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S O C I AL H O U S I N G P O L I C I E S
SOS-SH-004-B01
PAGE 1 OF 4
DIVISION:
Social and Community Services
POLICY SECTION:
Social Housing
EFFECTIVE DATE:
12/3/2018
SUBJECT:
Records Management Policy
POLICY NUMBER:
2018-NP-01
SUPERCEDES:
None
1. PURPOSE
1.1 This policy is intended for use by all County of Simcoe housing providers that operate a
designated housing project under the Housing Services Act Rent Supplement (including former
OCHAP/CSHP) and the Centralized Waitlist.
Municipal & Private Non-Profit
Rent Supplement *
*including former OCHAP/CSHP
Co-Operatives
CWL
Federal Non-Profit
Simcoe County Housing
1.2 This policy is intended to outline provisions for the management of records and information
within each housing portfolio within the County of Simcoe to ensure efficiency and
effectiveness as it relates to the creation, maintenance, retrieval, storage and disposition of
records.
2. POLICY STATEMENT
2.1 The County of Simcoe in its capacity as Service Manager is required to establish, as
appropriate, policies and procedures to ensure that official housing records are managed in
accordance with applicable legislation and regulations, as well as, this policy and any other
relevant directives, information bulletins and/or policies.
3. REFERENCES
Housing Services Act, 2011, s. 79 - 81, 169 - 176
O. Reg.367/11, s. 102 - 103, 145 - 147
SOS-SH-004-B01
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4. SCOPE
4.1 By following the procedures outlined below, housing providers will implement efficient and
cost effective management, preservation and destruction of all records. Further, housing
providers will establish the ability to organize, retrieve, provide timely access and responsibly
dispose of records, which is fundamental to the application of sound records management
practices.
4.2 Definitions:
"Active Records" are those records that are referred to on a daily, monthly or annual basis, to
support business processes.
"Destruction" is the physical disposal of records by means of burning, pulping, shredding,
disintegration and the electronic disposal of data by means of deletion and overwriting.
"Inactive Record" refers to those records that have low reference activity, usually less than
once per month, but preserved until its retention period has been fulfilled. Such records are
typically housed in a secure inactive records storage location.
"Records Coordinator" means the Records Coordinator as designated by the housing
provider.
"Records Retention Schedule" is a comprehensive schedule setting out the periods for which
the official records are to be retained. Such a schedule will include the timing for the transfer
of records from active to inactive status, as well as, time periods for the final destruction.
"Retention Period" is the period of time which records must be kept before they may be
disposed of. It is usually stated in months or years and may also be contingent upon the
occurrence of an event (e.g. tenancy termination).
5. PROCEDURES
5.1. All Housing providers must:
a) demonstrate compliance with this policy;
b) report any violation of this policy to their superior and/or the Service Manager, as deemed
necessary;
c) create, classify and store official records in accordance with sound records management
processes;
d) adhere to the retention periods stipulated within the Housing Services Act and its regulations, as
well as, Service Manager's directives and policies;
e) ensure that disposal of records is carried out in accordance with this policy, and the
Organizations destruction procedures;
f)
ensure that records under their custody and control are protected from inadvertent loss or
destruction and properly preserved throughout their life cycle;
g) protect records from unauthorized use or access as prescribed in accordance with this policy and
all applicable legislation and regulations;
h) ensure that all records created are accessible to the Service Manager;
i)
provide evidence of paper and electronic file destruction, annually at minimum
SOS-SH-004-B01
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5.2. Records Coordinator, shall:
a) develop and administer the organizations Records Management Program in accordance
with industry best practices, as well as, legislative and regulatory requirements, this
policy and any other pertinent directives and/or policies;
b) ensure that reasonable measures are established, documented and implemented
enabling the housing provider to properly manage and protect its records from
inadvertent destruction or damage, taking into account the financial and staff resources
available to protect such records;
c) develop and communicate processes which enable departments/staff to maintain
compliance with the organization's records management policy, as well as, this policy;
d) provide records management training to employees;
e) provide information about inactive storage location and retrieval services to the Program
Supervisor;
f) ensure the preservation, security and timely disposition of official records, being
maintained in the inactive storage location, in accordance with the organization's
Records Management Program, industry best practices, as well as, legislative and
regulatory requirements, this policy and any other pertinent directives and/or policies
g) from time to time update and administer other elements of the Records Management
Program, as necessary
5.3.
All official records regardless of format or media, are to be retained for the periods stipulated
in the Housing Services Act and its regulations.
5.4.
The destruction, deletion, alteration or any attempt to discard or interfere with the
accessibility of any official record or other information which may be relevant and required for
ongoing, imminent or pending audit, investigation, and litigation, or through an access
request under freedom of information legislation, is strictly prohibited.
5.5.
Storage:
1. Official records within the custody and control of the housing provider are to remain
accessible and retrievable during the retention period.
2. All official records are to be stored in accordance with the records retention system set
out by the housing provider.
3. All official records are to be stored in an environment which provides for the preservation
of the record over its entire life cycle. The type of storage and services required shall be
dictated by the purpose, physical form, use and value of the official record. Care over
privacy must be considered, typically seen in the form of locked and fire-proof cabinetry.
4. The electronic mail (e-mail) systems are not an official records repository and are not to
be used for the storage of official records.
5. E-mails deemed official records shall be classified in accordance with the records
retention system set out by the housing provider.
5.6.
Destruction:
1. The housing provider's inactive records are managed in accordance with all applicable
legislation.
2. The housing provider has established protocols for the timely and efficient destruction of
inactive corporate records pursuant to the housing provider's records retention
processes.
3. Upon fulfillment of the retention requirements pursuant to the records retention
requirements, official records are eligible for destruction.
SOS-SH-004-B01
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4. Destruction/disposal of all official records will be administered by the Records
Coordinator.
5. The housing provider must keep a permanent record of all records destroyed and the
timing of their destruction. Further, annually provide evidence of record and destruction
to the Service Manager.
5.7
Official Records:
1. No official records are to be deleted or otherwise destroyed by any person without the
written approval of the Department Head and/or Records Coordinator and without first
ensuring that the retention period for the record has been fulfilled and such records
have been documented in accordance with the housing provider's disposal procedures.
2. Wherever possible, official records are to be destroyed as part of an annual bulk
disposal process, as opposed to being random shredding.
3. Official records, as well as, drafts and copies, are to be destroyed in a manner which
preserves the confidentiality of the information contained within.
4. Written confirmation of all destroyed official records, pursuant to the records retention
process, shall be maintained by the Records Coordinator.
5. Destruction of official electronic records is to be carried out in accordance with this
policy and the industry standard destructions.
5.8 Destruction Record:
Prior to destruction of an inactive file, the following documentation is to be completed:
1. A written description (to the extent that such information is available) of the following:
a)
the title of the record;
b)
a brief description of the record;
c)
a listing of the contents/information being destroyed;
d)
the written approval of the respective Department Head and/or the Records
Coordinator
2. A copy of the record of destruction is sent to the Service Manager
Destruction records shall be retained permanently by the housing provider for audit trail
purposes.
5.9
Contact your Program Supervisor with any questions or concerns.