County reviews draft records-retention policy and schedule; committee to refine legal holds, elected-official authority and IT oversight

Chris Whitaker, a consultant with Iron Mountain, presented a draft Oklahoma County records retention policy and accompanying retention schedule to the Policy and Governance Committee on Oct. 13, outlining definitions, roles, retention triggers and next steps for adoption.

The nut graf: Committee members and department representatives discussed several substantive policy decisions the draft must reflect before final approval — including which body issues records-management policies, how elected officials may retain records beyond statutory minimums, who may issue legal holds, standards for disposing of sensitive records (including CJIS-covered materials), and a plan to create or re-establish an Oklahoma County Information Technology Council (OCITC) to coordinate IT and records oversight.

Whitaker said the schedule is “a living, breathing dynamic sort of document,” and walked the committee through the draft’s main sections: purpose and scope; definitions of records, official records and nonrecords; roles and responsibilities; records life-cycle (creation, maintenance, storage, disposal); legal holds; business continuity and vital records; and electronic-records expectations. He also reviewed the retention-schedule spreadsheet tabbed by functional area that lists record types, examples, minimum retention periods and the event that triggers retention timing.

Key policy points and committee direction - Legal holds: The draft states Oklahoma County’s legal, tax and risk departments have sole authority to issue or release legal-hold orders. Committee speakers agreed this should remain explicit; the policy will require custodians to acknowledge holds within seven days and the legal offices to maintain a record of active and released holds. - Elected-official authority: Committee members requested language explicitly allowing elected officials or department heads to retain county records for longer than the statutory minimums without requiring committee approval. Multiple speakers said the policy should establish minimum retention requirements and permit individual offices to keep records longer for business or historical reasons. - Disposal and sensitive materials: Committee members asked that the retention schedule include specific disposal procedures for sensitive categories (for example, criminal-justice information subject to CJIS rules) and other records that require supervised or witnessed destruction; Iron Mountain agreed to add best-practice guidance and carve-outs for such materials. - OCITC and governance: Discussion revived a previously drafted Oklahoma County Information Technology Council. Participants suggested the council — if formed by BOCC resolution — would include representatives from each elected official’s office, the county manager, and MIS representatives to provide IT and records policy coordination and training. Committee members directed staff to prepare a resolution to form or reactivate the council and to include it in the policy package. - Training and auditing: Committee members questioned which office should be responsible for training and compliance monitoring. The draft’s program-audits section was criticized as written (audits and disciplinary authority across elected-offices are administratively difficult); committee members directed edits to clarify that each office will be responsible for internal compliance while the governance group will provide guidance and issue supplementary procedures.

Other technical items: the schedule will include citations to the state statutes used to determine retention periods and an explicit statement that the content of a record, not its format, determines retention. The consultant said the final schedule will include statutory citations and that the retention schedule will be updated periodically as law or practice changes.

Ending: Committee members voted to approve changes made in the meeting’s markup and asked staff to return the redlined draft to the District Attorney’s office for legal review before the next Policy and Governance meeting. The consultant and staff will incorporate the committee’s direction, add disposal and CJIS-specific guidance, and prepare a draft BOCC resolution for the OCITC.