SES Record Retention Policy

This policy addresses the retention and disposal of documents and data in the State Examination System (SES). System users will be made aware of this policy during their initial onboarding.

This policy does not supersede the system’s Terms of Use.

SES users are advised that if a state law or policy requires a different retention schedule than this policy’s schedule, the user is solely responsible for complying with any such schedule in accordance with that user’s existing policies and procedures, outside of SES.

Definitions of Record, Documents, and Data

For purposes of this policy, records do not include agency library items, call center support user files or other non-supervisory activity records.

Record

A record in SES is the information generated in the system by state agencies and the companies they supervise during an examination, investigation, and consumer complaint handling in the system. Records are comprised of documents uploaded to the system and data generated in SES during supervision. Both terms are defined below.

Documents

A document is a file that is uploaded to the system during a SA or for complaint handling. These include but are not limited to:
  • The report of examination and report of investigation issued by a state agency.
  • Electronic documents in Word®, Excel®, PowerPoint®, PDF or similar formats in response to an examination or consumer complaint. The report of examination and report of investigation.
  • Other electronic material such as e-mails and audio recordings in response to an examination or consumer complaint.

Data

Data is information that is entered by, or displayed to, SES users on their screens when they use the system. Data is:
  • Generated automatically by the system (i.e., data that can be seen on the user’s screen).
  • Typed in the system by the user in a data entry field as part of the user’s activity in the system.

Examples of data include, but are not limited to, the exam start date; the exam rating (if assigned); comments added to the exam record by examiners when completing procedures; the summary of a complaint.

SES users – state agencies and the companies they supervise in the system – should limit the entry of comments in these fields, including consumers’ personal identifiable information and confidential supervisory information. Data that contains sensitive information should be uploaded to the system in a document wherever possible.

Record Retention and Disposition Schedule

For retention purposes, records in SES refer to the supervision or complaints work initiated and conducted in the system.

For retention purposes, records in SES refer to the supervision or complaints work initiated and conducted in the system. Records are comprised of documents uploaded to the system and data generated in SES during the supervision process or handling of a complaint. Information from each record may fall under one of the two following categories:
  • Category A. Information in this category is retained for 10 years. This retention period will begin to run as of the date the record is closed in the system, or, if applicable, when the last Matter Requiring Attention (MRA) is closed, whichever is later. Records will be permanently deleted from the system at the conclusion of the retention period. The following records fall under category A:

    • All data generated in the system during state supervision, i.e., Supervisory Activities (SAs) and complaints.

    • All documents uploaded to the system by agency users.

    • Documents uploaded by the company user in response to the report of examination, investigation, MRA, or consumer complaint.

    • Any documents assigned to this category by the agency at the agency’s discretion during the examination.

  • Category B. Information in this category is retained for 90 days. This retention period will begin to run as of the date the record is closed in the system, or, if applicable, when the last MRA is closed in the system, whichever is later. Records will be permanently deleted from the system at the conclusion of the retention period. The following records fall under Category B:
    • Documents uploaded to the system by company users during an exam or investigation that are not listed in Category A. For example, this may include documents uploaded to SES in response to an information request or loan request.

SES agency users can download documents from the system anytime until the files are removed from the system pursuant to the SES Records Retention and Disposition Schedules. The system offers a bulk download functionality to agency users for exams and investigations whereby documents associated to a SA can be downloaded in their original format. A state agency with a retention period greater than the policy’s retention timeframes, can use this download feature to store the information on their state agency system to comply with their agency requirements.

SES agency users may also suspend the retention timeframes in the system at their discretion to address pending supervisory matters until they are resolved, at which time they can resume the retention timeframe.