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CC - CONSENT ITEM: Adoption of a Resolution Amending the Records Retention Schedule for the City of Culver City, Authorizing Destruction of Certain City Records in Accordance with the Amended Retention Schedule, and Rescinding Resolution No. 2024-R063.
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Meeting Date: March 9, 2026
Contact Person/Dept: Jeremy Bocchino / City Clerk’s Office
Phone Number: (310) 253-5851
Fiscal Impact: Yes [] No [X] General Fund: Yes [] No [X]
Attachments: Yes [X] No []
Public Notification: (E-Mail) Meetings and Agendas - City Council (03/04/2026)
Department Approval: Lisa Soghor, Assistant City Manager (03/03/2026)
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RECOMMENDATION
Staff recommends the City Council adopt a resolution amending the Records Retention Schedule for the City of Culver City (“Retention Schedule”), authorizing destruction of certain City records in accordance with the amended Retention Schedule, and rescinding Resolution No. 2024-R063.
BACKGROUND/DISCUSSION
In 1999, Section 12236 was added to the California Government Code, which states, in part, “[t]he Secretary of State shall establish the Local Government Records Program to be administered by the State Archives to establish guidelines for local government retention and to provide archival support to local agencies in this state.” The guidelines were an initial attempt to provide some standards and structure to the local government records management effort.
To reduce current and future records storage costs, eliminate duplication of effort, increase efficiency, and take advantage of current technology and changes in law, City Clerk staff enlisted expert records management company Gladwell Governmental Services, Inc. to review department needs and create a schedule for records retention, which was adopted by resolution on August 14, 2017. The adopted Retention Schedule was based upon the then current laws regarding government records and replaced the 2006 Secretary of State Guidelines.
As new laws go into effect and as part of a subscription service, Gladwell Governmental Services provides updates to the Retention Schedule to ensure that it includes those laws. During this time, departments also reviewed the adopted Retention Schedule and provided updates to reflect the needs of each department more accurately, which are also reflected in the amended Retention Schedule.
The Retention Schedule was last amended on October 14, 2024 by Resolution No. 2024-R063 and requires further updates. Attached is a proposed Resolution amending the current Retention Schedule.
A summary of key substantive changes to the Retention Schedule are as follows:
• ALL Schedules:
o MODERNIZATION / ELECTRONIC RECORDS AS THE OFFICIAL: In all schedules, changed the “Destroy Paper after Imaged & QC'd?” to “Yes: After QC & OD” for most records series.
o The legal requirements for the electronic record to serve as the Official / Original record are summarized in the Records Retention Legend in the explanation of the “Destroy Paper after Imaged & QC'd” column, as they have been in the past.
o Databases (Major): Since many databases are image-enabled and have original documents attached within the database and many are providing unalterable media backups / immutable media backups, the media options have been updated to include options to attach original / official records to them. The legal requirements for the electronic to serve as the original / official record remain the same: See the Legend, “Destroy Paper after Imaged and QC’d?” column for the legal requirements for the electronic record to serve as the official / original record.
• City-Wide:
o CW-024: Correspondence - Routine removed Reading, Working Files.
o CW-024: Description Update: Correspondence - ROUTINE (IF CONTENT relates in a SUBSTANTIVE way to the conduct of the public's business) Improved the description, added SUBSTANTIVE Synonyms: Significant, Meaningful, Considerable, Essential to assist employees.
o CW-025: Correspondence - TRANSITORY / PRELIMINARY DRAFTS (Content Not Substantive) added “undeliverable envelopes / returned mail” to the examples
o CW-064.5: added new item (CW-064.5) to comply with SB 513 Reference Materials: Added descriptions for various records series that other agencies have encountered when destroying records during the year: Policies, Procedures, Brochures, Handbooks, Manuals, Flyers, Newsletters, Plans (if not provided in the schedule.) Standard Operating Procedures (SOPs), Studies / Reports (if not provided in the schedule.)
o New Item CW-064.5 - Training EMPLOYEE RECORDS (All Employee Training) to comply with SB 513
o CW-065 - Description Update: added Fiscal & Financial training
• City Clerk:
o Updated Change: The FPPC has removed the requirement for the agency to retain a paper version of Campaign Statements or Economic Statements for 2 years
o CC-035 - Elections - Petitions (Initiative, Recall or Referendum) Deleted that item and split into 3 new items:
§ CLK-035.1- Elections - Petitions (Initiative, Recall/Referendum) - If Insufficient - If Examined by proponents
Retention: Final Examination + 1 year after petition examination
§ CLK-035.2- Elections - Petitions (Initiative, Recall/Referendum) - If Insufficient - Not Examined by proponents
Retention: Determination of Insufficiency + 8 months
§ CC-035.3: Elections - Petitions (Initiative, Recall/Referendum) If Sufficient
Retention: Results + 8 Months
Comments/Reference: Not accessible to the public; The 8-month retention applies after the City Clerk makes the determination of insufficiency / examines the petitions. unless there is a legal or FPPC proceeding. EC §§17200(b)(3), 17400
o CM-049 - Description Update: Ethics Training Certificates, Fiscal and Financial, Harassment Prevention Training Certificates - Total Retention changed to Separation + 5 years
• Fire:
o FR-005 - Description: changed to meet SB 513
Employee Training File (by employee)
Required Information for all Employee Training: Employee Name, Training Provider’s Name, Date, Duration (length), Core Competencies / Skills, Certifications / Qualifications
Retention: Indefinite - Minimum Separation + 5 years
o FR-014 - Description Update: Training RMS Database (Target Solutions / Vector Solutions)
Required Information for all Employee Training: Employee Name, Training Provider’s Name, Date, Duration (length), Core Competencies / Skills, Certifications / Qualifications
Retention: Minimum Separation + 5 years
o FR-023.1 - deleted, included with FR-024, which now reads “Fire Inspections / Business Inspection Files / Occupancy Inspections - Approvals, Inspections, Fires, Modification / Alternative Methods or Materials) / Fire Citations / Notice of Violations”
o New Item: FR-027.5 - Fire Plans/Fire Sprinkler, Fire Safety Plans (Final, Approved by the Fire department Only)
Retention: Life of the Structure or Activity, or Minimum 5 years, Whichever is Longer. Comments: Changed to reflect the new legal citations: CFC §§ 1.8.4.3.1, 104.7; CBC § 107.5; H&S §19850; GC §34090
• Housing:
o New Item: H&HS-012.5 - (some may not go to Council for approval): Housing Plans: Consolidated Annual Performance and Evaluation Review (CAPER) / Comprehensive Housing Affordability Strategy (CHAS) / Consolidated Action Plan / Analysis of Impediments to Fair Housing Choices / Citizen Participation Plan / Action Plans, etc. Total Retention: Superseded + 5 years
Comments: 24 CFR 91.105(h); 24 CFR 92.508(a); GC §3409
• Human Resources:
o HR-015 - Description Update : added “Training Certificates” to Personnel Files to comply with SB 513
Retention: Separation +15 years
o HR-022 - Description update: removed “Training” from Workplace Violence because the retention mandate from SB 513 for Training Certificates is now Separation + 5 years (not just a straight 5 years).
• Information Technology:
o IT-004 - UNALTERABLE MEDIA / IMMUTABLE MEDIA
Retention: Changed from (Permanent) to “Follow Retention of Official Electronic Record”
• Parks, Recreation and Community Services:
o PR&CS-028: Retention Update - Swimming Pool Chemical Readings Retention Change: 2 years
Comments: 22 CCR 65523; GC §34090
• Planning & Development/Building:
o Building Permit and Building Plans: A new Building Code was effective in January, changed the legal citations in various records series
• Planning & Development/Current Planning:
o New Item: CD-038.5 - Planning Project Files - Cancelled/ Expired/ Withdrawn
Total Retention: Minimum Cancellation, Expiration or Withdrawal + 2 years
Comments: Department preference; Preliminary drafts not retained in the ordinary course of business; GC §34090
• Police:
o PD-008.2 - Automated License Plate Reader Data / ALPR recordings
Retention: minimum 30 days
Comments: Recordings that become evidence are stored with evidence; Does not record regular and ongoing operations; GC §34090.6 et seq;
o PD-037: Description Update: changed to meet SB513 - Personnel Files - Police Department Employees / Training Files (By Employee)
Required Information for all Employee Training: Employee Name, Training Provider’s Name, Date, Duration (length), Core Competencies / Skills, Certifications / Qualifications
Total Retention: Separation + 5 years
o New Item: PD-043.5 - Recordings: Body-Worn Cameras - Accidental Recordings Reviewed and Approved for Deletion (Non-evidentiary)
Total Retention: After Approval
Comments: Department preference; consistent with Lexipol policies (review, supervisory authorization, and documentation required); PC§ 832.18 et seq. GC §34090.6 et seq.
o PD-067.1 - Incident Reports / Crime Reports of Arrests: Sealed Juvenile Cases - Childhood Sexual Assault - Before January 1, 2024
Retention: Age of Majority + 22 years
Comments: Department preference to accommodate statute of limitations for victims; CCP §§340.1, GC §34090
o PD-069.4 & PD-069.5 Description Update: Registrants: Gang Adults (& Juveniles) - Shared Gang Databases - added CalGang (the name of the State’s Shared Gang database)
Retention: added “After Last Reset” as certain conditions can reset the retention, which is controlled by the local law enforcement agency
• Public Works:
o PW-054 - Aboveground Storage Tanks: changed the comments and retention. Comments: added EPA FAQs recommend Life of the Tank
Total Retention: Life of the Tank
• Transportation:
o TR-001 - Aboveground Storage Tanks: changed the comments and retention. Comments: added EPA FAQs recommend Life of the Tank
Total Retention: 20 years Life of the Tank
o TR-036 - Description Update: Videotapes of Vehicle Operations / Exterior and Interior of Public Transportation Vehicles
Retention: When No Longer Required
Comments / Reference: 1 year is not required - No forward-facing or parking control videos; 1. The agency has made a diligent effort to identify a security system that can store recorded data for one year. 2. The agency determines that the technology to store recorded data in an economically and technologically feasible manner for one year is not available. 3. The transit agency purchases and installs the best available technology with respect to storage capacity that is both economically and technologically feasible at that time. PUC §99164; GC §34090.6
Other additional changes include updating the department keeper of record for certain documents and other minor administrative updates.
FISCAL ANALYSIS
There is no financial impact associated with the adoption of the proposed Resolution; however, in general, there is some financial savings realized with the implementation a Records Retention Schedule. The savings include labor and storage expenses, including the avoidance of future storage and/or destruction costs.
ATTACHMENTS
1. 2026-03-09_ATT 1_Proposed Resolution Amending the Records Retention Schedules
MOTION
That the City Council:
Adopt a Resolution Amending the Records Retention Schedule for the City of Culver City, Authorizing Destruction of Certain City Records in Accordance with the Amended Retention Schedule, and Rescinding Resolution No. 2024-R063.