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Electronic records (e-files and emails) are also considered documents, and NAIS recommends that however
        long a record is "kept" in paper is how long it should be kept electronically.

        Each Renbrook department and office is responsible for following the NAIS and ISM guidelines, as well as for
        creating a system in which to store and catalog records. The goal of this system is to enable employees to
        locate a stored record with relative ease.

        The Chief Financial Officer oversees the Records Management Policy.

        Source:
        Wilson, Debra P. "Records in Independent Schools: What, How Long, and How?" NAIS publication, March 2007
        www.nais.org/files/PDFs/Records_Retention_05final.pdf.

        www.nysais.org/uploaded/Heads_Back_Page/Records_in_Independent_Schools07.pdf
        7/22/05

        SAFEGUARDING PERSONAL INFORMATION


        "Effective October 1, 2008 Connecticut law requires that both individuals and businesses that possess personal
        information of others to put into place safeguards to protect that information from misuse by others. The law
        not only requires the safeguarding of personal information, but also requires effective disposal of documents
        and computer files containing the personal information."
        [Shipman and Goodwin Security Alert July 2008]

        The School maintains records for employees, students, parents and alumni that include various items of
        personal information. The information contained in these records is presumed in all cases to be confidential
        and must be treated so by employees. Employees who have access to personal information must respect the
        privacy of employees, students, parents, and alumni by safeguarding information from inappropriate use
        and/or disclosure. Employees who become aware that personal information is not safeguarded have an
        obligation to report the breach of confidentiality to the Head of School and/or Chief Financial Officer.

        Certain information about the School, its Trustees, employees, students, alumni, vendors, and/or suppliers,
        although not personal in nature, should be considered confidential information by all employees. Only
        employees authorized to do so may publicly disclose such information. For the purpose of this policy, such
        information shall include, but not be limited to, financial information about the School, methods of operation
        and organization, and information concerning relationships with past, present or potential students,
        employees, vendors and suppliers.

        Deliberate breaches of confidentiality constitute a breach of trust with the School community and may be
        cause for immediate dismissal.

        Employee Records and Privacy
        Employee personnel records contain information and documents directly related to the employee's job at the
        School and the employee's benefits.

        This information may include, but is not limited to:
            •  application and resumes
            •  information obtained from reference and background checks
            •  job description
            •  letters of commendation or complaint
            •  attendance records
            •  emergency contact information
            •  benefit election forms
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