June 21, 2017
Table of Contents 1 Introduction...3 1.1 Purpose...3 1.2 Scope...3 1.3 Review Cycle...3 1.4 Document Owner...3 1.5 Definitions...3 2 Policy...4 2.1 Records and Record Storage...4 2.2 Applicable to All Corporate Functions...3 2.2 Compliance Policy...4 3 Approval...4 2
1 Introduction Under its Delegation Agreement and other regulatory and legal obligations, the Western Electricity Coordinating Council ( WECC ) is required to retain certain Records for designated periods of time. 1.1 Purpose The purpose of this is to provide a legal and business framework for the management, retention, and disposition of WECC Records. This policy is designed to: (1) ensure compliance with all applicable federal and state legal requirements; (2) eliminate accidental or innocent destruction of Records; and (3) permit WECC to identify valuable documents on short notice when needed. 1.2 Scope This policy applies to all Records created or received by WECC officers, directors, employees, contractors, or committee members ( WECC Personnel ) related to WECC functions. This policy covers all Records regardless of format or location. 1.3 Review Cycle This document will be reviewed every two years or as needed. 1.4 Document Owner The document owner is the WECC Corporate Secretary. The document owner, or designee, is responsible for: Reviewing the policy within the review cycle Making any needed revisions to the policy Obtaining Board approval of any revisions Ensuring the policy is appropriately distributed, posted and communicated 1.5 Definitions Term or Acronym Record Definition Any information created, received, and maintained as evidence and information by WECC or its employees in pursuance of legal obligations or in the transaction of business whether in physical form (e.g. paper or other physical document) or in electronic form (e.g. emails, database records, or 3
CMEP FERC NERC electronic files such as spreadsheets or word processor documents, etc.), regardless of where the information is stored or located. Compliance Monitoring and Enforcement Program Federal Energy Regulatory Commission North American Electric Reliability Corporation 2 Policy Records are the sole corporate property of WECC and WECC decides how they are maintained and disposed of. 2.1 Records and Record Storage 2.1.1 The primary focus of this policy is the official Records of WECC. The official Record is the final file or document maintained by WECC s designated custodian. All other copies or files are considered convenience copies which includes all copies, drafts, other temporary working files, and documents maintained by anyone other than the official designated custodian. Convenience copies should not be retained longer than the official Record. 2.1.2 All electronic Records should be saved on a network drive, application database, or other storage solution that is must be regularly backed-up. Local drives and removable storage devices may not be used for Records retention purposes. 2.1.3 If an adequate electronic version of an original paper Record exists, the paper Record is not required for Record retention purposes and should not be maintained or archived on-site or off-site, except as needed for business operations. 2.2 Applicable to All Corporate Functions 2.2.1 It is the policy of WECC to preserve all Records for the period of their immediate or current use, unless a longer retention period is necessary for historical reference or to comply with contractual or legal requirements. 2.2.2 WECC management will maintain a Retention Schedule that meets WECC s business, fiscal, and reference needs. This Retention Schedule will specify retention requirements for WECC Record series, identify the designated Record 4
custodian, and will be updated annually and approved by the Corporate Secretary. The retention schedule will be made available to all WECC Personnel. 2.2.3 This Policy governs those important business Records that are essential to the ongoing and effective functioning of WECC in accordance with its legal obligations. These Records are distinguished from those documents whose continued preservation serves no useful purpose to WECC (e.g. personal email and correspondence, preliminary drafts of documents after the final version has been produced, and unsolicited newsletters and brochures from vendors). Documents that serve no useful purpose should be promptly and systematically deleted and destroyed, with the exception of documents that are relevant to or discoverable in pending or potential litigation and other legal or official proceedings. 2.2.4 This Policy does not distinguish between paper and electronic Records. All Records are subject to the WECC Retention Schedule. If an employee, officer, or director has sufficient reason to keep an email message, the message should be retained in an appropriate recordkeeping system. 2.2.5 WECC Personnel shall not knowingly alter, conceal, or destroy a Record with the intent to impede or obstruct, or influence an investigation or proper administration of any matter within the jurisdiction of any court, department or agency of the United States or in relation to or contemplation of any such matter or case. 2.2.6 Unless specified otherwise in this Policy, the retention period for a Record begins on the date that the Record was received or created by WECC. 2.2.7 WECC management will develop and maintain a Legal Hold Policy that preserves all Records pertaining to certain matters or subjects and prevents destruction of those Records that would otherwise be authorized by this Record retention and destruction Policy. 2.2.8 A Record must be disposed of within one year of the end date of the Record s retention period unless subject to a hold under section 2.2.7 above. 5
2.2.9 Backup tapes are for disaster recovery only and are not an archive or recordkeeping system. 2.2.10 The following items will not be retained unless subject to 2.2.7 and within WECC s technical capability. Instant or text messaging/messages and similar technology Voicemails 2.2.11 The WECC Corporate Secretary is the WECC Records manager. 2.3 Compliance Policy This section contains policy specific to compliance program activities. 2.3.1 All Records generated or received pursuant to the compliance program activities delegated to WECC, including but not limited to all compliance program and hearing process activities, shall be maintained according to the WECC Retention Schedule, unless a different retention period is specified by NERC, FERC, or other applicable law. 2.3.2 The retention period for Records material to a compliance program activity begins after the activity has been completed and any applicable government authority approval has been obtained. 3 Approval Approving Committee, Entity, or Person Date Board of Directors June 21, 2017 This policy supersedes and revokes all past policies and practices, oral and written representations, or statements regarding terms and conditions of employment concerning the subject matter covered herein. WECC reserves the right to add to, delete, change, or revoke this policy at any time, with or without notice. This policy does not create a contract between WECC and any employee or contractor, nor does it create any entitlement to employment or any benefit provided by WECC to its employees or contractors. Caution! This document may be out of date if printed. 6