Inactive or expired non-electronic 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 ManagementThe 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 SchedulesRecords are to be maintained only for the recommended retention period, except if a "do not destroy" directive applies. Documents no longer required for any ministerial, canonical, legal, historical, or operational purpose must be disposed of or destroyed at the end of the retention period. Annual File ReviewIf 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 DocumentsEach 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 Personnel FilesAccess to Confidential Documents
– The general rule on access to confidential documents is that regardless of where confidential documents 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
– The Archdiocesan Catholic Center (ACC) and Catholic Cemeteries and Mortuaries lay personnel and medical records are maintained at the ACC by the Human Resources Department, which supervises access to such files at other locations. Insurance records for ACC and Catholic Cemetery and Mortuary employees are maintained at the ACC by the Insurance Department. Records other than the general personnel file (such as medical or disability files) are maintained in confidential folders in secured filing cabinets, separate from general personnel records. Lay personnel records for ACC and Catholic Cemeteries and Mortuaries staff may be accessed only by the Human Resources Department.Records Maintained at Parishes and 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/administrator 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. School staff records may be accessed by the superintendent and assistant regional superintendents. Persons authorized by the Human Resources Department or the superintendent or assistant regional superintendents may also access the records upon request.
Electronic Communications SystemsElectronic 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 ProvisionsEach location is responsible for maintaining its own records. Records may be maintained on-site or stored off-site at a secure record retention facility or a secure electronic storage service that adheres to the Electronic Communications Acceptable Use and Responsibility policy. 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 213-637-7460 for clarification.QuestionsAll 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 213-637-7460. The chancellor may then consult canonical and civil counsel in determining a response.2 EnforcementThe 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.
No person is allowed to remove or keep any archdiocesan documents from any location without express permission from the person in charge.