Records management policy

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    Policy Owner: Finance
    Approval: Executive Leadership Team
    First Approved: January 2006
    Effective Date: N/A

    Summary of policy

    This policy sets out TCHC’s commitments for the efficient and systematic control of TCHC’s records which support the continuing conduct of business, comply with legislated obligations, and provide necessary accountability.

    The policy will be used to inform and guide decision- making which will preserve the corporation’s memory. The policy will be implemented as part of the TCHC Records Management Program which will address the retention and disposition of records, organization of records, and records storage and retrieval.


    TCHC recognizes that records are its corporate memory, providing evidence of actions and decisions, and representing a vital asset to support the corporation’s daily operations and administration.

    In addition to supporting consistency, continuity, efficiency and productivity, records facilitate policy formation and managerial decision-making, assist the corporation to comply with its legislated obligations, contribute to corporate governance, and ensure accountability to management, shareholders, tenants, regulatory bodies and the public.


    The purpose of the records management policy is to ensure that records are systematically and efficiently managed from their time of creation or receipt (records life cycle) until their ultimate disposition in support of the corporation’s mission, business interests and risk management initiatives, and in compliance with applicable legislated record-keeping requirements.

    The policy also provides a framework for incorporating records management principles into TCHC’s day-to-day operations and for deploying a corporate Records Management Program to manage the corporation’s records.

    Application of policy

    The policy applies to TCHC and its subsidiary corporations, and applies to:

    • all records created, received and maintained by any division/unit as evidence and information by TCHC in pursuance of its statutory obligations and/or in the transaction of business.

    • records in any medium. Records may take many forms including, but not limited to: paper, cartographic and architectural items, pictorial and graphic works, photographs, films, microforms, sound recordings, videotapes, web pages, magnetic tapes or disks, and any other electro-magnetic medium (including e-mail). Records are often, but not necessarily, originals.

    • all TCHC records in the custody of third parties contracted by the corporation (e.g. payroll processing).


    • Classification Scheme (System): The file classification scheme or system arranges the records of the corporation’s business activities in a logical manner, breaking down activities from broad to narrow topics. It also identifies the division/unit (Office of Primary Interest) responsible for the management of each group or series of the corporation’s records.
    • Classification NumberUnder the classification scheme, classification numbers are used to further refine the arrangement of records into more specific topics. There may be many classification numbers under each broad topic defined by the classification scheme, and there may be many records under each classification number.
    • Office of Primary InterestThe Office of Primary Interest (OPI) identifies the division (or unit within a division) that is considered to be the official holder of the original records for that particular record series. More than one division or unit can be the OPI for a particular record.
    • Records life cycleThe life cycle of a record is the span of time from the record’s creation or receipt through its useful life to its final destruction or retention as an archival record.
    • Records Management Program (RM): The Records Management Program is responsible for the efficient and systematic control of TCHC’s records which support the continuing conduct of business, comply with legislated obligations and provide necessary accountability. The program addresses the retention and disposition of records, organization of records, and records storage and retrieval.

    The Records Management Program encompasses policies, procedures, systems, operations, space, equipment and staff.

    • Records Retention ScheduleThe records retention schedule is a listing of all records, sorted by classification number with their corresponding applicable legislated citations for which the record is governed. The retention indicates the length of time that the record must be kept to meet legal, legislative and/or limitation requirements. It also identifies what division or unit is considered the official holder of the record (Office of Primary Interest) and the method of disposition of the record. The retention schedule also identifies records with archival merit (records that cannot be destroyed) and whether it is considered a vital record.

    Policy statement

    TCHC will manage its records in accordance with recognized standards and codes of best practice for records management and in accordance with prevailing Canadian legislation, as applicable.

    All TCHC staff and its subsidiary corporations are responsible for adhering to and following the commitments set out in the records management policy and program.


    Through the implementation of the records management policy and Records Management Program, TCHC will ensure that:

    • records needed to reconstruct past activities and transactions are made and preserved;

    • it is possible to locate and access information and view it in a way that is true to the original presentation;

    • records and their representation remain true to the records originally created and used, and their integrity and authenticity can be demonstrated beyond reasonable doubt; and

    • records are maintained so that the information they contain can be accessed, interpreted and trusted for as long as necessary and on transfer to other approved locations, systems and technologies.

    Policy guidelines

    The following guidelines will be used in implementation of the policy and the development of a Records Management Program:

    Corporate ownership of records

    • All records created or received by TCHC in pursuance of its legislated obligations and/or in the transaction of business are the property of the corporation and shall be treated as an asset of the corporation. The records are not owned by the employees, committees, divisions/units or other parties that created or received them and the records shall be managed in accordance with this policy and any related policies and procedures.

    Managing the records life cycle

    • All records must be managed appropriately during their life cycle to ensure the records remain accessible, usable, accurate and complete for as long as necessary to support business operations and/or to satisfy legislated requirements and to ensure that the records’ authenticity, content, context, structure and confidentiality are protected and maintained over time (creation to destruction or archival).

    Records organization and retrieval

    • All records will be organized according to TCHC’s classification scheme which arranges the records of the corporation’s business activities into logically structured hierarchies and identifies the division/unit (Office of Primary Interest) responsible for the management of each group or series of the corporation’s records.

    Records access

    • Information in TCHC records will be made available – subject to limitations on the use or disclosure of certain information – to staff, as and when required in their work, so as to support management decision-making and the conduct of operations.

    • Information in TCHC records will be made available to the public and other parties (e.g. regulatory bodies) upon (written) request subject to exemptions under the Municipal Freedom of Information and Protection of Privacy Act (MFIPPA).

    • Any TCHC records in the public domain shall remain publicly accessible for the duration of the retention period specified for those records in the corporation’s records retention schedule.

    Records storage

    • Records will be stored according to the processes and in the locations approved by the Records Management Program.

    Records protection

    • TCHC records will be protected from unauthorized access, disclosure, alteration, deterioration and loss

    • Records containing information critical to TCHC’s continued operation or its survival during or immediately following a disaster (i.e. vital records) will be appropriately identified and protected to ensure they will be available without delay under abnormal conditions. Vital records may also contain information necessary to recreate the corporation’s legal and financial status and to preserve the rights and obligations of stakeholders, including employees, regulatory bodies and the public.

    Records retention and disposition

    • Records will only be destroyed or otherwise disposed of (e.g. transferred to an archives) according to the retention periods and disposition methods authorized in TCHC’s records retention schedule. Any extension to an approved retention period will only be supported if there is a demonstrated need.

    • It is contrary to TCHC policy to destroy, delete, alter, discard or otherwise make inaccessible any record or other information that may be relevant to an ongoing, imminent or pending audit, investigation or litigation.

    Preserving the corporation’s history

    • Archival or historical records created or received and accumulated by TCHC in the course of its operations and which are worthy of permanent preservation because they elucidate the history of the corporation will be identified and appropriately preserved.


    • TCHC will monitor the application of this policy from time to time.

    • Requests for records will be monitored and tracked to determine the number of requests, retrieval times, retention schedule compliance, etc.

    • TCHC will communicate the policy to staff and will make the policy publicly available on the TCHC website.

    • TCHC will communicate the Records Management Program to staff, members of the public and other stakeholders.


    All TCHC staff and its subsidiary corporations are required to comply with the Records Management Policy and Records Management Program with respect to records classification, retention, protection, storing, organizing, filing and disposition.

    Records management should be an ongoing activity at all levels of the organization and within subsidiary corporations.