroy After ___ [insert date]." 

Compliance Management

The person in charge should designate one or more staff members, who are authorized to have access to confidential documents, to be responsible for document retention compliance.

Adherence to Retention Schedules

Records are to be maintained only for the recommended retention period; documents no longer required for any ministerial, canonical, legal, historical, or operational purpose must be disposed of or destroyed. 

Annual File Review

If records of different date ranges are stored and interspersed with active files, the person who is responsible for document retention compliance should undertake at least an annual review of files to remove and segregate those records that no longer need to be retained under the applicable retention period. Any such records should then be destroyed. 

Disposal of Documents

Each location is responsible for the prompt disposal or destruction of all documents upon expiration of the scheduled retention period.​

Nonconfidential Documents

​​​Documents that do not contain any confidential information may be disposed of by recycling or by discarding with other refuse.

Documents Containing Confidential Information

Documents that contain any confidential or private information must be destroyed to prevent the confidential information from being obtained and misused for identity theft, fraud, or other unlawful purposes. Such documents must be destroyed under the direct supervision of the person in charge or his or her delegate, in a manner that reasonably ensures that confidential information may not be sifted out of the waste materials, and must be destroyed at the location. However, the location may retain the services of a reliable and reputable document disposal company that provides secured document disposal/shredding and a certificate of disposal.

Authorized Access to Files

The general rule on access to confidential documents is that regardless of where confidential records are located, they may be accessed by the archbishop or his delegate, and the chancellor, the director of human resources or the legal department if the documents pertain to their functions, and such persons as may be authorized by any of the foregoing.

Records Maintained at the Archdiocesan Catholic Center and Catholic Cemeteries

The Archdiocesan Catholic Center  (ACC) and Catholic Cemeteries lay personnel and medical records will be maintained at the ACC in a uniform manner by the Human Resources Department, which supervises access to such files by other locations. Records other than the general personnel file (such as medical or disability files) will be maintained in confidential folders in secured filing cabinets, separate from general personnel records. Lay personnel records for ACC and Catholic Cemeteries staff may be accessed only by the Human Resources Department.

School staff records may be accessed by the superintendents and assistant superintendents. Persons authorized by the Human Resources Department or the superintendents or assistant superintendents may also access the records upon request.

Financial records may be accessed by staff of the Financial Services Department and any persons granted access by the director of financial services or his or her authorized representative.

Records Maintained at Parishes/Archdiocesan Schools

Lay personnel or medical records located at a parish or a school in the archdiocese will also be maintained in a uniform and organized manner, in secured files, with access to those records supervised by the pastor or his designee, or in the case of school records, the principal or his or her designee. Records other than the general personnel file (such as medical or disability files) will be maintained by the parish or school in confidential folders in secured filing cabinets, separate from general personnel records. Access to confidential records of this nature is restricted to the pastor or his designee, or the principal or his or her designee.

Electronic Communications Systems

Electronic communications systems (ECS) are primarily intended to take advantage of a fast and automated means of communication, and to exchange information more efficiently than by telephone or written memorandum. Such systems also reduce the generation and handling of paper documents by shifting the creation, transmission, and retention of short-term correspondence to electronic form. However, these electronic systems, too, can become cluttered with unnecessary documents that have outlived their usefulness. Therefore, all ECS services managed by archdiocesan staff will adhere to the retention schedules that are set forth in this Policy.

Miscellaneous Provisions

Each location is responsible for maintaining its own records. Records may be maintained on-site or stored off-site at a secure record retention facility. The chancellor, in consultation with the archbishop's canonical adviser and the archdiocesan general counsel , is responsible for establishing retention schedules for any records not identified in the Record Retention Schedule (sorted by category and record type ). If two retention times appear to conflict, select the longer retention time and contact the Chancellor's Office at 213-637-7479 for clarification.

Questions

All questions about the retention and disposal or destruction of specific documents or the location's responsibility for maintaining certain types of records should be referred to the Chancellor's Office at 213-637-7479 . The chancellor may then consult canonical and civil counsel in determining a response.

17.3.3.2 Enforcement

The success of the Document Retention Policy for the Archdiocese of Los Angeles lies in uniform and diligent enforcement of its provisions. For this reason, the failure by a staff member to comply with these provisions may subject that staff member to disciplinary action, up to and including termination of employment, where applicable. Any staff member found to have knowingly and intentionally violated this policy will be subject to serious sanctions.