CITY COUNCIL POLICIES
POLICY NAME:
Records and Information Management
(RIM) Program
POLICY NUMBER: 112-01
Effective Date: August 02, 1994 Last Revised Date: October 04, 2022 Status: Active Page: 1 of 10
I. BACKGROUND
A well-maintained Records and Information Management (RIM) Program assists the City of Chula Vista (“City”) in remaining compliant with record-keeping regulations, avoiding risks and potential legal action, and improving workflow and productivity.
Pursuant to Charter Section 502, the City Clerk is designated as the official responsible for the administration and oversight of the City’s Records and Information Management (“RIM”) Program.
II. PURPOSE
To establish policies and procedures under a comprehensive RIM framework to control the orderly creation, utilization, maintenance, retention, preservation, and Disposition of Records, consistent with State law, including the California Public Records Act (California Government Code §7920.000 et seq).
This Policy also defines the requirements for using, managing , and storing Records received or created via Electronic Communication Systems in the conduct of City business. It establishes expectations for using email, messaging, and Collaborative Messaging Platforms to ensure appropriate, secure, and legally compliant practices consistent with Records management requirements.
III. SCOPE
This Policy applies to all Records, regardless of physical form, storage location, or medium. This includes, but is not limited to:
Physical Records: paper documents, maps, plans, photographs, and other tangible media. Electronic Records: documents, spreadsheets, databases, emails, and other digital formats. Electronic Communications: email, text messages, instant messages, chats, social media posts, or other electronic forms of communication related to City business. Multimedia: Audio, video, and multimedia Records produced in the course of official City activities.
This Policy applies to elected officials ; City Council-appointed board, commission, and committee members; employees; contractors; consultants; and volunteers of the City who are acting on behalf of the City and who create, access, manage, or store City Records, information, and Electronic Communication.
CITY COUNCIL POLICIES
POLICY NAME:
Records and Information Management
(RIM) Program
POLICY NUMBER: 112-01
Effective Date: August 02, 1994 Last Revised Date: October 04, 2022 Status: Active Page: 2 of 10
IV. DEFINITIONS
Collaborative Messaging Platform
Collaborative Messaging Platforms are software or systems, including but not limited to Microsoft Teams, Slack, text messaging, or other collaboration tools, that enable real-time text or chat communication.
Convenience Information
Convenience Information refers to materials maintained solely for reference, ease of access, or personal convenience that are not the official Record. These materials are typically duplicates, drafts, notes, or working copies kept to assist employees in carrying out day-to-day tasks and are classified as non-records or Convenience Information. They have no retention value once their administrative purpose is served and should be destroyed when no longer needed . Examples of Convenience Inform ation are included in Exhibit A.
Disposition
Disposition is the final action taken with respect to a Record, such as destruction, transfer to storage, or permanent retention, after it has met its approved retention period and is no longer required for cu rrent operations.
Electronic Communication
Electronic Communication is a message or data transmitted or received via an Electronic Message System, including any attachments that may be transmitted with the message, along with its descriptive transmission metadata, including email, instant messages, text messages, chat messages, and other forms of Electronic Communications used in City business.
Electronic Communication System
An Electronic Communication System is one or more computer networks, hardware, and software applications used to create, receive, and transmit messages and other documents electronically.
Records
Records are either defined specifically in applicable statutes, including Gov. Code § 7920.530, Municipal Code, City business practices, or, in the absence of specific practices, a Record is a document or information generated as the final output of a business process or business decision, regardless of physical form or characteristics.
CITY COUNCIL POLICIES
POLICY NAME:
Records and Information Management
(RIM) Program
POLICY NUMBER: 112-01
Effective Date: August 02, 1994 Last Revised Date: October 04, 2022 Status: Active Page: 3 of 10
Records and Information Management (RIM) Program
The Records and Information Management (RIM) Program is the framework administered by the City Clerk to ensure systematic control of creation, receipt, maintenance, use, and Disposition of Records in accordance with approved policies and the Records Retention Schedule.
Records Retention Schedule
The Records Retention Schedule is the City Council-adopted schedule identifying official Record series, retention periods, and final Disposition requirements based on legal, administrative, fiscal, and historical value.
Repository
A Repository is the official storage location, physical or electronic, approved by the City for maintaining Records in an organized and secure manner (e.g., Laserfiche, NetFile, or other City-approved systems).
User
User means any individual who is acting on behalf of the City and who creates, accesses, uses, manages, or stores Records, information, or electronic communications. This includes elected officials; City Council-appointed board, commission, and committee members; employees; contractors; consultants; and volunteers.
V. POLICY
1. Ownership and Privacy
1.1 City Property. Records created or received in the conduct of the City’s business by Users, including staff and elected and appointed officials, are the exclusive property of the City, unless otherwise required by contract or law, including data privacy laws . Records are subject to compliance with this Policy, the associated Records Retention Schedule, and any other City policy or procedure.
1.2 Personal Devices and Accounts . Records created, received, or stored in the conduct of City business on a personal device or account are the property of the City. Use of personal devices or accounts for City business is strongly discouraged.1 2
1.3 Communication of Personal Information . Users should not communicate their private, privileged, or confidential information, including but not limited to personal attorney -client communications, financial or medical information , using any City systems, accounts , or devices. Users who do communicate their private information using any City system, account, or device will be deemed to have waived privilege or privacy rights in those communications, even where those communications are made via a personal password-protected account. These
CITY COUNCIL POLICIES
POLICY NAME:
Records and Information Management
(RIM) Program
POLICY NUMBER: 112-01
Effective Date: August 02, 1994 Last Revised Date: October 04, 2022 Status: Active Page: 4 of 10
communications are not Records and may be accessed and/or deleted at any time, without notice.
2. Authenticity
2.1 Accuracy and Integrity of Records . The City is committed to creating and maintaining complete, accurate, and trustworthy Records that document its business decisions and activities.
Deliberately creating false or misleading Records regarding the City’s activities is strictly prohibited. Records should not contain language that is misleading, incomplete, inaccurate, or fraudulent.
3. Classification
3.1 Proper Classification . Records, both paper and electronic, are to be created, stored, and managed with the appropriate classification that enables efficient and, when appropriate, shared access, appropriate application of retention, and secure protection.
4. Retention and Disposition
4.1 Retention. Records are to be retained in accordance with the Records Retention Schedule.
When Records complete their retention period and are no longer required for current operations, regardless of their format, they shall undergo appropriate Disposition in compliance with established City procedures and applicable laws.
4.2 Email. Emails not specifically designated as a Record and transferred to a Repository shall be held for two (2) years. After this period of time, emails that have not been moved to a Repository will be considered Convenience Information and automatically and permanently deleted. Each User is responsible for identifying and preserving emails that meet the definition of a Record by transferring them to the appropriate Repository within the two -year timeframe to ensure proper management and Disposition.
4.3 Destruction. Records must be disposed of in accordance with the Records Retention Schedule and Records destruction process established by the City Clerk. Records may not be destroyed without prior approval from the City Clerk, City Attorney, and Finance Director.
4.4 Disposal and Destruction of Sensitive Records . The destruction of confidential or sensitive Records shall be carried out in a manner that ensures the information cannot be reconstructed or retrieved.
5. Records Storage
5.1 Hardcopy Records . Hardcopy Records that are no longer considered active should be evaluated for Disposition in accordance with the Records Retention Schedule. Records that
CITY COUNCIL POLICIES
POLICY NAME:
Records and Information Management
(RIM) Program
POLICY NUMBER: 112-01
Effective Date: August 02, 1994 Last Revised Date: October 04, 2022 Status: Active Page: 5 of 10
must be retained b eyond their active period may be transferred to City-designated storage facilities to fulfill retention requirements.
5.2 Electronic Records. Electronic Records, including Electronic Communications, that are no longer considered active, may be transferred to a Repository or moved offline to fulfill retention requirements. All Records, regardless of the storage location, must remain accessible by City employees for business needs and in response to Public Records Requests. Electronic Communication Systems, including, but not limited to, systems that send or receive email, texts, and chats, are not Repositories for the storage and retention of Records.
5.3 Unauthorized Storage Locations . Records should not be transferred to or stored in unauthorized physical or electronic locations, such as in personal accounts or devices.
6. Use of City-Issued and Personal Accounts and Devices
6.1 City-Issued Accounts and Devices . Users who are issued official City Electronic Communication devices or accounts , including , but not limited to, a City email account, computer, tablet, or mobile device , should use their City -issued account or device when conducting City business.
6.2 Personal Accounts and Devices . Users who conduct City business using personally owned devices or accounts may create, store, or transmit Records. Such Records may be subject to disclosure under the California Public Records Act. Users are responsible for promptly forwarding or transferring Records to a Repository to ensure appropriate retention, management, and accessibility in accordance with applicable laws and this Policy.1 2
7. Accessibility and Availability
7.1 Records Accessibility. Records must remain accessible and retrievable for business operations, legal proceedings, audits, or investigations as long as required by their applicable retention periods, regardless of storage location or format.
7.2 Public Records. Records that are determined to be “public” are to be made available for the public to obtain in accordance with the California Public Records Act, Government Code §§7920,000-7931.000.
7.3 Public Disclosure and Department Responsibilities. Records determined to be public are to be accessible in accordance with the California Public Records Act and applicable City policies.
Public Records Act requests for Police Department Records are generally handled by the Police Department. Requests for Records from all other departments are generally facilitated through the City Clerk. Users should not respond directly to requests for public Records unless expressly authorized by the City Clerk or, for Police Department Records, by the Police Department. This approach may be adjusted as needed to accommodate staffing or operational requirements
CITY COUNCIL POLICIES
POLICY NAME:
Records and Information Management
(RIM) Program
POLICY NUMBER: 112-01
Effective Date: August 02, 1994 Last Revised Date: October 04, 2022 Status: Active Page: 6 of 10
8. Records Security, Privacy, and Confidentiality
8.1 Protection of Records. Records shall be safeguarded from unauthorized access, alteration, theft, loss, or destruction. Each Department is responsible for ensuring that Records are stored in secure locations and that access is limited to individuals with a legitimate business need. The City Clerk and Information Technology Services (ITS) shall establish and maintain standards for access controls, authentication, and secure storage in accordance with applicable laws and this Policy.
8.2 Privacy and Confidential Information . Certain Records contain confidential, personal, or sensitive information protected by law, including but not limited to personnel, medical, and privileged legal Records. Users must handle such Records in compliance with all applicable privacy laws, including the California Public Records Act and the California Consumer Privacy Act, and City policies . Unauthorized disclosure or improper handling of confidential information is strictly prohibited.
8.3 Security Incidents and Unauthorized Access . Any suspected or confirmed breach, unauthorized access, or loss of Records must be reported immediately to a supervisor, the City Clerk, and Information Technology Services. The City shall investigate and respond to such incidents in accordance with its data breach notification and mitigation protocols.
9. Electronic Communication and Records Management
9.1 Collaborative Messaging Platforms . Messages sent or received on City -provided Collaborative Messaging Platforms (e.g., Microsoft Teams, Slack , etc.) are considered Convenience Information and should not be used in a manner that creates a Record. If a User does create a Record through these platforms, they are responsible for capturing, saving, and managing it in accordance with the City’s records management policies. Examples of allowable and non-allowable messages are provided in Exhibit B.
9.2 Social Media:
a. Official Ci ty Social Media A ccounts. City social media accounts are to be used exclusively for the distribution of official City information. Original documents are not to be created within social media platforms, but attached, and original communication posted to social media is to be limited to City announcements , notifications, or information al updates consistent with the City’s approved communications guidelines. b. Personal Social Media Accounts: Posts, comments, messages, and related metadata created or received on a personal social media account must be assessed by the User to determine whether they constitute a Record. The User who created or received the content is responsible for retaining and producing it in accordance with applicable laws and this Policy.
CITY COUNCIL POLICIES
POLICY NAME:
Records and Information Management
(RIM) Program
POLICY NUMBER: 112-01
Effective Date: August 02, 1994 Last Revised Date: October 04, 2022 Status: Active Page: 7 of 10
10. Records of Departing Personnel and Officials
10.1 Elected and Appointed Officials . When an elected or appointed official’s term ends, the elected or appointed official shall work with the City Clerk to transfer Records to the City Clerk’s Office to comply with the requirements of this Policy and any supporting procedures for retaining and managing the Records of the exiting official.
10.2 Employees, Volunteers, and Contractors. When an employee, volunteer, or contractor leaves the City, the exiting individual’s supervisor or manager, or the contractor’s City point of contact is responsible for complying with the requirements of this Policy and any supporting procedures for retaining and managing the Records of the exiting employee, volunteer, or contractor.
11. Legal Holds and Suspending Retention Requirements
11.1 Legal Hold . Records and Convenience Information relevant to pending or current City litigation identified explicitly in a legal hold notice submitted by the City Attorney’s Office shall immediately suspend all destruction procedures. All Records, to include Convenience Information, and Electronic Communications subject to a legal hold , must comply with the instructions on the legal hold notice issued by the City Attorney. Users shall not delete or dispose of any Records , Convenience Information, or Electronic Communication covered by the legal hold notice and/or relevant to the matter until notified in writing by the City Attorney’s Office.
12. Information Protection and Disaster Recovery
12.1 Disaster Recovery Backups. Disaster recovery backup media are exact copies of an operating system, associated application s, and data created for the sole purpose of protecting and recovering data and documents in the event of a disaster or business disruption . They are not subject to the requirements of the Records Retention Schedule . Backups serve as a level of protection for electronic systems and the data stored on those systems to ensure an exact duplicate or copy is available and unalterable for use in the event of a business disruption.
13. Preservation of Historical and Vital Records
13.1 Preservation. Preservation encompasses the activities undertaken to ensure the usable life of archival Records. These activities are designed to minimize the physical or digital deterioration of Records and to prevent the loss of informational content. 3
13.2 Protection of Vital and Historical Records. Records designated as “vital” or “historical” are to be protected in a manner that establishes the priority of recovery of the data or documents in a timely manner following a disaster or system disruption. Such Records must be safeguarded in accordance with established City procedures and standards for business continuity and disaster recovery. Vital Records are those Records essential to the City’s ability to recover from
CITY COUNCIL POLICIES
POLICY NAME:
Records and Information Management
(RIM) Program
POLICY NUMBER: 112-01
Effective Date: August 02, 1994 Last Revised Date: October 04, 2022 Status: Active Page: 8 of 10
a disaster, resume business operations , or protect legal and financial interests, and should be protected in accordance with City procedures and standards.
13.3 Mandatory Preservation of Paper Versions of Permanent Records. Under no circumstances are Records specified in Government Code section 34090 authorized to be destroyed, even when digitized, including the minutes, ordinances, or resolutions of the City Council or a City board or commission, due to their historical value.
14. Policy Administration and Procedures
14.1 Administrative Policies. Notwithstanding this Policy or any other City Council-adopted policies or procedures, the City Clerk, in consultation with the City Attorney and City Manager, shall have the authority to develop and amend administrative policies and procedures, as necessary, to implement the terms of this Policy.
VI. REFERENCES
Records Retention Schedule
HISTORY
1 City of San Jose v. Superior Court , 2 Cal. 5th 608 (2017): “When a city employee uses a personal account to communicate about the conduct of City business, the writings may be subject to disclosure under the California Public Records Act.” Records on personal accounts and devices may include, but are not l imited to, communications via: text message, personal email accounts, and social media accounts. The City does not seek correspondence that is personal in nature but only Records that relate to City business.
2 City’s Electronic Communications Policy No. 909
3 Government Code § 34090
DATE ACTION RESOLUTION NO.
08/02/1994 Adoption 17577
10/04/2022 Revision 2022-214
CITY COUNCIL POLICIES
POLICY NAME:
Records and Information Management
(RIM) Program
POLICY NUMBER: 112-01
Effective Date: August 02, 1994 Last Revised Date: October 04, 2022 Status: Active Page: 9 of 10
EXHIBIT A
CONVENIENCE INFORMATION EXAMPLES
The examples contained in this Exhibit are illustrative and not exhaustive. The City Clerk, in consultation with the City Attorney, is authorized to expand or clarify these examples and to issue updated guidance for staff training purposes. Such updates may be made administratively and do not require further action by the City Council, provided the underlying Policy itself is not modified.
Catalogs, Conference Handouts, and Trade Journals
Catalogs, trade journals, bulletins, magazines, manuscripts, brochures, conference/seminar handouts, manuals, external newsletters, and flyers that are external publications.
Collaborative Messaging Platform Messages and Notes
Collaborative Messaging is casual notes and conversations made within any Collaborative Messaging Platform used by the City in the conduct of business.
Duplicate/Extra Copies
Exact copies of Records and information; duplicates of a document, such as printed publication.
Personal Working Files
When there is a final document (the “Record”) in place, the drafts of that document and any rough notes are considered Convenience Information.
Reference Materials
Materials used as review or reference by an employee, but which are not documents of the City’s business activities.
Templates
Unused or blank templates that have not been filled out or completed.
Transitory Correspondence
Casual correspondence (including e -mail) used for administrative purposes or inte rnal communications (such as notification of a change in a meeting room or scheduling a working lunch).
RETENTION
Convenience Information can be destroyed or deleted when no longer needed, provided it is not subject to an active legal hold.
CITY COUNCIL POLICIES
POLICY NAME:
Records and Information Management
(RIM) Program
POLICY NUMBER: 112-01
Effective Date: August 02, 1994 Last Revised Date: October 04, 2022 Status: Active Page: 10 of 10
EXHIBIT B
EXAMPLES OF ALLOWABLE AND NON-ALLOWABLE MESSAGES ON COLLABORATIVE
MESSAGING PLATFORMS
The examples contained in this Exhibit are illustrative and not exhaustive. The City Clerk, in consultation with the City Attorney, is authorized to expand or clarify these examples and to issue updated guidance for staff training purposes. Such updates may be made administratively and do not require further action by the City Council, provided the underlying Policy itself is not modified.
Examples of Allowable Messaging on Collaborative Messaging Platforms Meeting Reminders: “Reminder: Team meeting at 2 PM in Conference Room A.” General Scheduling: “I’m running 5 minutes late for our check-in.” Quick Coordination: “Can you review the draft I emailed before 3 PM?” Technical Issues: “Having trouble accessing the shared drive—anyone else?” Non-Substantive Clarifications: “Which template should we use for the report?” Office Logistics: “Lunch orders are here in the break room.” Team Updates: “FYI: IT will be updating our software this evening.”
Examples of Non-Permitted Messaging on Collaborative Messaging Platforms Official Decisions or Approvals: “I approve the final version of the policy update.” Substantive Discussions: “Let’s discuss how to revise the ordinance before the next meeting.” Contract Negotiations: “The vendor agreed to lower the price—let’s move forward.” Policy Interpretations: “Based on our rules, this application should be denied.” Legal or Confidential Matters: “HR is investigating an issue with an employee.” Formal Requests or Directives: “Please submit your final budget recommendations by Friday.” Record-Keeping Information: “Here’s the final list of approved permits for the quarter.”