ORDINANCE NO. 2025-__ RECITALS WHEREAS, transparency in government requires preservation of electronic records; and WHEREAS, Microsoft 365 automatically generates audit logs that track all email access and system changes; and WHEREAS, the Town has denied public access to these logs claiming they don't exist despite Microsoft's documentation confirming automatic generation and retention; and WHEREAS, citizens have a right under the Colorado Open Records Act to access government records including audit logs; NOW, THEREFORE, BE IT ORDAINED BY THE PEOPLE OF THE TOWN OF PAONIA: SECTION 1. AUDIT LOG PRESERVATION REQUIRED The Town shall: a) Preserve all Microsoft 365 audit logs for a minimum of three (3) years b) Export audit logs monthly to permanent storage c) Maintain logs in searchable, unaltered format d) Prohibit deletion or modification of audit records SECTION 2. PUBLIC ACCESS The Town shall: a) Provide audit logs in response to CORA requests within three (3) business days b) Not claim logs are "not in custody or control" when maintained by IT providers c) Create a public portal for audit log requests d) Charge only actual costs for providing records per CORA SECTION 3. SCOPE OF LOGS Required audit logs include but are not limited to: a) MailItemsAccessed events showing email access b) Administrative actions and configuration changes c) File access and modifications d) User login and security events e) All other automatically generated Microsoft 365 audit data SECTION 4. COMPLIANCE a) Town Administrator responsible for implementation b) IT providers must be contractually required to preserve and provide logs c) Quarterly reports to Board of Trustees on audit log requests and responses d) Annual third-party audit of compliance SECTION 5. PENALTIES a) Failure to preserve logs: $1,000 per day per violation b) Failure to provide logs under CORA: $500 per day after deadline c) Intentional deletion or alteration: Immediate termination and criminal referral d) Citizens may enforce through court action with attorney fee recovery SECTION 6. EFFECTIVE DATE Immediately upon election certification.