John Glenn School Corporation
Administrative Guidelines
 

7540.05 - PROPER USE OF CORPORATION-ISSUED E-MAIL ACCOUNT

Depending on the content of an e-mail message, it may be a public record or an education record that needs to be maintained by the School Corporation in accordance with Policy 8310 – Public Records or Policy 8330 – Student Records, and made available for inspection and/or copying upon request by a member of the public, or a parent or student age eighteen (18) or older. In addition, an e-mail may constitute electronically stored information (ESI) that is subject to a litigation hold pursuant to Policy 8315 – Information Management. The following procedures are established so that the Corporation’s e-mail and Internet capabilities are not compromised, and e-mail messages are maintained in accordance with State and Federal law.

OPERATIONAL CONSIDERATIONS:

 

A.

Types of E-Mail Prohibited

     
 

1.

General Rule: Do not put anything in an e-mail that you would not put on Corporation letterhead.

   
 

2.

Do not respond to chain letters via your Corporation e-mail account. These letters often come from outside sources, which increase the risk of e-mail based virus infection. Such e-mails multiply exponentially and cost the Corporation in terms of time, money and resources.

     
 

B.

Proper Use of the Distribution Lists in the Corporation’s Global Address Book

   
 

1.

When using a Corporation-wide or building-wide distribution list, all members of that group should be intended targets. Distribution lists are to be used only when it is necessary to convey information to every member of a group. This includes all distribution lists.

   
 

2.

It is your responsibility to know to whom your information will be sent if you choose to utilize a Corporation-wide or building-wide distribution list.

PUBLIC RECORD CONSIDERATIONS:*

E-mail messages that are created or received by the Corporation are public records, unless they meet one of the statutory exceptions, and must be maintained in accordance with the Board’s Records Retention Policy and made available for inspection and/or copying by the public. The length of retention of an e-mail message depends on its content and purpose. The content, transactional information, and any attachments associated with an e-mail message are considered a public record unless they meet one of the statutory exceptions.

For the purposes of this guideline, there are four (4) categories of e-mail retention: non-record messages, transitory messages, intermediate messages, and permanent messages.

 

A.

E-mail Falls Within the Definition of "Public Record" under Indiana Law

   
 

All e-mail conducted on Corporation computers is owned by the Corporation and is a public record. Indiana Code 5-14-3-2 defines a public record as:

   
 

[A]ny writing, paper, report, study, map, photograph, book, card, tape recording, or other material that is created, received, retained, maintained, or filed by or with a public agency and which is generated on paper, paper substitutes, photographic media, chemically based media, magnetic or machine readable media, electronically stored data, or any other material, regardless of form or characteristics, unless it meets one of the statutory exceptions.

   
 

The Indiana Court of Appeals has added to this definition any material created for or on behalf of a public agency. Knightstown Banner v. Town of Knightstown, 838 N.E.2d 1137 (Ind. Ct. App. 2005). Consequently, all e-mail messages sent or received for a school purpose are public records and are subject to record retention requirements. "Retention requirements" is a term used to refer to the rules set by the Indiana Oversight Committee on Public Records regarding the length of time different types of public records must be stored before they can be discarded.

   
 

E-mail messages maintained in a personal email account (e.g., an AOL or Google account) generally are not public records. However, if the personal e-mail is submitted to the school corporation, it becomes a public record. For example, private e-mails that are then forwarded to Corporation e-mail addresses become public records.

   
 

E-mail messages fall within three (3) broad categories:

   
 

1.

Transitory & Duplicate E-Mails – No retention requirement

     
   

Corporation employees sending or receiving such e-mails may delete them immediately. "Transitory" means of brief, short-lived or temporary interest or importance. Many e-mails are transitory. However, e-mails that relate to a specific student may be considered part of the student’s educational records and are not transitory. Likewise, anything that is permanent, important, significant or of historical interest is not transitory.

     
   

Transitory e-mails do not a) set policy, b) establish guidelines or procedures, c) certify a transaction, or d) become a receipt. Transitory e-mails convey information of temporary importance. The following types of e-mail are considered transitory:

     
 

a.

Incoming listserv messages

     
 

b.

Personal e-mails unrelated to Corporation business

     
 

c.

Spam or unsolicited advertisements or sales promotions

     
 

d.

Non-policy announcements

     
 

e.

Telephone messages

     
 

f.

Published reference materials

     
 

g.

Invitations and responses to meetings

     
 

h.

"Thank you" responses

     
 

i.

Replies to routine questions, e.g., "we’re open 8 – 5", "our address is…", "the deadline is…"

     
 

j.

Scheduling meetings

     
 

k.

Out of Office auto-replies

     
 

l.

Attachments to e-mail that are identical to records that are stored and managed outside the e-mail system pursuant to approved record retention schedules

     
 

Duplicate e-mail messages: If an e-mail has been sent to multiple recipients, the recipients are not required to maintain the e-mail message. If the e-mail message is transitory, the sender likewise is permitted to delete the e-mail message. For duplicate e-mail messages that are "less than permanent" or "permanent," the sender should maintain those records as indicated below.

     
 

2.

"Less than Permanent" E-Mails – Retention is dependent on the local schedule for the destruction of records

     
   

Any e-mails that are not part of the Corporation’s permanent records and are not transitory in nature or duplicate e-mails fall within the "less than permanent" category. This includes any records that must be maintained for a certain number of years but may then be destroyed pursuant to the Corporation’s record destruction schedule. For example, except for the student records listed below that are considered to be "permanent" records, student records must be maintained for at least three (3) years after the student exits from the educational program.

     
 

3.

"Permanent" E-Mails – Retention is permanent and such e-mails are archived

     
   

Any e-mails that may not be destroyed but must be retained permanently and archived are "permanent" e-mails. For example, the following student information must be retained as part of a permanent record:

     
 

a.

name, address, and telephone number

     
 

b.

grades

     
 

c.

classes attended

     
 

d.

grade level completed and year completed

     
 

e.

attendance record

     
 

f.

the year the student exited form school

     
 

g.

high school transcript that includes the following:

     
 

1)

attendance records

     
 

2)

the student’s latest statewide assessment program test results

     
 

3)

any secondary or postsecondary certificates of achievement

     
 

4)

immunization information

     
 

5)

other information as determined by the Corporation

   
 

B.

Mailbox Management

   
 

Guidelines and Best Practices for Managing E-Mail

   
 

1.

Record Copy E-Mail

   
 

E-mail users should be aware that e-mail messages are often widely distributed to a number of recipients. Determining which individual maintains the record copy of the message, i.e., the original message that must be retained per the retention schedule, is vital to e-mail management. If the holder of the record copy is not identified and aware of his/her responsibility, the Corporation may find that no one retains the message or that everyone retains the message. Neither of these scenarios is appropriate.

   
 

For example, Board/Corporation policy/guidelines documents that are transmitted to multiple recipients via an e-mail system need not be maintained by each recipient beyond his/her need for this information if record copy responsibility is established so that the record is maintained by some office, employee or agent for its established retention period. In this example, a logical record copy responsibility rests with the creator or original distributor of the policy/guideline document. Prompt deletion of duplicate copies of e-mail messages from an e-mail system makes the system as a whole much easier to manage and reduces disk space consumed by redundant information.

   
 

Generally speaking, the individual who sends an e-mail message should maintain the record copy of the message. However, the varied uses and wide distribution of e-mail may result in many exceptions to this rule that will have to be dealt with internally.

   
 

2.

Filing

   
 

Non-transitory e-mail messages should be filed in a way that enhances their accessibility and that facilitates records management tasks. The IT staff will advise users on the set up or modifying of e-mail systems to facilitate records management and appropriate filing systems. Procedures and systems configurations may vary according to the building’s/users’ needs and the particular hardware and software in use.

   
 

In addition to the IN and OUT boxes that come with your mail account, you usually have the option of creating other "mailboxes" or "folders". After brief periods in your IN-OUT boxes, messages should be transferred to other boxes, based on business and retention requirements.

   
 

Employees should be responsible for classifying messages they send or receive according to content, the Corporation’s folder/directory structure, and established records series.

   
 

3.

Subject Lines

   
 

Fill in the subject line on your e-mail both to help your recipient identify and file messages, and to help you file your OUT box messages that must be retained for some period. Subject lines should be as descriptive as possible.

   
 

The following are some examples of poor and good subject lines for the same message:

   
 

Poor, confusing subject lines

Better, descriptive subject lines

 

"helpful info"`

"contact info"

 

"report"

"quarterly financial report"

 

"minutes"

"Jan 2016 Board minutes"

 

"important"

"revised admin. procedures"

 

"today?"

"lunch plans today?"

 

"news"

"new agency head appointed"

   
 

C.

Mailbox Maintenance and Cleanup

   
 

1.

Each e-mail user is responsible for keeping his/her e-mail account at a manageable size.

   
 

2.

If you do not maintain your mailbox and permit its size to grow beyond the recommended levels, your mailbox could become corrupt. The Corporation's staff is not responsible if the mailbox cannot be recovered due to lack of user maintenance.

   
 

3.

Your Corporation e-mail account is not meant to be a storage folder. Before developing your personal mailbox maintenance and cleanup procedure, you must review the Corporation's Policy 8310 - Public Records, Policy 8315 - Information Management, and any accompanying administrative guidelines to these policies. Any questions regarding these policies should be directed to the Superintendent.

   
 

4.

If you want to retain all e-mail items with your work records, you must implement a storage solution outside your e-mail account. Such records shall continue to be the Board's property and may not be removed from the Board's premises for any reasons.

Approved 9/26/17

© Neola 2017