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CITY OF GUELPH CORPORATE POLICY AND PROCEDURE
POLICY
Records and Information Management( RIM) Policy
CATEGORY
Corporate Services
AUTHORITY
City Clerk's Office
RELATED POLICIES
Access and Privacy Policy, Acceptable Use Policy, Bring Your
Own Device (BYOD), Network Backup Policy, Code of
Conduct for Council and Local Boards
APPROVED BY
Executive Team
EFFECTIVE DATE
March 23, 2017
________________________________________________________________________________________________________
POLICY STATEMENT
The City of Guelph is committed to consistently managing, retaining and preserving
the information assets of the municipality. The City recognizes that information and
records are valuable corporate assets that support accountable, transparent and
effective government administration, customer service, organizational efficiency,
decision making, business continuity and litigation support.
PURPOSE
The purpose of this policy is to ensure consistent standards and practices for the life
cycle management of records in the custody and control of the City. This policy
ensures that, regardless of format or medium, records and data are managed
consistently across the corporation from the time they are created, used, retained
and disposed of or preserved.
SCOPE
This policy applies to all City employees, including full-time, part-time, casual,
contract, volunteer and co-op placement employees.
This policy applies to all corporate information, in any format, including records,
data and knowledge managed by the City.
This policy applies to the records and information of the Office of the Mayor and
members of Council that are created and used for the purpose of carrying out City
business.
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CITY OF GUELPH CORPORATE POLICY AND PROCEDURE
POLICY
Accurate, useable and accessible information supports open, transparent and
accountable local government by improving customer service and program delivery.
This means that the City:
Integrates record keeping practices with service delivery;
Integrates records and information management practices with performance
management; and
Invests in records and information management awareness, training and
communication.
All employees share responsibility for the proper management of corporate
information assets.
As a critically valuable resource, it is recognized that information must be managed
reliably to improve City programs and services in the same manner and given the
same consideration as other valuable corporate resources.
The following principles and practices are the framework for effectively managing
information assets at the City.
Accountability and transparency
In recognition of public accountability, information that does not contain
confidential or personal information about the City, its programs, services
and governance is available to the public.
The access to and disclosure of corporate information is administered in
accordance with the Access and Privacy Policy, the Municipal Freedom of
Information and Protection of Privacy Act (MFIPPA) and the Personal Health
Information Protection Act (PHIPA).
Employees should have access to information they need to meet their
responsibilities in a timely and efficient manner.
In accordance with MFIPPA, it is an offence to willfully alter, conceal,
destroy/delete or cause any person to do so, with the intention of denying
access to a record or information contained in a record.
Quality and integrity
Information quality is assured at the point of collection or creation, and
administrative records are created within a reasonable time of the
transactions or events they document to the greatest extent possible.
Official and/or final versions of records or data are known and accessible.
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CITY OF GUELPH CORPORATE POLICY AND PROCEDURE
Transitory records and information which does not need to be retained
according to the records retention by-law are destroyed on a routine basis.
The integrity, authenticity, reliability and usability of information assets must
be preserved throughout the lifecycle of the asset.
Storage
Information must be stored in the appropriate department drive, system of
software to ensure that it can be accessed when needed. Unless a document
or data contains personal, confidential or classified information it should be
shared, available and accessible to other City employees.
Security
As a corporate asset, information created and used in the course of City
business is the property of the City.
The City will establish and maintain procedures and other controls to ensure
the security of its information, including prevention of unauthorized access to
its systems, third party and remote access.
The City will establish and maintain a security classification protocol, used to
classify all of its information. This protocol guides appropriate practices
related to labeling, storing, sending and sharing information, disposal,
protection of integrity and appropriate use and disclosure of information.
Security incidents are to be reported to the City Clerk's Office and/or IT, as
appropriate, and investigations involving security and/or privacy breaches
are conducted as needed.
Lifecycle management
Employees, vendors and contractors are responsible for managing
information from the time it's created, used, stored, and either destroyed or
preserved according to the records retention by-law.
The retention and disposal of all City business records is governed by the
most current records retention by-law. Retention of any business records
must be consistent regardless of format, storage location or system.
The City manages its records retention by-law for all business records to
comply with legal requirements and meet business needs.
The records retention by-law is reviewed annually and, if necessary, updated
to reflect reasonable retention requirements.
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CITY OF GUELPH CORPORATE POLICY AND PROCEDURE
The City will establish and maintain a records classification scheme, will to
classify all City business records, in any format, by the functions and
activities in which they are used.
The City Clerk or delegated employees must sign off and approve the
disposition of all original business records prior to destruction in accordance
with the records destruction procedure.
While most of the City's information is appropriately destroyed or disposed of
when it becomes obsolete or legal requirements have passed, some
information assets are of enduring archival value and must be preserved to
maintain corporate history and memory. The City establishes and maintains
procedures to identify and ensure the permanent preservation of information
assets of archival value.
Compliance
The City complies with records and information management requirements of
all laws, regulations and standards related to its operations and adheres to
generally accepted information management standards and best practices.
The City establishes and maintains internal procedures, standards, guidelines
and best practices required to comply with laws, regulations and policies.
The City promotes compliance with this policy and associated procedures,
standards, guidelines and best practices by supporting all employees to meet
their records and information management responsibilities though education
and training.
RESPONSIBILITY
The Chief Administration Officer (CAO) will:
Provide oversight and compliance with this policy by all City employees.
Deputy Chief Administration Officers (DCAO's) will:
Administer and communicate this policy broadly to employees in their service
areas;
Promote a culture and business practices that ensures City information is
shared and accessible to the greatest extent possible, while respecting
privacy requirements of personal information and other confidentiality
obligations; and
Integrate the appropriate management of information assets into the
development, implementation, evaluation and reporting activities of service
area programs and services.
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CITY OF GUELPH CORPORATE POLICY AND PROCEDURE
The City Clerk and delegated employees will:
Ensure the appropriate retention and availability of corporate records and
information assets in accordance with the Municipal Act;
Be accountable for the administration of the Records and Information
Management Program within the municipality;
Ensure oversight of and compliance with this policy;
Establish safeguards to protect archival records and information to preserve
corporate memory;
Develop standards, procedures, guidelines, training material and other tools
as required, to assist members of Council, employees and the public on
matters pertaining to the creation, use, storage, retention and disposition of
city information assets;
Ensure that legislative updates are incorporated into the City's records
retention by-law; and
Ensure that the corporate destruction procedure in place is adhered to.
The General Manager Human Resources will:
In partnership with the City Clerk, establish a training and education plan to
improve awareness of records and information management requirements;
and
Build records and information management awareness into all new employee
orientation programs.
The General Manager Technology and Innovation will:
In partnership with the City Clerk, implement and integrate with records and
information management policies, standards, and procedures in enterprise
architecture, systems and technologies where appropriate; and
Ensure records and information management considerations, including
retention and disposition, are built into all new technological systems or
applications involving corporate information assets prior to implementation.
General managers, managers and supervisors will:
Implement this policy and communicate requirements to the employees
under their direction;
In collaboration with the City Clerk and procurement/purchasing staff,
require vendors and contractors comply with this policy, ensuring that
information asset ownership, retention and disposition requirements are clear
and are referenced in all procurement documents;
Ensure information management considerations, including retention and
disposition, are considered and planned for any new programs, services or
technologies; and
Promote a culture and business practices that ensures City information is
shared and accessible to the greatest extent possible while respecting
security and privacy requirements of personal information; and
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Ensure the City Clerk or delegated employees are aware when there are
changes in legislation, guidelines, or in your business process that affects the
length of time a record in your area needs to be kept.
Employees will:
Understand their responsibilities as information creators, organizers and
managers;
Dispose of transitory, duplicate or old versions of records or data in a timely
fashion to prevent clutter, difficulty finding important information and
additional storage expenses;
Store information assets in the appropriate network drive, system, database
or application, rather than personal drives, Outlook or external storage
services outside the control of the City;
Take records and information asset management training as required; and
Adhere to information management requirements contained in this policy and
other related standards and procedures, including the records retention by-
law.
MONITORING AND REPORTING
Failure to comply with this policy can result in inadequate information to support
business decision making, can impact the quality of customer service provided to
the public, can result in the inadmissibility of records in legal proceedings,
regulatory sanction, and/or excessive costs for record creation, storage and
handling. Employees who fail to comply with this policy may be subject to
disciplinary and/or legal action, as deemed appropriate.
The City recognizes that compliance is an ongoing and evolving process and
anticipates continuous improvements in its efforts to meet the expectations of this
policy.
The City Clerk's Office monitors compliance, engagement and awareness of this
policy with:
information management reporting documents;
the results of audits and/or inventories;
training and education session evaluations; and
employee surveys.
This policy is reviewed a minimum of once per calendar year to ensure its
effectiveness and compliance with legislation and current business processes or as
required based on legislative changes.
For further information regarding this policy please contact the Program Manager
Information, Privacy and Elections at 519-822-1260 extension 2605 or at
[email protected].
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CITY OF GUELPH CORPORATE POLICY AND PROCEDURE
REFERENCE MATERIAL
City of Guelph Records Retention By-law
Municipal Act, 2001
https://www.ontario.ca/laws/statute/01m25
Municipal Freedom of Information and Protection of Privacy Act
http://www.e-laws.gov.on.ca/html/statutes/english/elaws_statutes_90m56_e.htm
Personal Health Information Protection Act
http://www.e-laws.gov.on.ca/html/statutes/english/elaws_statutes_04p03_e.htm
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CITY OF GUELPH CORPORATE POLICY AND PROCEDURE
APPENDIX A: DEFINITIONS
Archival means information assets of enduring significance that have historical and
business value for the City of Guelph and individuals engaging in historical
research.
Authenticity means the extent to which a business record can be proven to be
what it purports to be.
Business records means any records that are created by City employees, or by a
third party directly paid by and working on behalf of the City, in order to document
the decision making, administration or operational activities of the City. This
includes documents in any form, including physical paper files, digital files in any
machine readable format, emails, instant messages, video, etc.
City means the Corporation of the City of Guelph.
Control (of a record) means the power or authority to make a decision about the
use or disclosure of a record.
Custody (of a record) means the keeping, care, watch, preservation or security of
a record for a legitimate business purpose. While physical possession of a record
may not always constitute custody, it is the best evidence of custody.
Data means any symbols or characters that represent raw facts or figures and form
the basis of information
Destruction is the physical or electronic disposal of records or data by means of
shredding, recycling, deletion or overwriting. This also includes the destruction of
records or data residing on computers and electronic devices supplied or paid for by
the Corporation.
Dispose means to destroy a record or remove it from the official record keeping
system. For digital records this involves deleting files and ensuring that any
backups, such as in the desktop `recycle bin` have been deleted as well. For paper
documents, this involves recycling, shredding or securely disposing of papers.
Head refers to the City Clerk.
Information asset means organized information that is valuable and easily
accessible to those who need it. Information assets come in a variety of formats
including records, data and documented corporate knowledge.
Information management means the administration of information, its use and
transmission, and the application of theories and techniques of information science
to create, modify, or improve information handling systems
Integrity means the extent to which a business record is demonstrably complete
and unaltered.
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CITY OF GUELPH CORPORATE POLICY AND PROCEDURE
Institution means the Municipality.
Lifecycle management means the administration of information assets from the
time they are created, actively used, inactively stored and retained, as well as,
disposed of or preserved.
Municipal Freedom of Information and Protection of Privacy Act (MFIPPA)
means legislation that governs access to and the privacy of municipal records.
Permanent means that records and information shall be preserved for the life of
the Corporation and never destroyed or removed from the official records keeping
system.
Personal Information means recorded information about an identifiable individual
including:
a) Information relating to the race, national or ethnic origin, colour, religion,
age, sex, sexual orientation, or marital or family status of the individual;
b) Information relating to the education or the medical, psychiatric,
psychological, criminal or employment history of the individual or information
relating to the financial transactions in which the individual has been
involved;
c) Any identifying number, symbol, or other particular assigned to the
individual;
d) The address, telephone number, fingerprints or blood type of the individual;
e) The personal opinions or views of the individual except if they relate to
another individual;
f) Correspondence sent to an institution by the individual that is implicitly or
explicitly of a private or confidential nature, and replies to that
correspondence that would reveal the contents of the original
correspondence;
g) The views or opinions of another individual about the individual, and
h) The individual's name if it appears with other personal information relating to
the individual or where the disclosure of the name would reveal other
personal information about the individual.
Personal Health Information means identifying information about an individual
in oral or recorded form, if the information:
a) Relates to the physical or mental health of the individual, including
information that consists of the health history of the individual's family;
b) Relates to the providing of health care to the individual, including the
identification of a person as a provider of health care to the individual;
c) Is a plan of service within the meaning of the Home Care and Community
Services Act, 1994 for the individual;
d) Relates to payment or eligibility for health care, or eligibility for coverage for
health care, in respect to the individual;
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CITY OF GUELPH CORPORATE POLICY AND PROCEDURE
e) Relates to the donation by the individual of any body part or bodily substance
of the individual or is derived from the testing or examination of any such
body part of bodily substance;
f) The individual's health number; or
g) Identifies the individual's substitute decision maker.
Record means any unit of information however recorded, whether in printed form,
on film, by electronic means, or otherwise, and includes correspondence,
memoranda, plans, maps, drawings, graphic works, photographs, film, microfilm,
sound recordings, videotapes, machine readable records, an e-mail and any other
documentary material regardless of physical form or characteristics, made or
received in the course of the conduct of City business.
Records Retention By-law means the most recent by-law passed that contains
the schedule and the length of time City business records must be retained for
before it may be disposed of in order to meet business needs and legislative
requirements.
Reliability means the extent to which the contents of a record can be trusted as a
full and accurate representation of the transactions, activities or facts to which they
attest and can be depended upon in the course of subsequent transactions or
activities.