Information Management 101

INFORMATION MANAGEMENT101

Arkansas School Business Officials

November 7, 2013

PRESENTED BY:

L. Freeman Wish, CPAClarksville School District

1701 Clark RoadClarksville, AR 72830

[email protected]

WHAT INFORMATION DO WE MANAGE?

Student InformationFinancial InformationEmployee InformationBoard Information

STUDENT INFORMATION

Good News – This will not be covered in this presentation.

We will leave this section for the “Dark Side” of APSCN

FINANCIAL INFORMATION

What is Financial Information? Correspondence Emails Requisitions Purchase Orders Invoices Bid Records Checks Telephone Calls/Memos


Correspondence:

All written letters, memos, notes, etc. that are related to a financial transaction.

Includes correspondence both to and from a vendor or customer.

Includes any information obtained from a website to justify a purchase.


Emails:Types of E-Mail

1. Non-Record Material

2. Transient Material

3. Official Records


Emails: Non-Record Material

Any email not received or created in the course of school business may be deleted immediately since it is not an official record. The “Let’s do lunch” (not a school business lunch) or “Can I catch a ride home?” type of email.

Other examples would include any personal messages not conveying school business.


Emails: Transient Materials

E-mail that is determined to have insufficient value to warrant its preservation may be deleted upon receipt.

Examples are list serve messages, announcements regarding departmental bake sales and other agency memos without legal, administrative, fiscal or historical value


Emails: Transient Retention

Much of the communication via e-mail has a very limited administrative value and is deemed transient. For instance, an e-mail message notifying employees of an upcoming meeting would only have value until the meeting date has been attended or the employee receiving the message has marked the date and time.


Emails: Transient Retention

The user may delete these types of e-mail messages immediately after they have served their intended purpose.

Other e-mail messages that have limited administrative value would include: telephone messages, drafts and other limited documents that serve to convey information of temporary importance in lieu of oral communication. It would only be necessary to retain these records until no longer of administrative value.

Financial InformationEmails: Official Records

These emails are those used to establish such things as quotes, contracts, purchase or delivery information. As such they are an integral part of the official transaction.


Requisitions & Purchase Orders

Requisitions are the first step in the ordering process. It is a request to purchase some supply or service.

Purchase order is a legal document that authorizes a purchase to take place. Any purchase without a purchase order is not a school purchase but is the responsibility of the person placing the order.


Invoices

Invoices are the first outside source of a transaction detail. Should contain the PO number, date of the invoice, date of shipment, quantity, description of item or service, unit price, total price, shipping costs, terms etc.

Invoices must agree with terms, prices, etc. of the original purchase order.


Bid Records

Bids are required on all purchases of $10,000 or more.

Maintain a bid folder.

No PO should be approved if over $10,000 without supporting bid documentation.


Checks

Checks should be signed by Superintendent & Disbursing Officer.

Before a check is issued, you should have verified the accuracy of the invoice, validity of the PO, RECEIPT of the supply or service.


Telephone Calls/Memos

Telephone calls and conversations that are an important part of the transaction should be referenced somewhere in the transaction process.

Create a short memo of any conversations that are a critical part of the purchase of any supply or service and these should become a part of the record of the financial transaction.

EMPLOYEE INFORMATION

What is Employee Information?

Personal DataPay RateForms W-4, I-9Performance ReviewsEarnings HistoryHealth Insurance InformationBenefit InformationEarnings RecordsContracts

EMPLOYEE INFORMATION

Personnel Files

Recommendation:

Maintain two sets of files.

One file for personnel records.

One file for records related to health matters.

BOARD INFORMATION

What is Board Information?MinutesAgendasBond IssuesAnnual MeetingsRequired InformationSalary SchedulesAnnual AuditContracts

COMPONENTS OF RECORD MANAGEMENT

Archive - A place where records of permanent value (inactive data) are kept for legal, compliance, historical or research purposes.

Records Management Center- A place where semi-active data are kept for legal, compliance, historical or research purposes and are accessed frequently.

Records Management- The systematic control of recorded information from creation to final disposition.

What is a Record?

Recorded information, regardless of medium or characteristics, received by an organization that is evidence of its operations, and has value requiring its retention for a specified period of time.

Information created, received and maintained by an organization or person in pursuance of legal obligations or in the transaction of business.

What is a Record?

Information, often detailing business transactions, that is preserved because of the value of its data.

Sources of Information/RecordsCorrespondenceInvoicesPurchase OrdersPayroll RecordsSchool Board Meeting MinutesBond IssuesElectionsE-MailTelephone Calls

Non-Record Materials

Non-State Publications

Publications, promotional material from vendors, and similar materials that are “publicly available” to anyone, are not official records unless specifically incorporated into other official records.

Examples are unsolicited promotional materials (spam), files copied or downloaded from internet sites, etc.


Non-State Publications

However, for example, if you justify the purchase of a particular filing system by incorporating the reviews you saved from a list serve in your proposal to your supervisor, those list serve messages become official records and must be retained in accordance with the retention schedule for purchasing proposals.


Duplicate records are not normally considered records and do not have to be retained.

Duplicates may become the only official record if the original is destroyed or lost.


Emails: Intermediate Retention

These may include (but not limited to)

General Correspondence: Includes internal correspondence (letters, memos): also, correspondence from various individuals, companies, and organizations requesting information pertaining to agency and legal interpretations and other miscellaneous inquiries.

This correspondence is informative: it does not attempt to influence agency policy.


Emails: Intermediate Retention


Routine Correspondence. Referral letters, requests for routine information or publications provided to the public by the agency, which are answered by standard form letters.

Monthly and Weekly Reports: Document status of on-going projects and issues; advising supervisors of various events and issues.


Intermediate Retention


Minutes of Agency Staff Meetings: Minutes and supporting records documenting internal policy decisions.

Official Records

Permanent Retention

E-mail messages and other memorandums having significant administrative, legal and/or fiscal value and are scheduled as permanent should be categorized under the appropriate record series.

Official Records

Permanent Retention

These may include (but not limited to):

Executive Correspondence: Correspondence of the head of an agency dealing with significant aspects of the administration of their offices. Correspondence includes information concerning agency policies, program, fiscal and personnel matters.

Official Records

Permanent Retention

These may include (but not limited to):

Department Policies and Procedures: Includes published reports, unpublished substantive reports and policy studies.

Reflect official actions taken.

Convey statements of official policy or rationale for official decisions.

What is Record Management?

File Plan ImplementationRecords RetrievalRetention and DispositionPreservation of Significant or Historical RecordsAuditing

What is Record Management?

The systematic control of all records from their creation or receipt, through processing, distribution, organization, storage and retrieval to their ultimate disposition.

Why Do I Need Record Management?

Comply with Government RegulationsReduce Legal LiabilityControl Valuable Company AssetsReduce Record Archive Size

Essential Elements ofRecord Management

RecordFile PlanRetention ScheduleRecords RetrievalDisposition

File Plan

A system for categorizing records, divided into categories.

Each category has its own retention schedule.

All records in the system are assigned to a category.

Retention Schedule

The amount of time a record should remain in the system.

When (and if) the record should be disposed.

How the record should be disposed.

Record Retrieval

Structured query, full text search, or a combination of both.Export records into their native formats.Print or e-mail records.Version records.Add notes or comments to original record.

Disposition

The method by which a record is removed from the system.

Disposition is based on time, event, or a combination of time and event.

The process is generally either transfer or destruction.

Why Dispose of Records?

Not all records are permanent records.

Non-permanent records may have set retention rules.

Enforcing retention rules removes records when they become obsolete.

Example: Destroy employee personnel records seven (7) years after retirement.

Record Retention Policy

Lack of a formal Arkansas School Record Retention and Disposal Plan.

West Virginia Records Retention Schedule

Michigan Public Schools Record Retention Plan

Recommend that each school adopt a Record Retention Plan and follow it.

Legislative Action19-4-1108. Retention of documents.

(a) The original evidences of indebtedness, including documents prepared in connection with purchasing procedure, and all original contracts, invoices, statements, receipts, petty cash tickets, bank statements, cancelled checks drawn upon bank accounts, and other original supporting papers shall be retained in the permanent file of the business office of each state agency. These documents shall be kept in a safe place subject to audit and shall not be destroyed until authorization is given for their destruction by the Legislative Auditor.

(b) With the approval of the Legislative Auditor of the state, a state agency may retain evidences, to satisfy record retention policies, of indebtedness and other contracts, invoices, statements, receipts, petty cash tickets, bank statements, cancelled checks drawn upon bank accounts, and other supporting papers by microform or a form of stored images in a computer system or other form of computer technology in lieu of retaining the originals of such documents.

History. Acts 1973, No. 876, § 15; A.S.A. 1947, § 13-341; Acts 1997, No. 541, § 2; 2001, No. 1453, § 33.

DFA Interpretations

R1-19-4-1108 Public Records

The law defines public records as writings, recorded sounds, films, tapes, electronic or computer-based information or data compilations in any medium required by law to be kept or otherwise kept and which constitute a record of the performance or lack of performance of official functions which are or should be carried out by a public official or employee, a governmental agency or any other agency wholly or partially supported by public funds or expending public funds.

All public records shall be open to inspection and copying by any citizen of the State of Arkansas during the regular business hours of the custodian of the records, except as otherwise specifically provided by law.Refer to Arkansas Code ACA 25-19-105 for exceptions, charges for providing copies of records and required response time to requests for copies and ACA 25-19-109 for special requests for electronic information.

R2-19-4-1108 Records Retention

All records that are public property are required to be maintained by the agencies that generate the documents. The type of business record in question and the business process it supports determines the length of retention. Generally, all records should be maintained a minimum of three fiscal years. All records and supporting documentation must be maintained until they have been audited and may not be destroyed until permission has been granted by the Division of Legislative Audit. Other records such as records for grants are maintained according to State or Federal laws.

Public records can only be destroyed after permission is granted by the Division of Legislative Audit.

Storage of records in electronic form is permissible in some cases. Refer to Arkansas Law ACA 19-4-815, 19-4-1108, 25-32-112, 13-4-203, 25-32-117, 25-32-118.

Effective January 1, 2006, the Executive Chief Information Officer shall promulgate rules and guidelines governing the retention and management of public records and issue periodic updates as necessary. Each State agency shall comply with these rules and guidelines by the earlier of July 1, 2007, or when the line item appropriation is established to comply with this requirement.

ACT 918 of 2005

Applies to all cities, county or local governments in Arkansas

Requires the development of rules and guidelines for the retention of public records commonly found in state agencies

Requires rules and guidelines to be effective July 1, 2007

Arkansas Record Retention Schedule

Agency Directives, Internal Policies and Procedures

Keep until superseded plus three years


Meeting Agenda and Minutes of Governing Bodies

Permanent


Employee Benefit Records and Employee Personnel Records

Workers Compensation Accident Reports

5 years after separation or until closure of unresolved personnel issues, whichever is greater

3 years from date of injury


Accounts Payable

Accounts Receivable

Until authorized by the legislative auditor (as required by Arkansas Code)

Until authorized by the legislative auditor (as required by Arkansas Code)

Let’s Take A Look At A Few Examples of Record Retention Periods

(Comparing West Virginia, Michigan and Arkansas)

Accounting Records

Bank Statements, Deposit Slips

West Virginia – Audit + 3 years

Michigan – Current FY + 7 years

Arkansas – Until authorized by legislative auditor

Cash Receipts/Receipt Books




A/P Invoices/Purchase Orders




Journal Entries




Bonds

West Virginia – Permanent

Michigan – Expiration + 7 years

Arkansas – Expiration + 5 years

Audit Reports

West Virginia – Permanent

Michigan – Permanent

Arkansas – Until the next audit report is issued by Legislative Audit

Let’s Talk Payroll Records

Employment History RecordsPayroll History (Annual Earnings)

West Virginia – 50 years

Michigan – Current Fiscal Year + 50 years

Arkansas – Permanent

Unemployment CompensationRecords

West Virginia – At least 4 years

Michigan – Current Fiscal Year + 1 year

Arkansas – 5 years after case closed

Forms W-2

West Virginia – At least 4 years


Arkansas – Not Addressed in Arkansas Record Retention Schedule

Time and Attendance Records

West Virginia – Not Addressed



Salary Schedules

West Virginia – 25 years

Michigan – Creation Date + 6 years

Arkansas – Not Addressed in Arkansas Record Retention Schedule

Case Study of Record Retention Policies That Don’t Work

Carlucci vs. Piper AircraftA Piper Cheyenne crashed in Ireland – 3 men died

as a resultClara Carlucci sued Piper for design defects that

caused the pilot to lose control and crashRecords were subpoenaed from Piper2 Employees in Flight Test Department had been

told by supervisor to “selectively” purge hundreds of records that might be detrimental to Piper in future lawsuits.

Carlucci vs. Piper Aircraft

Piper claimed these records were destroyed under retention procedures

Piper could not demonstrate that these procedures were in place or that they were being followed.

Judge entered default judgment against Piper for $10 million – for selective destruction of records.

Carlucci vs. Piper AircraftJudge did not even consider merits of caseMilestone decision about destruction of records –

courts will not tolerate selective destruction of records

Major Issue – Piper could not document to court that it destroyed its records in the regular course under an approved records retention schedule

The Andersen Lesson

After a 6-week trial and 10 days of deliberation, a jury found Arthur Andersen guilty of obstruction of justice when it destroyed Enron Corp. documents while on notice of a federal investigation by the SEC.

The Andersen Lesson

The jury rejected Arthur Andersen’s defense that the documents were destroyed as part of its housekeeping duties and not as a ruse to keep Enron documents away from the regulators.

The Andersen Lesson

Arthur Andersen received the maximum sentence of 5 years probation and a $500,000 fine.

35,000 people lost their jobs worldwide.

Since the initial court decision, the Anderson Case was reversed but it was too late to save the company

The Andersen Lesson

The lesson to be learned from the Arthur Andersen experience is that a Document Retention Program, an otherwise critical part of a company’s risk management program, will not save you from sanction if the policy does not conform to law, either in content or in implementation.

In Conclusion

Records and information are the key component to the existence of any organization.

Good record keeping processes and policies are imperative.

Litigation issues.

What happens if the organization ceases to exist?

How to Comply

If a record retention policyIs reasonable, has a genuine business purpose and establishes appropriate retention periodsIs not selective – it wasn’t designed to destroy all records quickly so that nothing would be available if anyone should ever sue the organization or commence an investigationIs implemented in an evenhanded manner by employees who understand the policyProvides for prompt cessation of destruction programs if and when the organization learns of an investigation or litigation

ThenA company should not incur criminal liability for an

innocent failure to retain potential evidence.

Sites To Remember

The Arkansas General Records Retention Schedule

http://www.dfa.arkansas.gov/offices/intergovernmentalServices/Pages/recordRetentionSchedule.aspx

Sites To Remember

West Virginia Public School Records Retention Schedule

http://wvde.state.wv.us/finance/manuals/ recordretentionschedule.pdf

http://wvde.state.wv.us/finance/manuals/

Sites To Remember

General Retention Schedule #2Michigan Public Schools

http://www.michigan.gov/documents/hal_mhc_rms_local_gs2_171482_7.pdf

Thank You For

Your Attendance

GOOD LUCK

I HOPE I HAVE HELPED

ALWAYS REMEMBER THIS!

IT IS NEVER TOO LATE TO HAVE A HAPPY

CHILDHOOD

Information Management 101

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