Record Retention Requirements

Schools and libraries that participate in the Emergency Connectivity Fund Program are required to maintain inventories of devices and services purchased with Program support.

For each connected device or other piece of equipment provided to an individual student, school staff member, or library patron, a school or library must maintain an asset inventory that identifies: (a) the device or equipment type; (b) the device or equipment make/model; (c) the device or equipment serial number; (d) the full name of the person to whom the device or other piece of equipment was provided; and (e) for that device or equipment; and (f) the dates the device or other piece of equipment was loaned out and returned, or the date the school or library was notified that the device or other piece of equipment was missing, lost, or damaged.

The record of services must include the following information: (a) type of service provided (i.e., DSL, cable, fiber, fixed wireless, satellite, mobile wireless); (b) broadband plan details, including: upload and download speeds and monthly data cap; (c) the name(s) of the person(s) to whom the service was provided; and for fixed broadband service; (d) the service address, and (e) the installation date of service: and (f) the last date of service (as applicable).

Participants are required to retain records related to their participation in the Program sufficient to demonstrate compliance with all Program rules for at least 10 years from the last date of service or delivery of equipment.

While a school or library is responsible for retaining all of the information required by the FCC’s rules, it does not need to be managed or maintained in a particular format. Schools and libraries can determine how they format, extract, and retain the required data.

For example, if a school or library separately tracks its inventory, circulation history and student, staff, or library patron data, and collectively all required information is retained for the requisite period of time, no modifications to the school or library’s recordkeeping system would be needed.  In cases where the information is requested by the Commission or USAC, libraries will not be required to modify the information (e.g., connect separately tracked patron data to circulation data) prior to submission.  In requiring schools and libraries to collect and document this information, we commit to ensuring that if the FCC or USAC staff need to access this information (e.g., for audit purposes), they will request and safeguard the information in accordance with the applicable privacy laws and guidance, including using de-identified and anonymized information whenever possible.

Missing, Lost, or Damaged Equipment

Applicants are not obligated to repair devices that break before the three-year mark. However, it is the obligation of schools and libraries to keep track of and document the devices and other equipment that they distribute, and that includes documenting information about missing, lost, or damaged equipment. Schools and libraries can establish their own policies around missing, lost, or damaged equipment and student, staff, or patron responsibilities.