remote deposit of checks
|remote deposit of checks||
We have had several questions about retention and confidentiality of checks when a unit uses remote deposit. We conferred with the Indiana Commission on Public Records about the retention of these checks and their suggestion will be that retention of the checks remain 3 years, however; based on OCPR policy 06-01 (see http://www.in.gov/icpr/files/policyelectronic10years.pdf); the paper can be destroyed after the documents have been scanned and are in the digital repository, so long as the total retention is less than 10 years. We conferred with the Public Access Counselor in regard to confidentiality and he provided that the confidential financial provision, IC 5-14-3-4(a)(5), would allow an agency to redact the person’s account and routing number from the check. The social security number would be considered confidential pursuant to IC 5-14-3-4(a)(12).