Every September we get the same call. A school business manager in Lowell or Newton or Andover has just walked into a basement storage room and found sixty banker’s boxes of student files going back to the Clinton administration. Nobody in the building knows which ones are legally required to stay and which ones should have been destroyed years ago. The custodian wants the room back. The superintendent wants a number. Somebody vaguely remembers a state regulation. That is where this guide starts, because Massachusetts actually answers the question in writing, and the answer is more specific than most districts realize.
By Erica McKowski, Compliance Manager · Updated September 2026 · 12-minute read
Massachusetts splits every student file into two piles
Before you can decide what to destroy, you have to know which of two categories a document falls into. Massachusetts regulation 603 CMR 23.00 divides the student record into the transcript and the temporary record, and the two carry completely different clocks.
The transcript is the short one. It holds the information the state considers permanent: name, address, phone, birth date, course titles, grades, credits and grade level completed. That is a handful of pages per student, and it stays for sixty years after the student graduates, transfers or withdraws. Sixty years. A student who left Lowell High in 1975 still has a transcript the district is expected to hold.
The temporary record is everything else, and in most buildings it is ninety-five percent of the paper. Standardized test results, class rank, extracurricular activities, evaluations by teachers and counselors, health information, discipline records, correspondence with parents, incident reports and the loose paper that accumulates in a manila folder over thirteen years of schooling. Under 603 CMR 23.06, the temporary record must be destroyed no later than seven years after the student transfers, graduates or withdraws.
Read that as a deadline rather than an option, because that is how it is written. The regulation does not say a district may destroy the temporary record after seven years. It says the record shall be destroyed no later than seven years out. A district holding fifteen years of temporary records is not being careful. It is holding personal information past the window the Commonwealth set, on students who are now adults with jobs, mortgages and credit files.
The seven-year clock starts later than people assume
The most common mistake we see is districts counting seven years from the date a document was created. The clock does not start there. It starts when the student leaves the system: transfer, graduation or withdrawal.
So a kindergarten health form from 2010, for a student who graduated in 2023, is not due for destruction in 2017. It is due by 2030, because the file follows the student and the whole temporary record ages together from the exit date. This is why storage rooms fill up. A single graduating class of 300 students generates hundreds of pounds of temporary record that then sits for seven more years before it becomes eligible.
The practical consequence is that a district always has roughly seven graduating classes of temporary record in storage at any moment, plus whatever backlog was never purged. If your building holds more than that, you have a purge waiting to happen. Districts that run the purge annually keep the storage footprint flat. Districts that skip a few years end up calling us in September with sixty boxes and no plan.
One more timing rule that gets missed: 603 CMR 23.06 also requires the principal or a designee to periodically review the temporary record while the student is still enrolled and destroy information that has become misleading, outdated or irrelevant. That is a continuous obligation, not a once-a-decade event, and it comes with its own notice requirement covered below.
Special education records answer to a second set of rules
Special education files sit under both Massachusetts regulation and federal IDEA requirements, which is why so many districts publish a formal destruction notice in the local paper each year. If you have ever seen a “Notice of Destruction of Special Education Records” in the Waltham or Billerica papers, that is the process running correctly.
Under 34 CFR 300.624, a district must inform parents when personally identifiable information collected or maintained under IDEA is no longer needed to provide educational services to the child. At that point the parent may request destruction, and the district destroys the information on request. Two details matter here and both surprise people.
First, the decision about when information is no longer needed belongs to the district, not the parent. Parents cannot force the clock. Second, the federal rule lets a district keep a permanent record of a student’s name, address, phone number, grades, attendance record, classes attended, grade level completed and year completed without any time limitation. That permanent core lines up neatly with the Massachusetts transcript, which is convenient: destroy the special education temporary material, keep the transcript, and both frameworks are satisfied.
IDEA also defines destruction in a specific way. It means physical destruction, or removal of personal identifiers so the information is no longer personally identifiable. A box sitting in a locked room is not destroyed. A file marked “inactive” in a cabinet is not destroyed. The regulation is describing an end state, and only two things reach it: real physical destruction, or full de-identification.
The parent notice step districts skip most often
Massachusetts does not let a district quietly shred and move on. 603 CMR 23.06 requires written notice to the eligible student and the parent of the approximate date of destruction, along with notice of their right to receive the information in whole or in part. That notice is supposed to go out at the time of transfer, graduation or withdrawal, seven years ahead of the destruction date.
In practice that means the notice belongs in the exit packet. Put it with the graduation paperwork and the withdrawal form, log that it went out, and the district has documented compliance seven years before anyone touches a shredder. Districts that wait until purge day and then try to notify hundreds of families who moved away years ago create a problem they did not need to have.
The periodic in-enrollment review carries a parallel requirement. Before destroying outdated material from an enrolled student’s temporary record, the district notifies the student and parent in writing and gives them the chance to receive the information or a copy first.
There is also a federal hold that overrides any schedule. Under 34 CFR 99.10, a school cannot destroy education records while a request to inspect and review them is outstanding. If a parent has an open records request, that student’s file freezes until the request is resolved, even if the calendar says the file is due. Build that check into your purge process. We ask every school client to confirm no active requests exist on the boxes they hand us, and we note that confirmation on the paperwork.
The method of destruction is regulated too
Retention rules tell a district when a file becomes eligible. A separate body of Massachusetts law tells the district how the destruction has to happen, and schools are squarely covered by it.
Massachusetts General Laws chapter 93I governs disposal of records containing personal information. Paper has to be redacted, burned, pulverized or shredded so that the personal information cannot practicably be read or reconstructed. The statute reaches agencies as well as businesses, which puts public districts, charter schools, private schools and preschools all inside it. Enforcement runs through the Attorney General, with a civil fine of up to $100 per data subject affected and up to $50,000 for each instance of improper disposal. Run that math against a single box holding 200 student files and the exposure gets real fast.
The companion regulation, 201 CMR 17.00, sets the standards for protecting personal information about Massachusetts residents and applies to paper and electronic records alike. It calls for destruction when the information is no longer needed, using methods that prevent reconstruction. Student files hold exactly the data these rules were written for: full names, dates of birth, home addresses, parent financial information on free and reduced lunch applications, and in older files, Social Security numbers that were routinely collected decades ago.
Those older files are the real risk. A 1998 enrollment form with a student Social Security number belongs to someone who is now in their thirties, whose credit file is wide open, and who has no idea a school basement still holds the number.
Things that look like destruction and are not
We get called after all of these. None of them satisfy 93I, and none of them produce anything a district can show an auditor.
The recycling dumpster. Whole files in a mixed paper container are readable at every stop between the loading dock and the mill. This is the single most common failure we see in school purges, usually driven by a facilities crew told to clear a room by Friday.
The office shredder. A strip-cut machine in the main office handles the daily mail. It does not handle sixty boxes. Districts that try burn out the motor by box four, and the half-finished pile then sits in a hallway for months with the riskiest paper still readable.
The “just move it” solution. Relocating boxes from the basement to a storage unit resets nothing. The retention clock already expired. Now the personal information sits in a facility with less control than the school had.
Destruction with no paperwork. Even a legitimate shredding job leaves a district exposed if nobody documented it. Without a Certificate of Destruction, there is no evidence of what was destroyed, when, by whom or under what method. Seven years later, when a former student asks why their file is gone or an auditor asks whether the district follows its own retention policy, the answer needs to be a document rather than a memory.
How a school purge actually runs
The districts that handle this well treat it as an annual calendar item rather than an emergency. Here is the sequence we walk school business managers through.
Step one, inventory by exit year. Sort storage by the year students left, not by the year documents were created. Anything with an exit year seven or more years back is eligible. In September 2026 that means classes that left in 2019 and earlier.
Step two, pull the transcripts. Before a single box leaves the building, the transcript for every student in those boxes has to be confirmed as retained, whether on paper or in the student information system. The sixty-year obligation survives the purge. Most districts have transcripts digitized by now, which makes this a verification step rather than a sorting job.
Step three, clear the holds. Check for outstanding inspection requests, active special education disputes, open litigation and anything under a legal hold. Those files come out of the purge and go back into storage with a note.
Step four, confirm notice. Verify the destruction notices went out at exit, and for special education files, that the IDEA notice ran. Districts that publish the annual newspaper notice usually schedule destruction thirty days after publication.
Step five, destroy with documentation. Boxes go to shredding, and a Certificate of Destruction comes back listing the job date, volume and method. That Certificate is what closes the loop. We issue one on every job, and we recommend districts file it with the retention policy rather than in a drawer.
For most schools, steps one through four are a week of clerical work and step five is a single afternoon.
What it costs a Massachusetts school
School budgets are public and tight, so here are our actual numbers rather than a quote form. Everything below is also on our published rates page.
Drop-off at our Tewksbury plant runs 99 cents per pound with no minimum. A standard banker’s box of records weighs roughly 30 pounds, so a box lands around $30. Every job adds a $14.95 HIPAA handling fee and a $19.95 environmental fee, and both are flat per job rather than per box. A small private school clearing eight boxes is looking at somewhere near $275 all in.
Our address is 1215 Main Street, Unit 115 in Tewksbury, open Monday through Friday from 10 AM to 1 PM and again from 2 PM to 6 PM. Districts in Andover, Wilmington, Billerica and Lowell are close enough that a facilities van makes the trip in under half an hour.
For volume that will not fit in a van, off-site pickup adds $129 for transport anywhere in our service area, which covers Boston, Lowell, Lawrence, Andover, Tewksbury, Burlington, Wilmington, Waltham, Newton, Lexington, Methuen, Haverhill, Billerica and Fitchburg. Our crew loads the boxes, gives you documented chain of custody and returns the Certificate. For a sixty-box basement, this is the practical option.
Old backup drives, retired student information system servers and archived media get handled separately under hard drive destruction at $9 per drive with a $79 minimum, on a separate certificate. Districts replacing servers should bundle the drives with the paper purge rather than letting them sit in an IT closet, because a decommissioned drive holds far more student data per pound than any box of files.
Schools that want to watch it happen are welcome to. Witnessed shredding at our viewing window is included at no extra charge on drop-off jobs, and business managers who need to sign an attestation for the school committee often send someone to stand there while the boxes go in.
Private schools, charters and preschools are not exempt
603 CMR 23.00 applies to public elementary and secondary schools in Massachusetts, and charter schools operate under it. Private and independent schools sit outside that specific regulation, which occasionally gets read as “the rules do not apply to us.” They still do, just through different doors.
Chapter 93I and 201 CMR 17.00 do not care whether an institution is public or private. Any entity holding personal information about a Massachusetts resident has to dispose of it so the information cannot be read or reconstructed. A private school in Lexington or Concord holding enrollment applications with parent financial disclosures is holding exactly the material those rules target, and it gets handled the same way as any other business document destruction job.
Preschools and daycare centers face the same reality with an added wrinkle: their files often include immunization records and health information, which pushes some of that paper into medical territory. We handle those under our HIPAA protocol, with the same documented destruction we use for clinics and dental offices across the region.
Colleges and universities carry FERPA obligations plus their own institutional retention schedules, and the volume is different by an order of magnitude. Those jobs usually run as scheduled service with locked consoles in the registrar and financial aid offices rather than as an annual purge.
Questions school business managers ask us
How long does Massachusetts require schools to keep student records?
Can a school destroy student records early?
What is the annual special education records destruction notice about?
Does a parent records request stop a scheduled destruction?
Is putting old student files in the recycling dumpster legal?
What does a school purge cost?
Do private schools and preschools have to follow these rules?
What paperwork should a district keep after destruction?
Can someone from the school watch the records get destroyed?
Get the storage room back before the school year gets busy
September is the right month to schedule this. The building is staffed, the boxes are accessible, and the work is clerical rather than urgent. By November nobody has time, and by June everyone is packing.
If you have a room full of boxes and no idea where the seven-year line falls, call us. We have run purges for districts, private schools and preschools across metro Boston since 2007, we are family owned out of Tewksbury, and 87 verified reviews average 4.9 stars. Reach a real person at (978) 636-0301 and we will walk your inventory with you before anything is scheduled. Drop-off at 1215 Main Street, Unit 115 runs Monday through Friday, 10 AM to 1 PM and 2 PM to 6 PM, and pickup covers the rest of the region.
Related reading: Annual document purge service · What a Certificate of Destruction proves · Why chain of custody matters
