Effective date: July 1, 2017
Application: All information stored by the WCB.
Policy subject: Privacy and access to information
To establish guidelines for the storage, archiving, and destruction of information.
Transitory records means records of temporary usefulness that are needed only for a limited time to complete a routine task or prepare an ongoing document. These records are not required to meet statutory obligations or to sustain administrative or operational functions. These records should be destroyed once they have served their purpose.
- POL 05/2017, Privacy of Information establishes guidelines for the collection of information by the Workers’ Compensation Board (WCB), the use of the information collected, together with access to, and disclosure of the information within the control of the WCB.
- The following procedure provides staff with specific guidance with respect to the storage, archiving or destruction of information in compliance with legislative requirements.
- All information that is collected for the purposes of decision making on worker or employer files will be stored on the worker claim record or the employer account file.
- In order to maintain the integrity of the claim record or the employer account file, information collected must be stored on the file in its complete form without the removal or redaction of information, except in the following situations:
- Redaction or removal of information may occur when the file is provided to the worker or employer if it is required to protect the worker or third parties (PRO 06/2017, Authority for Disclosure). Specifically, the WCB will not disclose information that is harmful to personal privacy or individual safety.
- A worker may request the removal of medical information that is irrelevant or excessive for the purposes of administering The Workers’ Compensation Act, 2013 (the “Act”).
- Information that is collected for purposes other than decision making on worker claim or employer account files will be stored by the respective department that is responsible for actions related to that information. For example, information relating to security incidents is stored in an appropriate file in the Safety, Security and Facilities department.
- According to The Electronic Information and Documents Act, 2000 (EID), in the absence of a paper copy of a document, an electronic copy of that document is considered to be a legal original.
- Email correspondence with a customer in the course of business is also considered to be a WCB record, and shall be retained as part of the customer file.
- WCB encourages the scanning, microfilming, and imaging of all paper records in order to improve service and reduce costs.
- To meet the requirements of The Archives Act (AA), the WCB will use the Administrative Records Management System, 2014 (ARMS 2014), a provincial government classification system for common administrative records (http://www.saskarchives.com/sites/default/files/pdf/arms_2014_manual.pdf). The Saskatchewan Archives Board will also provide the necessary assistance for the development of an Operational Records System (ORS) to manage the records specific to the operations of the WCB.
- Each director, manager or other department head is responsible for compliance with this procedure and will act as the designated Records Manager (RM) being responsible for identifying the types of records in their department so that they may be properly categorized in accordance with ARMS 2014.
- After such identification has occurred the RM will develop a records retention schedule (RRS) stipulated by ARMS 2014 or ORS for the storage, archiving and destruction of information. This will include selection of non-current documents of historical interest for transfer to the Archives.
- Records stored in-house will be kept in a clean, dry location with adequate security for the type of information stored. Electronic records will be stored in containers that provide environmental and magnetic protection with a fire rating of at least one hour. Records will not be stored in areas subject to water damage, mold or infestation.
- Off-site private or public storage agencies will be contracted for the long-term storage of records not required on a regular basis, but which may be needed from time to time for reference purposes. In compliance with The Health Information Protection Act (HIPA), the agency must sign an agreement including, but not limited to, the following conditions:
- WCB records will be kept in a clean, dry location with adequate security for the type of information stored.
- Electronic records will be stored in containers that provide environmental and magnetic protection with a fire rating of at least one hour.
- Records will not be stored in areas subject to water damage, mold or infestation.
- The integrity, accuracy, and confidentiality of the information is protected against any reasonably anticipated threat, loss or hazard, and
- The information is to be stored in a manner that is consistent with the ARMS 2014 classification system and for easy retrieval by WCB staff when necessary.
- Records Managers, in consultation with the Privacy Officer, will be responsible for arranging for the storage and destruction of documents no longer needed by departments.
- Records scheduled for destruction in accordance with the RRS will be destroyed under controlled conditions and in a manner that protects the privacy of individual customers and the WCB. Records may be destroyed by shredding, pulverizing, disintegrating or burning of paper, tapes, disks or any other media. Electronic media may also be destroyed by deleting it from the WCB’s storage systems.
- RMs will maintain a log of records disposed, using the form developed under the Saskatchewan Archives Board’s “Records Disposition System” (RDS) for quarterly review by the Privacy Officer.
- The Privacy Officer will ensure ongoing training is provided to RMs as necessary.
- RMs will:
- Consult with the Privacy Officer regarding the development of an ORS/RRS for their department or unit.
- Obtain approvals (manager, vice-president) for the disposition of all expired records listed in the ORS/RRS schedule, and
- Maintain and be accountable for control logs showing the disposition of all board records, electronic and paper. Logs will include a description of the records, the date range and volume of records and the date, method and agency responsible for destruction.
- WCB staff will not keep transitory records. Upon the completion of a final work product, the creator of a transitory record will place the record in a secured disposal bin.
Act Sec #
Act Sec #
20, 21, 22, 25, 140, 172, 173, 174;
The Health Information Protection Act;
The Archives Act;
The Electronic Information and Documents Act, 2000;
Administrative Records Management System, 2014.
PRO 18/2013 Records Management
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