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Retention Guidelines for Common Administrative Records of the Government of Canada

Section 1, Part 2

Real Property Management Function
(Function-based arrangement)

Section 3 - Exceptions to the General Retention Guideline - Real Property Management Function:

Function/Description

Retention Guidance
Always apply the General Retention Guideline unless specified otherwise

Assessing and Planning Real Property Requirements

 

This sub-function generally encompasses the business processes and activities which produce records created by government institutions while evaluating existing assets and resources, and assessing current and future organizational needs; developing short-term to maximum long-term strategic planning and life-cycle costing of acquisition alternatives; coordinating the development of real property objectives based on requirements for institutional programs and plans that are consistent with corporate goals, including environmental objectives, policy and legislation; keeping inventories and maintaining records of real property administered by departments and Crown corporations, including recording information in the Directory of Federal Real Property (DFRP) containing the central records of the real property holdings of the Government of Canada; seeking the administration of real property, through acquisition or transfer only when the property is required for the purposes of the departments programs; conducting regular reviews of the real property administered, linking it to program requirements, and confirming that the current use of it is appropriate; ascertaining the environmental condition of the property before acquisition and determining whether it is or can be made environmentally compatible with its intended use; and systematically examining and assessing the condition of the real property in inventory and using this information to determine when and how to acquire, maintain, preserve, and renew its value based on the full life-cycle costs of the property involved.

 

Current and Future Planning and Requirements, Plans for Expansion, Space Allocation, etc.

 

Construction - General requirements, preliminary discussions and investigations

5 years after completion of structure

Reports and Statistics

3 years

Acquiring Real Property Assets and Related Services

 

This sub-function generally encompasses the business processes and activities which produce records created by government institutions that add new real property to the federal inventory by purchase, lease, exchange, gift, easement, expropriation, or any other means, such as the acceptance of the surrender of a lease or the acceptance of the relinquishment of a license or easement; transfer of administration of real property from a department or an agent Crown corporation to a department; or a transfer of administration and control of real property to the federal government. It also includes the contracting for or provision of services supporting the acquisition, use and maintenance of real property; for example, cleaning, utilities maintenance and repair, office design, fire-protection or investigating and reporting, snow removal, surveying, etc… Note: Whereas this sub-function includes the management of the Real Property Management common administrative activities and processes involved in contracting for or procuring of related services, it does not include the financial management of Comptrollership activities related to acquisitions. These records are covered by the MIDA 1999/004 Comptrollership Function. As well, all records documenting activities related to any real property, or about the property itself, which has a recognized or classified heritage designation from the Department of Canadian Heritage are operational in nature, and are therefore, excluded from the scope of MIDA 2001/002.

 

Construction

 

- Arrangements and Consultant Services (tenders, discussions with architects, contractors and suppliers about costs, building materials, subcontractors, completion dates, progress reports, inspection and takeover, etc…).

3 years after takeover

- Cancelled projects

2 years after cancellation

Plans, Drawings and Specifications

Until superseded or obsolete

- Government owned

Until superseded or obsolete

- Leased

2 years after obsolete or expiry/cancellation of lease3

- Routine correspondence

3 years after completion or cancellation4

Signage (includes records associated with identifying government real property - advance signs, primary identification signs, directory boards, common-use etc…)

 

Utility Systems (Air conditioning and ventilation, refrigeration, gas, hydro power, lighting, plumbing and heating, telecommunication, water and sewer, disposal of hazardous waste)

 

- Installation

2 years after installation

Operating and Using Real Property Assets

 

This sub-function generally encompasses the business processes and activities which produce records created by government institutions while operating and using real property assets such as, buildings, works, lands, communications systems, hydro-electric structures, utility infrastructures, sewers and drainage, or other fixed structures on, above or below the surface of the land; ensuring that real property is used for its intended purpose; using real property in a manner consistent with the principle of sustainable development contributing to protecting and preserving the environment, and in a manner that protects their heritage character; providing a safe, healthy and productive environment in facilities; ensuring barrier-free access to, and use of, real property owned or leased; ensuring the real property conforms to physical and fire standards and policies on occupational health and safety; and ensuring that the appropriate program department administers real property, and the total real property a department administers (referring to the stewardship between a department and the real property it uses for its program purposes and for which it is accountable) is limited to that required to directly support its program.

 

Addresses and Locations

Until superseded or obsolete

Elevator Services

 

- Routine correspondence

1 year

Protection (From fall-out, nuclear blast, warning devices (sirens) etc… Includes preventive measures)

3 years

Trespassing

 

Maintaining Real Property Assets

 

This sub-function generally encompasses the business processes and activities which produce records created by government institutions while ensuring real property assets are properly maintained to extend the service life of the asset for as long as the property is required for the purposes of the institutions programs; repairing, refurbishing, altering, improving, and reusing assets when economically feasible; submitting annual reports to the Treasury Board of Canada Secretariat reflecting changes made to accessibility plans and implementation progress on accessibility improvements completed to real property. Real Property must be managed and maintained to the maximum long-term economic advantage of the government, to honour environmental objectives, and to provide safe and adequate facilities.

 

Alterations and Repairs

3 years after completion or cancellation5

Damages - Reports of Investigations into the Damage

3 years after investigation completed6

Development

 

- Ditching and drainage

2 years

- Excavation

2 years

- Landscaping and Gardening

2 years

Fencing

2 years

Fires - Reports

 

- Major

5 years

- Minor

2 years following completing report to Dominion Fire Commissioner

Note: It is incumbent upon the institution to determine the difference between major and minor. Generally, however, the value of the asset determines whether it is considered minor or major.

 

Flood Control (Preventive measures and control of minor floods)

3 years

Maintenance (cleaning and janitorial services, re-decorating, garbage removal, recycling etc…)

1 year

Parking Areas; Recreation Areas; Roads, Streets, and Sidewalks (including snow removal)7

2 years

Replacing, Transferring and Disposing of Real Property Assets

 

This sub-function generally encompasses the business processes and activities which produce records created by government institutions while replacing, exchanging, transferring, disposing, or selling-off real property when these assets are beyond cost-effective repair or are no longer required for the purposes of an institutions programs, including custody transfer of administration of real property that supports an adjustment to or transfer of program accountability, such as transfers to support the government's reassignment of program responsibility, transfers to support government restructuring, and transfers to recognize a more appropriate custodian; disposing of real property which includes alienating real property by sale, lease, exchange, gift, easement, or any other means, such as the surrender of a lease or the relinquishment of a real property from one department to another department or an agent Crown corporation, or a transfer of administration and control of real property from the federal government; and disposing of real property in a manner consistent with the principle of sustainable development contributing to protecting and preserving the environment, and in a manner that protects their heritage character.

 

Legal Documents

 

- Lease, rental, rights of way, easements and concessions

3 years after termination or expiry of lease, concession, right of way etc…

- Purchase, transfer, sale, etc.

Original documents are transferred to new owner. Institutions must retain copies until all operational and legal requirements have expired.

Lettings and Concessions, Rights of Way, Easements, Leases, etc., for Crown-owned Lands by Private Corporations or Persons or Privately-owned Lands by the Crown (excluding legal documents)

3 years after expiry of lease, concession, right of way etc. involved.

Sale, Transfer, Expiry of Lease, etc… (excluding legal documents)

3 years after sale, transfer, expiry of lease, etc.

3. Original retention guidance stated "Until obsolete." With amalgamation of all "Plans, drawings and specifications" for Buildings and Utilities this was changed to "2 years after obsolete or expiry/cancellation of lease" in keeping with retention guidance originally provided in Real Property Function for Utilities/Actual construction plans and specifications/leased - 2 years after obsolete or expiry/cancellation of lease.

4. Originally, this was broken down to "for minor structure worth less than $5,000 - 1 year" and "for structures others worth more than $5,000 - 3 years." LAC team decided to amalgamate and adopt higher retention to reflect today's current dollar value. As we have referenced users to the Comptrollership function for financial records and have identified this as "Routine Correspondence" original query to roll-up retention to 6 years can be removed.

5. Originally broken down into "Major (over $1000) - 3 years after completion or cancellation" and "Minor (under $1000) - 1 year after completion or cancellation." As these dollar values are outdated the LAC team decided to amalgamate and adopt the greater retention period for all. That said, currently, the Comptrollership Function suggests a standard retention period of 6 fiscal years for financial transaction records such as vouchers, invoices, claims etc... This retention is applied after all administrative actions have been completed. What LAC is questioning is whether there are any legislative or policies in place which bolster the need to apply the same retention period to common administrative records that support or document a financial action. References: the 1996 Treasury Board "Policy on Electronic Authorization and Authentication" Appendix A, Guidelines, iii Audit states that "The electronic authorization and authentication system and processes should be designed to ensure complete auditability. The audit trail should include delegation matrices, user profiles and all the electronic authorization and authentication data and files required to reconstruct the sequence of events and the transactions processed" and the Treasury Board "Policy on Internal Audit" (takes effect on April 1, 2006 and will replace the 2001 Policy on Internal Audit) under section 5. Policy Requirements, 5.5 states that "Deputy heads of all departments are responsible for:" under 5.5.3 "Ensuring that the audit committee receives all of the information and documentation needed or requested to fulfill its responsibilities, subject to applicable legislation."

6. Previously divided into: Major: over $1000 - 3 years after investigation complete and Minor: under $1000 - 1 year after investigation complete. These dollar value are not conducive to today's market… Team members thought it best to remove the "major" and "minor" categories and go with the higher retention period for all damage correspondence/reports.

7. Previously, "Highways" also identified under this activity. LAC team recommends removal of "highways" as the maintenance of highways is not a common administrative activity shared by GoC institutions.

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