MnDOT Policies

Records Retention and Disposal Procedures

For Records Retention and Disposal Policy (#DM006)

Effective Date: July 12, 2024

Print Procedures (pdf)

Introduction

This document is the technical companion to the Minnesota Department of Transportation’s (MnDOT’s) Records Retention and Disposal Policy.

Definitions

Disposal (Record Disposal)

Permanent removal of a record from MnDOT’s repositories, which could include secure destruction, recycling, deleting, or transferring to the Minnesota State Archives. 

Minnesota State Archives

A department of the Minnesota Historical Society responsible for keeping long-term records deemed of archival value to the state but no longer hold a business need for MnDOT.

See Minnesota Statutes §138.17.

Record (Business Record)

Information that documents MnDOT business decisions or transactions and is designated in the agency's Records Retention Schedule.

Records Disposition Panel

The body that approves government retention schedules. Membership on the panel consists of the Attorney General, Legislative Auditor in the case of state records, State Auditor in the case of local records, and the director of the Minnesota Historical Society.

See Minnesota Statutes §138.17.

Repository

A physical or electronic storage location for documents and records.

Retention Schedule

An official document that specifies each record series and how long they must be kept.

Procedures

Prepare and maintain a records retention schedule

Responsible Party: Records Manager

• Identify business records and data that become part of an official transaction.
• Categorize the records and data by content and determine the retention period, whether required by law or for business needs.
• Obtain approval of MnDOT’s Records Retention Schedule by the State Records Disposition Panel.
• Update the retention schedule to ensure accuracy and compliance with the law and MnDOT’s policies.
• Offer records identified as “Send to State Archives” on the Retention Schedule to the Minnesota State Archives of the Minnesota Historical Society when the disposal date occurs.

Suspend retention time for legal holds

Responsible Party: Chief Counsel

• For records or data that are the subject of a legal hold, the normal record retention and disposal is suspended until the Chief Counsel lifts the hold. The records or data must be preserved and not destroyed while the hold is effective. See the MnDOT Legal Hold policy.

Follow the Records Retention Schedule

Responsible Party: All Employees

• The owner of the record or data is responsible for the compliance with the Records Retention Schedule.
• Each record series on the retention schedule specifies the event that starts the retention period, the record repository, and the method of disposal.
• Records or data classified by the Minnesota Government Data Practices Act as something other than “Public,” must be destroyed in a way that prevents their contents from being accessed.
• See Minnesota Statutes §138.17, subd. 7

Safeguard records against removal or loss

Responsible Party: All Employees

• Employees must identify final records, avoid duplication, and store records in the proper repository for easy retrieval, backup, security and use for the full retention period. Records classified as “Not Public” must be properly secured.

Paper Records

• Must be protected from the elements, fire or flood; and
• Must be transferred to the appropriate person or repository when the owner separates from employment with MnDOT.

Electronic Records

• Must have file formats that are upgradeable for the life of the record and must be capable of being migrated to a different system when necessary;
• Must be secured and backed up for the life of the record and be readily accessible, retrievable, readable, and destroyed or sanitized in compliance with the MnDOT Retention Schedule;
• Must be stored on designated MnDOT network drives or business applications;
• Must not be stored on the computer hard drive, removable drive, personal archives, personal email account, or personally owned devices, such as cell phones or laptops. See MnDOT Mobile and Portable Computing Device Use and Data Security Policy and Guidelines for Information Technology (IT) Use at MnDOT for further information;
• Must not be stored with a cloud computing service or Software of a Service (SaaS) provider. However, if a MnDOT-approved repository does not meet the business needs, managers may apply to the MnDOT Technology Investment Manager for an exception to this requirement. All approved exceptions must have a fully executed data management agreement with the service provider or vendor.


• Both paper and electronic records must readable, retrievable, and secure for the life of the records. This may require upgrades to software, rebinding for books, or moving the records to a more stable repository for safekeeping.  Aside from where statutorily required, only one copy of the record must be kept (be it paper or electronic).