9:110-AP1 Data Governance
Purpose
This procedure establishes Districtwide governance expectations for the classification, handling, retention, and disposal of data in order to support legal compliance, responsible data stewardship, and consistent records management practices across the District.
Scope
This procedure applies to all District data and records, regardless of format or storage location, including but not limited to:
- Student records
- Personnel and employment data
- Financial and operational records
- Instructional, assessment, and administrative information
- Physical and electronic records
This includes records as defined by the Illinois Local Records Act.
I. Data Classification
District data shall be classified into categories that guide access, handling, retention, and disposal requirements.
Data classifications are:
- Public Data – Information approved for public release
- Internal Data – Information intended for internal District use
- Confidential Data – Information involving personal privacy or sensitive operational matters, access limited to individuals with a legitimate need to know
- Restricted Data – Highly sensitive information requiring heightened protection due to legal, regulatory, financial, or security risk; access requires explicit authorization from the Superintendent or designee
Classification determinations shall consider legal requirements, the nature of the data, and the potential impact of unauthorized access, disclosure, alteration, or loss.
II. Data Handling
District data shall be handled in accordance with its classification and applicable legal and policy requirements.
Governance requirements include:
- Access limited to individuals with a legitimate educational or business need
- Appropriate safeguards applied to the storage, transmission, and use of data
- Compliance with applicable privacy laws and District agreements
- Prompt reporting of suspected data misuse, loss, or unauthorized disclosure
This procedure establishes expectations and does not define specific technical safeguards or response procedures.
III. Data Retention
District records shall be retained in accordance with:
- The Illinois Local Records Act
- The Illinois School Student Records Act
- Other applicable federal and state laws
- Board policy and approved records retention schedules
Records shall not be retained longer than required unless legally or operationally justified.
Approved retention schedules are maintained separately from this procedure.
IV. Data Disposal and Destruction
District records shall not be destroyed except in accordance with approved records retention schedules and applicable law.
When records reach the end of their required retention period, they shall be disposed of in a secure and appropriate manner to prevent unauthorized access, recovery, or reconstruction.
These requirements apply to both physical and electronic records.
V. Roles and Responsibilities
- Board of Education
Establishes data governance expectations through policy. - Superintendent and Cabinet
Provide executive oversight and ensure Districtwide alignment with data governance requirements. - Technology Department
Supports implementation of approved data governance requirements. - Departments and Staff
Serve as data stewards and are responsible for managing data in accordance with this procedure.
VI. Review and Compliance
This procedure shall be reviewed periodically to ensure continued compliance with applicable laws, Board policies, and records management requirements.
Adherence to this procedure supports internal reviews, external audits, and regulatory compliance obligations.
Date Approved: March 2, 2026