MEMORANDUM 

 

TO: Indigo Community Development District 

 

FROM: Katie S. Buchanan 

 

DATE: November 17, 2022 

 

RE: Retention Requirements for Transitory Messages and Electronic Records Updates 

 

 

On April 28, 2010, the District approved Resolution 2010-02, adopting a policy relating to 
the retention and disposition of its public records. The District’s Record Retention Policy currently 
remains in full force and effect. In order to ensure the District’s record retention practices remain 
economically feasible and technologically practical, we are offering some clarification regarding 
the retention period for records of short-term value. Additionally, we propose modifications to 
designate the electronic record as the official record of the district and allow for disposal of paper 
duplicate copies unless prohibited by any law, rule or ordinance. 

 According to the General Records Schedule for State and Local Government Agencies 
(“GS1-SL”)1 with which all community development districts must comply, records retention 
requirements “apply to records regardless of the format in which they reside.”2 This means that 
electronic communications, which include emails, instant messages, text messages, multimedia 
messages, chat messages, social networking, voicemail/ voice messaging, or other 
communications via electronic messaging technology or device, must be retained in accordance 
with the applicable section of the GS1-SL. Retention periods for electronic communications “are 
determined by the content, nature, and purpose of records, and are set based on their legal, fiscal, 
administrative, and historical values, regardless of the format in which they reside or the method 
by which they are transmitted.”3 

1 Incorporated by reference in Rule 1B-24.003(1)(a), F.A.C. 

2 General Records Schedule for State and Local Government Agencies, Section V, Electronic Records. 

3 Id. at Records Retention Schedules, Electronic Communications. 

4 Id. at Records Retention Schedules, Transitory Messages, Item #146. 

Electronic communications “created primarily to communicate information of short-term 
value” may fall under the Transitory Messages schedule set forth in GS1-SL.4 Transitory 
Messages do not “formalize or perpetuate knowledge and do not set policy, establish guidelines or 


procedures, certify a transaction, or become a receipt.” Examples of Transitory Messages include, 
but are not limited to: 

· reminder messages (“don’t forget the upcoming meeting”); 
· email messages with short-lived or no administrative value (“thank you”) 
· telephone messages lacking content (“Ms. Smith called – please return her call”); 
· recipient copies of announcements of District sponsored events (“daily events 
email”); and, 
· news releases received by the District strictly for informational purposes and 
unrelated to District programs or activities. 


The retention requirement for Transitory Messages is "[r]etain until obsolete, superseded 
or administrative value is lost."5 For example, an email message notifying employees of an 
upcoming meeting would only have value until the meeting has been attended or the employee 
receiving the message has marked the date and time in the calendar, at which time the message 
could be disposed of. In other words, an electronic communication intended for short-term value 
does not need to be retained once it is no longer needed. Unlike most other public records, the 
District may dispose of a transitory message once it is obsolete, superseded, or has lost its 
administrative value without having to document the disposition of the record, unless the record 
has been microfilmed or scanned and will serve as the record copy.6 

5 Id. 

6 See Rule 1B-24.003(9)(d), F.A.C.