Records Retention and Disposal Procedures

For Records Retention and Disposal Policy (#DM006)

Revised: August 6, 2025

Introduction

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

Definitions

Disposal (Records Disposal)

Permanent removal of a record from MnDOT’s repositories, which could include secure destruction, recycling, deletion, or transfer to another entity like the Minnesota State Archives.

Minnesota State Archives

A department of the Minnesota Historical Society responsible for keeping records of sufficient historical or other value to warrant continued preservation after MnDOT's retention period has ended.

Note: The Minnesota State Archives may inspect any MnDOT records for historical or other continuing value upon request.

See Minnesota Statutes §138.17.

Record (Business Record)

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

See Minnesota Statutes §15.17 and §138.17

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, the designated repository, how long to retain the records within each series, and when and how the records can be disposed.

Procedures

Prepare and maintain a Records Retention Schedule

Responsible Party: Information Governance Coordinator

Work with subject matter experts to identify records necessary to a full and accurate knowledge of official MnDOT activities.
Categorize the records into series by content and determine the retention period, whether required by law or for business needs.
Indicate the record series identified by the Minnesota State Archives with continuing historical or other value as "Send to State Archives" on the retention schedule.
Update the retention schedule to ensure accuracy and compliance with the law and MnDOT’s policies.

Approval of Records Retention Schedule

Responsible Party: Information Governance Coordinator

Obtain required internal approvals of MnDOT’s Records Retention Schedule.

Additions or deletions of a record series on the Records Retention Schedule as well as changes to the following fields must be approved by the relevant Office Director(s)/District Engineers(s), Deputy Chief Counsel – Technology and Data, and the Technology and Data Leadership Committee (TDLC):

Retention number
Title
Description
Retention starts at
Time to keep in years
Whether the record is considered vital

Changes to the Data Practices Classification field must be approved by the Deputy Chief Counsel – Technology and Data. No other approvals are required.
Changes to any other field not listed above must be approved by the relevant Office Director(s)/District Engineer(s). No other approvals are required.

For changes under item 1a above, obtain required signatures on the Minnesota Records Retention Schedule Form:

Agency Records Management Officer (Information Governance Program Supervisor)
Agency Head or Designee (Deputy Commission – Chief Administrative Officer)
State Records Disposition Panel

Minnesota Historical Society Director
Legislative or State Auditor
Attorney General

Suspend records disposal for legal holds

Responsible Party: Chief Counsel

For records that are the subject of a legal hold, the normal retention period is suspended until the Office of 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 is responsible for compliance with the Records Retention Schedule.
Each record series in the retention schedule specifies the event that starts its retention period, the designated storage location, the required disposal method, the best contact person or subject matter expert, and whether the record is likely to contain “not public” data.

Responsible Party: Subject Matter Expert

Work with the Information Governance Coordinator to determine appropriate document classification.
Assist employees with questions regarding documents classified under their assigned record series.

Store records and safeguard 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.
Use the Records Retention Schedule to identify the designated storage location for each record. Designated storage locations may be changed through the Information Governance Program with the appropriate Office Director(s) or District Engineer(s) approval. Complete the MnDOT Records Retention Schedule Update Request to initiate a change in the designated storage location.
Records classified as “not public” must be properly secured. See the Data Practices Interchange page
Records must be accessible and understandable by at least two employees.
Limit record storage and retention time to that which is required for legal, regulatory, and/or business requirements.¹
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.
The format of an official record may be changed but must not alter the content (for example, paper records may be converted to electronic). The new format has the same effect and weight as the original as long as it accurately and clearly reproduces the original content.²
Only one copy of the record must be kept (either paper or electronic), unless otherwise required by law.
If an official record is damaged, it may be reproduced, and the reproduction has the same effect and weight as the original as long as it accurately and clearly reproduces the original content³. Contact the MnDOT Information Governance Program for assistance.

Paper Records

Should, whenever possible, be stored with the MnDOT Records Center. See the Records Center Interchange page for information on preparing, transferring, and requesting physical records from the Records Center.
Must be protected from fire or flood and stored in a secure, clean, cool, and dry location not exposed to the elements. The location should be climate controlled with an appropriately weight-rated floor.
Must not be easily accessible to the public.
Must not be stored in an employee’s home office.
Must be transferred to the appropriate person or repository when the owner separates from employment with MnDOT.

Electronic Records

Under Minnesota Statutes § 325L.12, electronic records satisfy laws that require a record to be retained as long as they accurately reflect the information contained in the record and remain accessible for later reference.

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 stored in the designated location according to the Records Retention Schedule. Unless otherwise designated, eDOCS is the designated location for electronic records.

Use the information on the Records Retention Schedule to appropriately assign the Record Series ID and Doc Type for records in eDOCS. Assigning the appropriate Record Series ID and Doc Type is important for ensuring records are retained according to the retention schedule.

Must not be stored in Teams chats or Outlook, or anywhere:

they could be easily destroyed (for example, desktop, computer hard drive, removable drive, or external hard drive).
that does not belong to the state (for example, personal online storage such as Google Drive or Dropbox, personal devices like cell phones or laptops, or personal email accounts).

Should follow Best Practices for File-Naming.
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 Records Retention Schedule.
Should be shared as links instead of attachments whenever possible.
Should only accessed by MnDOT employees from a MnDOT device and/or through an approved remote access option.

Resources

Disposal Procedure

Responsible Party: All Employees

Use the MnDOT Records Retention Schedule to identify records that have reached the end of their retention period and follow instructions for when retention time is finished.
If instructions for when retention time is finished indicate "Send to State Archives," follow the State Archives Transfer Procedures.
If records may have historical value but are not marked as “Send to State Archives,” consult with the MnDOT library to determine whether to transfer the records to the library when retention time is finished.
Complete the Records Disposition Report when destroying MnDOT records or permanently transferring them outside of MnDOT.
Records 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 determined.
See Minnesota Statutes §138.17, subd. 7 and Physical Environmental Security Standard, Minnesota IT Services

Contacts

Information Governance Program Supervisor

Jennifer W. Witt
651-366-3541
jennifer.w.witt@state.mn.us

Information Governance Coordinator

Megan Bauer
Call via Teams
megan.bauer@state.mn.us

^{1. MNIT Data Protection Categorization Standard Go back}
^{2. Minnesota Statutes § 15.17, Subd. 1 Go back}
^{3. Minnesota Statutes § 600.135 Go back}