000.180 Personal Device Use

1000.180 PERSONAL DEVICE USE PROCEDURE

A. PURPOSE

This procedure establishes expectations for the creation, retention, and disclosure of text messages and communications conducted on personal devices when used for college business.

B. DEFINITIONS

1. Public record and other terms defined in the Public Records Act shall have the same meaning in this procedure as they have under the Public Records Act. Public records include any writing, electronic media, email, video recording and/or other recording and must be an existing and identifiable record. Any record created by an employee or representative of the state as part of their official duties or using state resources is a potential public record.
2. Transitory record: A short-term communication with no administrative, legal or historical value.
3. Substantive record: A communication that documents decisions, actions, policies, or historical value.

C. USE OF TEXT MESSAGING FOR COLLEGE BUSINESS

1. Permissible Use:
   1. Brief, operational or time-sensitive communication.
   2. Scheduling and logistical coordination.
2. Restricted Use:
   1. Personnel actions or discipline
   2. Complaints, investigations, or grievance matters
   3. Policy decisions or approvals.

If such communication occurs, it must be preserved and transferred to an official college system.

D. RECORDS RETENTION REQUIREMENTS

1. Transitory messages may be deleted when no longer needed.
2. Routine administrative messages are retained per retention schedules.
3. Substantive records must be retained per SBCTC retention schedules.

E. PERSONAL DEVICES AND RESPONSIBILITIES

1. Employees using personal devices must:
   1. Retain work-related messages.
   2. Ensure accessibility for retrieval.
   3. Transfer substantive messages to official systems.
   4. Produce records upon request.

Use of a personal device does not exempt a communication from disclosure requirements.

F. PUBLIC RECORDS REQUESTS COMPLIANCE

1. Employees must:
   1. Conduct reasonable searches of personal devices.
   2. Provide responsive records.
   3. Provide declarations if required.

G. LITIGATION AND PRESERVATION HOLDS

Employees must preserve all relevant text messages when notified of a public records request, litigation or investigation.

H. PROHIBITED PRACTICES

1. Deleting messages to avoid disclosure.
2. Conducting substantive business via text without retention.
3. Failing to search personal devices.
4. Using apps to evade retention or disclosure.

I. TRAINING AND COMPLIANCE

1. Employees will receive training on public records and retention requirements.
2. Supervisors are responsible for compliance.
3. Failure to comply may result in disciplinary action and legal risk to the college. 

Approved by the president’s cabinet: 4/21/26
Last reviewed: 4/21/26
Policy contact: Human Resources

Related policies, procedures and other relevant laws and resources

000.170 Public Records Policy
000.180 Personal Use Device Policy
1000.170 Public Records Procedure

RCW 34.05, 40.14.060, 42.56
WAC 132W-277
State Board for Community & Technical Colleges