/var/www/www_htdocs/Applications/PoliciesAndProcedures/html-policies/1NLll3SkjKz2qSRyy7Sq00sNW6I1MUhqN/index

INFORMATION

GOVERNANCE

POLICY

Policy Type:

Management

Initially
Approved:

May 28, 2026

Policy Sponsor:

General Counsel
and University
Secretary

Last
Revised:

Primary Contact:

Privacy, Access
and Information
Governance
Office

Review
Scheduled:

May 28, 2031

Approver:

Board of Governors

OVERVIEW

Mount Royal University creates, receives, maintains and has access to information as part of its
regular activities as a post-

secondary institution within the Province of Alberta. The University’s

information  is  considered  an  asset  of  the  University.    The  information  serves  to  provide
documentation of institutional activities and is relied upon to support informed decision-making.

The  University’s  approach  to  Information  Governance  articulated  in  this  policy  creates  a
governance framework that supports the management of information in whatever form within the
University’s operations.

PURPOSE

The purpose of this Policy is to establish roles and responsibilities for Employees with respect to
how information is managed throughout the University. This Policy also sets out a framework under
which University Employees engage with mandatory rules, informal guidelines and foundational
principles as they perform these roles.

The principles within this Policy are intended to support the establishment of suitable practices with
respect to the management of information. These principles and practices will enhance E

mployee’s

ability to access valuable documentation to enable informed decision-making by the University.

While this Policy primarily references Information Assets, this term is intended to have a broad
meaning that extends to all records in whi

ch the University’s information is stored, regardless of

medium.

SCOPE

This Policy applies to all Employees. Additionally, this Policy applies to all information held by the
University, regardless of medium, with the exception of information which is not considered to be
an asset of the University and includes the following:

● Teaching Materials - Teaching or course materials generated and owned by Faculty

Members, except where a Faculty Member transfers copyright or ownership of the
materials to the University.

●

Research  Materials  -  Research  material  or  other  records,  including  research  data,
presentations,  publications  and  reports  generated  by  Faculty  Members  in  the  course  of
their  scholarship,  provided  that  such  research  is  not  directly  commissioned  by  the
University. Note

– these documents may be subject to the Procedure for the Collection,

Storage and Authenticity of Research Data.

● Published Materials - Books, magazines, articles, or other works acquired by the

University, for example the Library

’s Collections. This includes digital sources of published

information such as websites, published information accessed via accounts or other
licensed works (including creative commons) not under the control of the University.

● Health Information held on behalf of health practitioners - Health records for which the

University is not the health custodian under the Alberta Health Information Act. Note

–

these records are managed under the Health Information Act.

●

Cultural Materials - Cultural material, artifacts or similar records gifted to the University for
academic or operational use, which are managed by specific cultural traditions and/or
customs. These materials should be maintained in accordance with the traditions in which
they were received.

● Artistic Materials - Any materials that meet the definition of Artwork under the Art Policy.

Note

– Artwork should be managed in accordance with the Art Policy and its procedures.

● Archival Materials - Records held by the University Archives & Special Collections.

● Affiliated Organizations - records held by organizations that are affiliated with, but

independent of, the University are maintained independently by those organizations.
However, records held by the University in support of the relationship between the
University and the affiliated organization are the Information Assets of the University.

Although this Policy does not apply to the above materials, the principles outlined in this Policy may
still provide guidance

Information is intended to have a broad meaning extending to both physical and digital mediums.
Excluding the exceptions above, wherever the University’s information is set out (in whatever form),
this is considered an Information Asset to which this policy applies.

POLICY STATEMENT

1.

PRINCIPLES OF INFORMATION GOVERNANCE FRAMEWORK

1.1

All Information Assets that Employees create, receive, manage and have access
to within their role, regardless of medium, are an asset of the University as these
records facilitate the operations and activities of the University.

1.2

Information Assets will be managed to a standard that reflects their relative
sensitivity, importance and value for the University. Information Assets will be
managed in accordance with the Procedure for the Management of Information
Assets

and the University’s legal obligations.

1.3

Information Assets will be managed using reasonable security measures that are
proportionate to the privacy or confidentiality of the information contained in the

Information Assets. These reasonable security measures should mitigate against
such risks as unauthorized access, collection, use, disclosure or destruction of the
information contained within the Information Assets.

a) Information Assets which contain private, confidential or important information

will be managed at a higher standard than other Information Assets.

b) The privacy or confidentiality of Information Assets will be informed by the

security classification conducted in accordance with the Procedure for the
Classification of Information Security.

c) Information Assets will be managed in accordance with the Information

Security Policy.

1.4

Information Assets should be designated for destruction when they no longer have
sufficient operational use, including when any relevant retention periods under this
Policy have expired. Information Assets designated for destruction should be
destroyed using appropriate mechanisms for destruction given the importance and
sensitivity of the information contained in the Information Assets.

DESIGNATED RECORDS

Official Records

2.1

Certain Information Assets which are of most importance to the University are
designated as “Official Records” of the University. Official Records are centrally
categorized under the authori

ty of the University’s Executive.

2.2

Official Records:

a) not only support University Operations, but provide authoritative

documentation of the most significant activities, operations or decisions of the
University;

b) are retained in accordance with mandatory retention periods established for

the Official Record category;

c) need to be formally maintained, retained and protected in a way that strongly

aligns to the Principles set out in the Procedure for the Management of
Information Assets; and

d) provide reliable information of University activities to support informed

decision-making.

Transitory Records

2.3

In the course of University operations, some Information Assets are generated
which are, by their nature, intended for short-term operational use. These records
will have limited ongoing value for the University’s operations and are referred to
as “Transitory Records”.

2.4

Transitory Records:

a) cannot be an Official Record of the University;

b) cannot be the authoritative record of a decision of the University;

c) must be managed in the same manner as other Information Assets while in

use; and

d) can be destroyed by the Employee who created them, at their own discretion,

once they are no longer operationally needed.

ROLES AND ACCOUNTABILITIES

All Employees

3.1

All Employees of the University have responsibilities for the University’s
information that they create, receive, manage and have access to within their roles.
These responsibilities include the following accountabilities:

a) understanding their role with respect to the Information Assets they engage

with in their work;

b) identifying if any of the Information Assets for which they are responsible are

an Official Record or a Transitory Record;

c) managing the Information Assets for which they are responsible. This

includes:

managing the Information Assets in accordance with any applicable
practices, rules or guidelines set out in the Procedure for the
Management of Information Assets;

ii.

adhering to the security measures established for the Information
Assets;

iii.

identifying Information Assets that are designated for destruction; and

iv.

where responsible for the destruction of the Information Assets,
carrying out the destruction using methods reflective of the sensitivity
of the information contained in the Information Assets.

3.2

Where the Employee is uncertain as to their responsibilities, the Employee will
engage with their manager to receive clarity with respect to their obligations.

3.3

Multiple Employees may have responsibilities over the same Information Asset. In
such instances, Employees should seek clarity from the Department Leader
responsible for the Information Asset.

Executive Leaders

3.4

Executive Leaders are collectively accountable for the oversight of the institutional
information governance framework established in this Policy and individually
accountable for the oversight of the management of Information Assets held within
their Divisions.

3.5

Executive Leaders are responsible for establishing Official Record categories in
accordance with the process outlined in the Procedure for the Categorization of
Official Records.

3.6

Executive Leaders must consider the factors outlined in the Procedure for the
Categorization of Official Records in establishing Official Record categories.

3.7

Department Leaders may propose new Official Record categories to their
Executive Leaders. Such proposed Official Record categories remain subject to
the approval of the Executive Leader.

Department Leaders

3.8

Department Leaders are responsible for the management of the Information
Assets within their Department. This includes:

a) Ensuring that Information Assets within the Department are managed in

accordance with the Procedure for the Management of Information Assets.

b) Directing Employees within their Department in the proper application of both

reasonable  security  measures  and  destruction  methods  established  by  the
University  to  mitigate  against  risks  such  as  the  unauthorized  access,
collection,  use,  disclosure  or  destruction  of  Information  Assets  held  by  the
Department Leader

’s Department.

c) Managing institutional Official Records assigned to the Department Leader

’s

Department. This includes acting as the approval authority for Official Records
that are designated for destruction.

d) Proposing additions, deletions or revisions to the categories of Official Records

managed by that Department Leader to their Executive Leader.

3.9

Department  Leaders  are  considered  the  accountable  leader  over  those
Information Assets and Official Records for which they are responsible.  They may
assign  further  roles  for  specific  Information  Assets  or  Official  Records  for  which
they are responsible.

3.10

Department Leaders and Employees with designated roles will perform their
responsibilities in accordance with the Procedure for the Management of
Information Assets.

DEFINITIONS

(1)

Data:

means all recorded information in digital mediums, that is
collected, created or managed by the University in the course
of its operations.

(2)

Department:

means a faculty within the Academic Division or a department
outside  of  the  Academic  Division.    This  definition  does  not
include  Academic  Departments.    For  clarity,  within  non-
academic  Divisions,  several  smaller  Departments  may  form
part  of  a  larger  Department  within  the  Division,  with  each  of
these units each being individual

ly considered a “Department”

for the purpose of this Policy.

(3)

Department Leader:

includes the leader of a Department or any other person
designated as a Departmental Leader by ELT. As an illustration

this includes Vice-Provosts, Deans, Vice-Deans, Associate
Vice-Presidents, Directors and Managers.

(4)

Division:

means a division of the University that is led by a Vice-President
or the President.

(5)

ELT:

means Executive Leadership Team.

(6)

Employee:

means individuals who are engaged to work for the University
under an employment contract, including but not limited to,
faculty, staff, exempt, casual and management employees.

(7)

Executive Leader:

means a member of the ELT who manages a University
Division.

(8)

Faculty Member:

A person responsible for an academic or scholarly activity and
can include course instructor, faculty member, practicum
coordinator, work integrated supervisor, research associate
and others.

(9)

Information Asset:

means  Data  or  other  record  containing  the  University’s
information  in  any  form  or  medium  and  includes,  but  is  not
limited  to,  notes,  emails,  letters,  images,  audiovisual
recordings,

documents,

databases,

maps,

drawings,

photographs, invoices and any other information materials that
are  is  written,  photographed,  recorded,  captured  or  stored  in
any  manner,  but  does  not  include  the  materials  specifically
excluded  in  the  Scope  of  this  Policy.  The  definition  includes
Data  itself,  but  does  not  include  software  or  any  mechanism
that stores, produces or reads the Data.

(10)

Official Records:

means an Information Asset that is categorized as an Official
Record in the Policy.

(11)

Policy:

means this Information Governance Policy.

(12)

Principles:

means the principles for the management of Information Assets
set out in the Procedure for the Management of Information
Assets.

(13)

Transitory Records:

means an Information Asset that meets the description
articulated in the Policy.

(14) University:

means Mount Royal University.

F. RELATED POLICIES

●  Art Policy
●  Access to Information Policy
●  Privacy Policy

● Information Security Policy

G. RELATED LEGISLATION

● Access to Information Act, SA, 2024, c.A-1.4

● Protection of Privacy Act, SA, 2024, c P-28.5

H. RELATED DOCUMENTS

● Art Collection Procedure
● Procedure for the Categorization of University Official Records

● Procedure for the Collection, Storage and Authenticity of Research Data

● Procedure for the Classification of Information Security

● Procedure for the Management of Information Assets

● International Standard: ISO 24143 - Information Governance - Concepts and Principles

(2022)

REVISION HISTORY

Date
(mm/dd/yyyy)

Description of
Change

Sections

Person who
Entered Revision
(Position Title)

Person who
Authorized
Revision
(Position Title)