Record Retention Requirements
Schools, libraries, and consortia that participate in the Emergency Connectivity Fund (ECF) Program are required to maintain inventories of devices and services purchased with ECF Program support.
Asset Inventory: Pursuant to 47 CFR § 54.1715, 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 (i.e., laptop, tablet, mobile hotspot, modem, router);
(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) 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.
Service Inventory: The service inventory must include the following information:
(a) the type of service provided (i.e., DSL, cable, fiber, fixed wireless, satellite, mobile wireless);
(b) the 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;
(d) the service address (for fixed broadband service only);
(e) the installation date of service (for fixed broadband service only); and
(f) the last date of service (for fixed broadband service only).
Participants are required to retain records related to their participation in the ECF Program sufficient to demonstrate compliance with all ECF Program rules for at least 10 years from the last date of service or delivery of equipment, and are required to produce the documents upon request from any representative (or auditor) appointed by a state education department, USAC, the FCC and its Office of Inspector General, or any local, state, or federal agency with jurisdiction over the entity.
For libraries only, a library is responsible for retaining all of the information required by the FCC’s rules, but it does not need to be managed or maintained in a particular format. Libraries can determine how they format, extract, and retain the required data.
For example, if a library separately tracks its inventory, circulation history, and library patron data, and collectively all required information is retained for the requisite period of time, no modifications to the library’s recordkeeping system would be needed. In cases where the information is requested by the FCC 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 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. 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.