603 CMR 3.12 sets forth the regulatory requirements for student records, including what records schools must keep and for how long; however, the regulation does not specify in what medium the records must be kept. Therefore, it is the Department's policy that schools may keep records in either paper or electronic format. However, this policy does not apply to transcripts, which must be kept in paper form on a permanent basis. Schools that choose an electronic format, must do the following:
1) Notify the Department in writing that the school will be using an electronic document storage system, specifying what system will be used, how often back ups of the system will be conducted, and where back ups of the system will be kept, both in-house and offsite.
2) Keep hard copies of student records, excluding transcripts, for a minimum of 3 years. After 3 years, the school may dispense with the hard copies in favor of electronic storage. The school is not required to keep the electronic records longer than 7 years.
3) Maintain hard copies of all transcripts for as long as the school is in operation. Upon closure, a school may opt to provide the hard copies of the transcripts to the Department for safekeeping. While the Department is not required to take the transcripts, it does so as a service to students of closed schools.