Minnesota Department of Transportation

511 Travel Info

MnDOT Policies

Records Retention and Disposal

MnDOT Policy #DM006
Revised: August 6, 2025

View/print signed policy (PDF)

Records Retention and Disposal Procedures

Please go to the MnDOT Org Chart to find specific contact information: Org Chart.

Responsible Senior Officer: Deputy Commissioner/Chief Administrative Officer
Policy Owner: Chief Counsel, Office of Chief Counsel
Policy Contact: Information Governance Coordinator, Office of Chief Counsel

Policy statement

The Minnesota Department of Transportation (MnDOT) must create and maintain complete and accurate records in compliance with state and federal laws.

Records Retention Schedule and Procedures

MnDOT must create and maintain a Records Retention Schedule as identified in Minnesota Statutes § 15.17.

Additionally, MnDOT has created Records Retention and Disposal Procedures. MnDOT employees must follow the Records Retention Schedule and the Records Retention and Disposal Procedures to:

Data Minimization

MnDOT employees must only collect or retain information identified in the Records Retention Schedule or that is necessary for legitimate business purposes. Avoid saving non-records that would be “nice to have” and delete non-records when they are no longer needed.

Records Classification and Access

The MnDOT Office of Chief Counsel classifies data in the Records Retention Schedule according to the Minnesota Government Data Practices Act and other applicable laws. MnDOT employees must follow the classification assigned to the data in the retention schedule to appropriately control data access in accordance with data practices procedures.

Records Disposition

Defensible Disposition

MnDOT employees must follow the established disposition procedures identified in the Records Retention and Disposal Procedures when records have reached the end of their retention period, including documenting the disposition in the Records Disposition Report.

Any person who improperly destroys a government record may face criminal penalty (Minn. Stat. §138.225).

Legal Holds

When records are under a legal hold, the Record Retention Schedule is superseded, and these records must be kept until the hold is released. Refer to the Legal Holds Policy for specific information regarding legal holds.

Reason for policy

MnDOT records are valuable assets and must be well-organized, easy to retrieve, and disposed of in accordance with this policy and the retention schedule. Proper management of MnDOT’s records ensures the quality, reliability, integrity, shareability, security, and transparency of the records.

Minnesota Statutes §15.17 requires MnDOT to make and keep all records necessary to  a full and accurate knowledge of the agency’s official activities. A critical part of MnDOT’s compliance with the law is the Retention Schedule. The retention schedule creates an inventory of all records series and specifies where to keep the records, how long to retain the records within each series, and when and how the records can be disposed. The Records Disposition Panel approves the retention schedule.

Minnesota Statutes §13.03, Subd. 1, requires MnDOT to keep records containing government data in such an arrangement and condition as to make them easily accessible for convenient use.

Minnesota Statutes §16.08, Subd 4(c), requires MnDOT to make specific agency records (such as contracts for professional and technical services over $25,000.00) available online and submit a copy to the Legislative Reference Library.

Minnesota Statutes §138.17, Subd. 1b, requires MnDOT to transfer records of sufficient historical or other value to the Minnesota State Archives.

Minnesota Statutes §138.17, Subd. 7, requires MnDOT to maintain a list of records disposed according to the Records Retention Schedule. It also requires records containing not public data to be destroyed in a way that prevents their contents from being determined. The Disposition Report functions like a receipt showing that MnDOT is following established procedures, complying with its Records Retention Schedule, and serving as a good steward of its records.

This policy reduces legal risks and ensures efficient use of state resources by specifying record repositories, discouraging duplication, limiting retention, and requiring disposal of records at the end of their retention period.

Applicability

All MnDOT employees must comply with this policy.

Key stakeholders with responsibilities under this policy include:

  • Chief Administrative Officer
  • Chief Counsel
  • Information Governance Supervisor
  • Information Governance Coordinator
  • Records Center Coordinator
  • Office Directors/District Engineers
  • Managers and Supervisors
  • Application Stewards
  • Records Subject Matter Experts
  • Employees
  • Technology Investment Management (TIM) Program

Definitions

Disposal (Records Disposal)

Permanent removal of a record from MnDOT’s repositories, which could include secure destruction, recycling, deletion, or transfer to another entity like the Minnesota State Archives. 

Legislative Reference Library

The Legislative Reference Library is a repository of all documents published by the state and is responsible for the collection, indexing, and availability of governmental and legislative information which will aid members of the legislature to perform their duties in an efficient and economical manner.

MnDOT Records Center

Responsible for cataloging and ensuring storage of physical MnDOT records in a safe and secure environment in accordance with the department’s Record Retention Schedule.

Minnesota State Archives

A department of the Minnesota Historical Society responsible for keeping records of sufficient historical or other value to warrant continued preservation after MnDOT's retention period has ended.

Note: The Minnesota State Archives may inspect any MnDOT records for historical or other continuing value upon request.

See Minnesota Statutes §138.17.

Record (Business Record)

Information that documents final MnDOT business decisions or transactions related to official MnDOT activities and is designated in the agency's Records Retention Schedule.

See Minnesota Statutes §15.17 and §138.17

Records Disposition Panel

The body that approves government retention schedules. Membership on the panel consists of the Attorney General, Legislative Auditor in the case of state records, State Auditor in the case of local records, and the director of the Minnesota Historical Society.

See Minnesota Statutes §138.17

Repository

A physical or electronic storage location for documents and records.

Retention Schedule

An official document that specifies each record series, the designated repository, how long to retain the records within each series, and when and how the records can be disposed.

Responsibilities

Chief Administrative Officer1

  • Consult with the Chief Counsel to confirm the MnDOT Records Retention Schedule complies with state and federal laws.
  • Approve and sign the MnDOT Records Retention Schedule.

Information Governance Supervisor, Office of Chief Counsel

  • Approve and sign the MnDOT Records Retention Schedule.
  • Ensure training, procedures, and other documents associated with the policy remain current.

Chief Counsel, Office of Chief Counsel

  • Ensure the MnDOT Records Retention Schedule complies with state and federal laws.
  • Advise on legal requirements for records retention.
  • Review the policy every 2 years, or sooner as necessary, to ensure the policy remains up to date.
  • Ensure the policy and procedures remain compliant with all state, federal, enterprise, agency, or other requirements.
  • Ensure that necessary approvals by state or federal agencies are obtained before changes to the policy or procedures are implemented.
  • Work with the Policy Coordinator to revise the policy and/or confirm its accuracy.
  • Communicate policy revisions, reviews, and retirements to stakeholders.

Office Directors/District Engineers

  • Guide the management of shared records for the common benefit of MnDOT.
  • Guide the quality, security, retention, timeliness, availability, and reliability of records.
  • Inform users of the proper management of records.
  • Manage records in accordance with data practices classifications and requirements. 

Information Governance Coordinator, Office of Chief Counsel

  • Maintain and update the Records Retention Schedule.
  • Inform employees of the Records Retention and Disposal policy and provide training, as needed.
  • Coordinate records transfers with the Minnesota State Archives.
  • Respond to employees’ questions and their requests for information or assistance with records and disposition.
  • Provide subject matter expertise regarding records management practices.
  • Identify records provided to, impacted by, or retrieved from enterprise or agency technology solutions, including applications.

Records Center Coordinator, Office of Chief Counsel

  • Ensure physical records in the MnDOT Records Center are secure, accessible, and efficiently managed in accordance with the MnDOT Records Retention Schedule.
  • Coordinate periodic disposal of outdated MnDOT Records Center materials.

Managers / Supervisors

  • Know what records are produced by staff and communicate where to store and how to access records.
  • Ensure staff comply with the Records Retention and Disposal policy.
  • Ensure proper management and disposal of records and comply with the Legal Holds policy when employees separate from employment with MnDOT or move to another position within MnDOT.

Technology Investment Management Program

  • As software applications are retired or replaced or professional/technical contracts expire, consult with the assigned Application Steward, the Office of Chief Counsel, and MNIT to ensure that MnDOT data is returned or destroyed as referenced in the applicable Data Management and Services Agreement and Certificate of Return or Destruction of Government Data Agreement.

Employees

  • Treat MnDOT records as valuable assets.
  • Manage records so that they are easily found, retrieved, secured, backed up, and readable for the full retention period.
  • Keep records in designated MnDOT repositories, avoid duplication, and do not save records in prohibited locations like computer hard drives, removable drives, personal archives, personal email accounts, or personally owned devices, such as cell phones or laptops.
  • Follow the Records Retention and Disposal Procedures.

Application Stewards

  • As software applications are retired or replaced or professional/technical contracts expire, consult with the Office of Chief Counsel, the Information Governance Coordinator, and MNIT to ensure that MnDOT data is returned as required by contractual obligation or, if no contractual obligation is in place, by mutual agreement of the parties.

Records Subject Matter Experts

  • Serve as the expert for their assigned record series on the Records Retention Schedule.
  • Assist in determining whether specific documents fall under their assigned record series.

Resources and related information

Forms

Processes, Procedures, and Instructions

Resources

History and updates

Adopted

May 23, 1995 (Policy #95-12 and Guideline #95-12-G-1)

Revised

  • First Revision: July 7, 2000 (Policy #4.14 and Guideline #4.14-G-1)
  • Second Revision: July 28, 2014 (Policy #AD003)
  • Third Revision: September 23, 2015 (Policy #DM006)
  • Fourth Revision: December 7, 2020
  • Biennial Review: December 2, 2022 - Added three policy owner responsibilities to match revised template; added clarification to the responsibility for the Records Manager / Assistant Records Manager to provide
    training for employees, as needed.
  • Fifth Revision: August 6, 2025

Policy Review

This policy's next scheduled review is due August 2027.

1. Minnesota Statutes §15.17, subd. 2. Go back