Records management policy

Version: 2.0
Policy Owner: Legal Services Division
Approval: Executive Leadership Team (ELT)
Effective Date: April 1, 2025

1. Purpose

Toronto Community Housing (TCHC) recognizes that Records are its corporate memory, providing evidence of actions and decisions, and represent a vital asset to support TCHC’s daily operations and administration. 

In addition to supporting consistency, continuity, 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 this policy is to: 

• Ensure that Records are systematically and efficiently managed from their time of creation or receipt until their ultimate disposition (Records Life Cycle) in support of the corporation’s mission, business priorities and risk management initiatives, and in compliance with legislated recordkeeping requirements

• Provide 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.

2. Scope

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

• all Records in any medium, created or received by TCHC and maintained to satisfy statutory obligations and/or manage and document business transactions.

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

• All tenant-related Records created and/or managed by Toronto Seniors Housing Corporation (TSHC).

3. Policy details

3.1 Policy statement

TCHC will manage its Records in accordance with recognized standards and codes of best practice for Records management and in accordance with the requirements of applicable legislation.

3.2 Policy guidelines

The following guidelines will be used to implement this policy and for the development of a Records Management Program: 

3.2.1 Corporate ownership of records

• All Records created or received by TCHC are the property of TCHC and will be treated as an asset of TCHC. Records are not owned by employees, committees, divisions/units, or other parties that created or received them. Records will be managed in accordance with this policy and any related policies and procedures.

3.2.2 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.

3.2.3 Records organization and retrieval

• All Records will be organized according to TCHC’s Records Classification which arranges the records of the corporation’s business activities into logically structured hierarchies.

3.2.4 Managing the records classification

• All business units are encouraged to suggest changes to the Records Classification for the purposes of usability and efficiency. Requests for changes will be submitted to the Records Management Unit so that changes can be recorded and implemented in a controlled manner.

3.2.5 Records access

• Information in TCHC records will be made available – subject to limitations on the use or disclosure to employees, as required, 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 the process requirements and exemptions under the Municipal Freedom of Information and Protection of Privacy Act (MFIPPA).
• Any TCHC Record in the public domain will remain publicly accessible for the duration of the retention period specified as per TCHC’s Records Retention Schedule.

3.2.6 Records storage

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

3.2.7 Records protection

• TCHC Records will be protected from unauthorized access, use, disclosure, alteration, deterioration, and loss. Special attention and processes will be assigned to Records containing Personal or Confidential Information.
• Vital Records will be identified and protected to ensure they will be available without delay under abnormal conditions.

3.2.8 Records retention and disposition

• Records will only be destroyed or disposed of (e.g., erased, transferred to an archive) 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 this 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.

3.2. 9 Preserving the Corporation's history

• Archival or Historical Records that explain or clarify the history of the corporation will be identified and appropriately preserved.

3.2.10 Securing records

• All employees will ensure that Records are appropriately secured when they leave their workspace. Physical Records will be locked if necessary, and computers and other devices will be secured through password protection at a minimum. Computers will be logged off all networks at the end of day.

3.3. Roles and responsibilities

• Legal Services Division (LSD): is responsible for the development and implementation of the Records Management Program within TCHC and co-chairs the Records and Data Steering Committee (RDSC). The LSD initiates the Disposition of Official Records process on a yearly basis at the direction of the RDSC.
• Records and Data Steering Committee (RDSC): is the owner of all processes and standard operating procedures that support this policy. It will be comprised of certain members of the ELT as well as key members of management.
• Records Management Unit (RMU): is a unit within LSD and is tasked with the design, implementation, and control of the Records Classification and Records Retention Schedule, and is the lead for the development and implementation of all Records Management processes and procedures.
• Record Owners: are responsible for ensuring Records under their purview are secure, protected and accessible by all appropriate employees. This includes the timely destruction of Records at the end-of-life of the Record. The Record Owners are the organizational division heads as represented by ELT.
• Record Steward: is a delegated authority from a Records Owner to operationalize the Records Management Program processes and SOPs.

4. Standards

• Records management should be an ongoing activity at all levels of the organization and within subsidiary corporations.
• TCHC will provide all employees and its subsidiary corporations with the tools and training required to satisfy their obligations to comply with the Records Management Policy and Program.

Through the implementation of the 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 a reasonable doubt;
• 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;
• Records are held only as long as necessary to satisfy their business objective or legislative/regulatory obligation;
• Records containing Personal or Confidential Information are appropriately secured and access to them is limited to authorized individuals; and
• Vital Records are identified and safely secured so they remain available in the event of a catastrophe.

5. Compliance and Monitoring

•  All TCHC and TSHC employees and its subsidiary corporations are required to comply with the Records Management Program.
• TCHC will monitor the application of this policy from time to time. 

6. Definitions

• Archival or Historical Record: Record which is created or received and accumulated by TCHC in the course of its operations and which is considered worthy of permanent preservation
• Classification Code: In the Records Retention Schedule, the Records Classification Codes are used to further refine the arrangement of Records into more specific topics. There may be many Classification Codes under each broad topic and there may be many Records under each Classification Number.
• Confidential Information: Refers to sensitive information that, if made available to the unauthorized individuals or groups, would have an adverse affect on the organization, its board members, and/or its employees.
• Personal Information: Has the same meaning as defined in MFIPPA and includes recorded information about an identifiable individual which is collected, used, or disclosed by TCHC and subsidiaries and TSHC. For the application of this Policy, Personal Information may include but is not limited to:
  • the personal address, telephone number, or email address of an individual;
  • any identifying number assigned to an individual which can lead to their identification (e.g., Social Insurance Number);
  • information relating to the race, national or ethnic origin, colour, religion, age, sex, sexual orientation, or marital or family status of an individual;
  • financial information about an individual for the purposes of establishing Rent-Geared-to-Income assistance;
  • information about rent payment history;
  • credit and rental history reports; and
  • employee information, including resumes, salary and benefits, tenant or client complaints about the individual, and personnel issues.
    • With regards to applicants and tenants, personal information may include: income, credit history, subsidy, arrears, personal circumstances, health, conflicts between tenants, requests for transfers for personal reasons, and any requests from tenants that are personal in nature.
    • With regards to employees: personal information may include hiring, termination, disciplinary record, salary negotiations, tenant complaints, and problems between employees members.
• Record: Information created or received by any TCHC business unit in the course of its business. Records are not specific to any particular medium or format. They may take the form of (a) paper documents, forms, reports, manuals, correspondence, and files; (b) computer files such as spreadsheets, databases, word-processed documents, and e-mail messages; or (c) information in other formats such as video tape, audio tape, microfilm, and photographs, etc.

Records are broken into two categories: Official Records and Transitory Records

• Official Records: contain information that is required to be retained for business or legal reasons. An Official Record satisfies an organization’s legal and administrative retention requirement and provides evidence of organization, business functions, policies, decisions, procedures, operations and internal or external transactions. Examples may include, but are not limited to:
  • Original invoices;
  • Signed contracts;
  • E-mails that contain work product in the body of the e-mail, especially legal advice or any directives that are contrary to standard procedures;
  • Original Receipts;
  • Original documents that demonstrate compliance with governmental requirements;
  • Final version of an Audit Report;
  • Etc.
• Transitory Records: These are Records that do not need to be retained for business or legal reasons and therefore can be deleted/disposed of at any time. A Transitory Record is not necessary to satisfy an organization’s legal or administrative retention requirements. This applies to Records for which there are multiple drafts, copies and versions in which the final version is an official document. Transitory Records also include any copy of a Record maintained for convenience purposes, rather than to document a final version. Examples include, but are not limited to:
  • Duplicates or “convenience copies” of Official Records that have not been annotated;
  • Document drafts that have been superseded by approved, official versions;
  • Published literature, catalogs and trade journals;
  • Casual correspondence including records created to facilitate meetings for internal communication (most e-mail messages fall in this category);
  • Reference or training materials which have no on-going value;
  • Information copies of memoranda;
  • Etc.
• Records Classification: arranges the records of the corporation’s business activities in a logical manner, breaking down activities from broad to narrow topics.
• Records Life Cycle: the 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 (RMP): the 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 RMP addresses the retention and disposition of Records, organization of Records, protection of Records, Records storage and retrieval, identification and control of Personal Information and Confidential Information. RMP encompasses policies, procedures, systems, operations, space, equipment, and employees. The RMP will define roles and responsibilities within the organization to ensure program activities are completed and the appropriate accountability is assigned.
• Records Retention Schedule: is a listing of all record types, sorted by Classification Number with their corresponding applicable legislated citations for which the Record is governed. The Records Retention Schedule indicates the length of time that the Record must be kept to meet legal, legislative, or business requirements. Disposition may include destruction of the Record or the transfer of the Record to provincial or city archives for permanent retention. The Records Retention Schedule also identifies Records with archival merit (Records that cannot be destroyed) and whether it is considered a Vital Record.
• Vital Record: are those Records without which an organization cannot continue to operate in the event of a disaster or emergency. These Records provide continuity in the event of a disaster or emergency because they contain information required to reestablish business after a catastrophe has ended, as well as protect the assets and interests of the corporation, its employees, and interested parties. These include, but are not limited to, Records required to:
  • Evaluate inventories and properties;
  • Determine liabilities;
  • Determine employee benefits and liabilities;
  • Rebuild facilities;
  • Serve TCHC’s legal and accountability purposes.

7. Governing and Applicable Legislation

Federal Legislation

• Canada Pension Plan Act
• Employment Insurance Act
• Excise Tax Act
• Income Tax Act
• Personal Information Protection and Electronic Documents Act (PIPEDA) 

Provincial Legislation

• Arbitration Act
• Building Code Act
• Business Corporations Act
• Corporations Information Act
• Corporations Tax Act
• Employer Health Tax Act
• Employment Standards Act
• Fire Protection and Prevention Act
• Insurance Act
• Land Transfer Tax Act
• Limitations Act
• Mortgages Act
• Municipal Freedom of Information and Protection of Privacy Act (MFIPPA)
• Occupational Health and Safety Act
• Ontario Municipal Employees Retirement System Act
• Real Property Limitations Act
• Social Housing Reform Act (SHRA)
• Technical Standards and Safety Act
• Tenant Protection Act (TPA)
• Workplace Safety and Insurance Act 

8. Related Policies and Procedures

• TCHC Code of Conduct Policy
• TCHC Conflict of Interest Policy
• TCHC-City of Toronto Shareholder Direction
• Records Management Procedure 

9. Commencement and Review

Publication Frequency: Every 5 years, or when there are changes to risk factors or other documents that have an impact to the content of this Policy.

Next Planned Publication: April 2030