CS6.2 Records and Information Management Corporate …



ERCOT CORPORATE STANDARDDocument Name:Records and Information Management Corporate StandardDocument ID:CS6.2Effective Date:March 16, 2016Owner:Vice President and General CounselGoverns:ERCOT Employees and Contract WorkersApproved:Bill Magness, ERCOT, Inc. President & CEO1. PurposeThis corporate standard and its operating procedure (i.e., OP6.2.1) establish the requirements for the Records and Information Management program at ERCOT. Records and Information Management:makes ERCOT more efficient by reducing the time and resources necessary to maintain information and respond to requests for information (including discovery requests in legal or regulatory proceedings);reduces ERCOT’s system costs and storage capacity;helps ERCOT mitigate the risk of unfavorable publicity, litigation, and fines; and is an ongoing process and not a one-time event or activity.2. Terms and DefinitionsTermDefinitionInformation CustodianAs Defined in the ERCOT Master List of Terms and DefinitionsLegal HoldAs defined in the ERCOT Master List of Terms and Definitions.Non-RecordAs defined in the ERCOT Master List of Terms and Definitions.Records and Information ManagementAs defined in the ERCOT Master List of Terms and Definitions.Records Retention ScheduleAs defined in the ERCOT Master List of Terms and Definitions.RecordAs defined in the ERCOT Master List of Terms and Definitions.3. Standards3.1 GeneralERCOT’s Records and Information Management program is comprised of the following key standards:Each piece of information created or received by ERCOT is either a Record or Non-Record. Guidelines for determining whether a piece of information is a Record are located in OP6.2.1 and in GL6.2.4.ERCOT maintains a Records Retention Schedule on the Corporate Records Management SharePoint site that categorizes Records and specifies a retention period for each category based on ERCOT’s business or legal requirements. Records must be retained for the retention period specified in the Records Retention Schedule and then destroyed promptly thereafter, but no later than six months after the end of the retention period. The Records Retention Schedule must be updated when necessary to comply with changes to ERCOT’s business requirements or legal obligations.Non-Records must be retained only as long as necessary for ERCOT business purposes and must be destroyed promptly thereafter.Records and Non-Records must be stored and maintained in a manner that protects against misplacement, damage, inadvertent destruction, misuse, or theft.Records and Non-Records eligible for destruction must be destroyed systematically and in accordance with OP6.2.1.The General Counsel, or a designee within the Legal Department, has the authority to issue a legal hold on specified Records and Non-Records. While a legal hold is in effect, Records and Non-Records subject to the hold must not be altered or destroyed, regardless of the retention period specified in the Records Retention Schedule.Each Record and Non-Record must be handled according to the relative sensitivity of the information as defined in CS7.6, Information Classification Corporate Standard.3.2 Electronic RecordsIt is ERCOT’s policy that employees and contract workers will cooperate in the advancement and implementation of the following additional key standards for electronic Records:Electronic Records that are not maintained in a specialized ERCOT application (e.g., Concur, Lodestar, Siebel, etc.) should be designated as Records and stored appropriately within the SharePoint application. Additional information regarding management of electronic Records is located in OP6.2.1.To help ensure compliance with this corporate standard, ERCOT uses computer processes that automatically destroy email, documents on SharePoint sites, and documents on network drives (e.g., shared department drives) after a specified period of time. Details about the automatic destruction of documents are located in OP6.2.1.A department will not be able to manage electronic Records in compliance with these standards until the new records management functionality has been implemented for the department. A departmental implementation and training schedule is maintained on the Corporate Records Management SharePoint site.3.3 TrainingAll ERCOT employees are required to complete Records and Information Management training, which will affirm their understanding of the requirements, policies, and procedures of the program. Required training will be provided at least biannually. Additional training may be required as determined necessary by the Records and Information Management team.Additionally, ERCOT employees are encouraged to regularly review the operating procedures and guidelines associated with this corporate standard.4. Roles and AccountabilitiesThis section explains the roles and accountabilities for the Records and Information Management program at ERCOT.4.1 Legal Department4.1.1 General CounselThe General Counsel is accountable for the overall Records and Information Management program, including documentation and training. The General Counsel is responsible for developing and administering the program, educating ERCOT employees and contract workers, and providing support for the organization to carry out day-to-day activities related to the program. The General Counsel also has the authority to institute and remove a legal hold. The General Counsel may delegate these responsibilities within the Legal Department.4.1.2 Legal Department (Records Management)The Legal Department performs responsibilities delegated by the General Counsel.4.2 Business Units4.2.1 Department DirectorThe department director is responsible for implementing the Records and Information Management program in a consistent manner throughout the department and ensuring compliance with this corporate standard and OP6.2.1. The department director approves changes to the Records Retention Schedule and destruction requests for department Records. These responsibilities may be delegated to a department manager.The department director is also responsible for Records retention, maintenance, and storage activities for the department, including compliance with the Records Retention Schedule and any applicable legal holds. Additionally, the department director must consider and adhere to these requirements when implementing any new policies/procedures or when procuring a vendor, system, or application to produce, store, and/or manage Records and Non-Records. The department director may delegate these responsibilities to an information custodian.4.2.2 Information CustodianAn information custodian performs responsibilities delegated by the department director.4.2.3 Employees and Contract WorkersERCOT employees and contract workers receive, create, use, and maintain a wide variety of Records and Non-Records. For this reason, the success of the RIM program at ERCOT depends upon employees and contract workers who understand and comply with their responsibilities.ERCOT employees and contract workers are responsible for creating and maintaining Records sufficient to support their ongoing operations and complying with the Records Retention Schedule and any applicable legal holds. Employees and contract workers must ensure any Records maintained in their work areas are organized and available when needed. Employees and contract workers are also responsible for notifying their department managers of any pending or threatened audit, regulatory proceeding, or litigation that could affect ERCOT’s obligation to retain Records and Non-Records.4.2.3.1 Contract Workers under a Professional Services Agreement (PSA)Contract workers providing services under a PSA are required to adhere to the requirements and procedures outlined in this corporate standard. Additionally, any Records and Non-Records produced, stored, and/or managed by contract workers or a purchased software solution or application must adhere to the requirements for maintaining Records and Non-Records outlined (a) in the Records Retention Schedule, (b) in any other requirements defined by ERCOT, and/or (c) in any applicable ERCOT operating procedures. ................
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