|
💡 |
If you're the clerk, the HR lead, or the person responsible for SB 827 training records at your agency — this article is for you. Not the officials who take the training. You. The one who has to prove it happened.
SB 827 recordkeeping sounds simple on paper: two data points per completion, five-year retention, public on request. In practice, it means tracking dozens of people across two separate training types on staggered two-year cycles, collecting certificates you didn't issue, and producing documentation for requesters you've never met. No stress. No jargon. Let's walk through it.
TABLE OF CONTENTS:
- What records does SB 827 require you to keep?
- How long you must keep them
- What to capture for each completion
- Officials who serve more than one agency
- Building the annual notification into your calendar
- When your tracking system stops working
- How to get ready for a records request
- Frequently asked questions
Key takeaways
- Capture two things per completion: date and provider. Keep certificates too.
- Retain everything for five years from the completion date, not from the end of an official's term.
- Officials who serve multiple agencies train once but provide proof to each. Your archive needs their certificate even if your agency didn't provide the training.
- Notify all covered officials about available training at least once a year, and log that you did.
- These records are public under the CPRA. Build your system to produce a certificate on demand, not after a four-day dig.
- Volume, staff turnover, and rolling six-month deadlines are what push agencies past manual tracking.
|
📌 |
What records does SB 827 require you to keep?
Two data points per completion, for every covered official, for both training types:
- The date the official completed the training
- The entity that provided it
That's the statutory minimum. If the provider issues a certificate of completion, keep a copy of that too — it's the document that ties the date and provider together in one place and gives you something to hand over when a request comes in.
This applies to both AB 1234 ethics training and SB 827 fiscal and financial training. Separate requirements, separate records, often on different completion schedules for the same official.
These records are public under the California Public Records Act. You can't withhold them on privacy grounds. Anyone can request them, and your agency has to respond.
How long you must keep them
Five years minimum, starting from the date the official finishes the training. Not from when they leave office. Not from when their term ends. From the day they completed the course.
That retention window matters because it overlaps with training cycles. An official completes ethics training in year one and doesn't retrain until year three. A records request in year four needs documentation from both completions. Five years covers that overlap with room to spare.
It also means you're holding records for officials who've already moved on, as long as that window is still open. When someone leaves, their training records don't leave with them.
What to capture for each completion
Date and provider are what the statute requires. In practice, a file that holds up over five years and survives a staff transition needs a bit more:
- Official's full name and title at time of completion
- Which training: ethics (AB 1234) or fiscal (SB 827)
- Completion date
- Training provider name
- Certificate of completion (PDF or scan)
- Training format: in-person, online, or self-study with test
- Next renewal date (two years from completion)
The last field is the one that saves you work downstream. If you capture the next renewal date at intake, you don't have to calculate it later when you're building reminder lists. Front-load the math, and it stays done.
One process note: officials are required to hand you their proof of completion, but they aren't required to keep their own permanent copies. If your process depends on someone remembering to forward a PDF weeks after finishing a course, that's where most missing records start. Build the handoff into your intake — the day they finish, not the day you notice they haven't.
Officials who serve more than one agency
They complete each training once every two years. But they have to provide proof of completion to every agency they serve — and every agency keeps its own copy.
An official who sits on your board, a water district board, and a JPA takes one ethics course and one fiscal course per cycle. Your job is to get their certificate into your own five-year archive, even though your agency didn't provide the training and has no record of scheduling it.
You can't rely on the other agency's files. If a records request lands on your desk, you need your own documentation — regardless of where the training happened.
These certificates tend to arrive as email attachments and quietly vanish. If you're tracking which officials serve multiple jurisdictions, flag them at appointment and build the certificate handoff into whatever process you already use for onboarding. Chasing them six months later is the version of this that doesn't work.
Building the annual notification into your calendar
SB 827 requires agencies to notify all covered officials about available training at least once a year. Miss the window and officials discover their deadlines after they've lapsed.
Two approaches work. Pick a fixed annual date — January works for many agencies because it gives officials most of the year to complete their training before year-end. Or tie notifications to each official's appointment anniversary, which spreads the workload but adds complexity.
Either way, the notification itself needs to do three things: tell the official which training they're due for, give them the deadline, and point them to the available options. A generic 'training reminder' email that doesn't say which training or when it's due is a notification in name only.
Track that you sent it. The statute says you must provide the information. If someone claims they weren't notified, having a sent date in your records is a simple problem to solve or a hard one, depending on whether you logged it.
When your tracking system stops working
For a small agency with a stable board — five or seven officials, low turnover, the same clerk for years — a spreadsheet and a shared drive handle this fine. You know every name on the list. You know when they're due. You file the certificates yourself.
Three things change that:
- Volume. SB 827 pulled department heads into training for the first time. An agency that was tracking seven board members may now be tracking thirty or forty people across two training types on staggered cycles.
- Turnover. Not the officials' — yours. When the clerk who built the tracking system leaves, the next person inherits a filing structure only one person understood. Records that live in someone's email or a folder labeled '2026 misc' aren't retrievable records. They're a liability.
- Rolling deadlines. New officials get six months from their first day. That means the deadline moves with every hire and every appointment. There's no single annual date to plan around.
The cost of a manual system isn't the system — it's the hours. Someone chases certificates. Someone cross-references who trained when. Someone builds the annual notification list by hand. At some headcount, those hours cost more than the alternative.
That's usually the point where agencies start looking at training management systems that timestamp completions, store certificates against each learner, and produce the date-and-provider pair the statute asks for without anyone assembling it by hand.
How to get ready for a records request
Your website posting is already live (the deadline was July 1, 2026). That means requests can arrive at any time. The question is whether you can actually produce what's asked for.
Five steps:
- Name an owner for the training archive — by title, not by person, so it survives turnover.
- Put everything in one place. Digital or physical, but one. Not scattered across email, shared drives, and someone's desk drawer.
- Tell your records custodian where it is. In writing.
- Add training records to your existing retention schedule so nothing gets swept up in a routine purge.
- Run a dry test. Have someone submit a request and see how long it takes to produce a certificate. A system that takes four days to answer a simple request is a system you want to discover before a reporter does.
→ Related guide: SB 827 Website Posting Rule: What Your Agency Must Publish
Frequently asked questions
What records must agencies keep for SB 827?
The completion date and the name of the training provider for each official, for both ethics and fiscal training. If the provider issues a certificate, keep a copy. Retain everything for at least five years.
How long do agencies have to keep SB 827 training records?
Five years from the date the official completes the training. The clock starts at completion, not at the end of their term or appointment.
Are SB 827 training records public?
Yes. They're public records under the California Public Records Act. Agencies can't withhold them on privacy grounds.
What if an official serves more than one agency?
They complete each training once every two years but must provide proof to every agency they serve. Each agency maintains its own independent records.
Do agencies have to notify officials about training?
Yes. SB 827 requires agencies to provide information on available training to all covered officials at least once a year.
What happens if training records are missing when someone asks?
You still have to respond to the records request. A gap in your documentation shows up as exactly that — a gap. There's no penalty in SB 827, but the record (or the absence of one) is public.
Do ethics and fiscal training records need to be tracked separately?
Yes. They're separate requirements with separate two-year cycles that often run on different schedules for the same official.
Need a system that handles the tracking for you?
Both Vubiz SB 827 courses timestamp completions, store certificates against each learner, and produce the records the statute asks for, without anyone assembling them by hand. Available on demand so new officials can start the day they're appointed. Get a quote today!
Sources
- SB 827 bill text, Government Code sections 53235.2 and 53238 et seq. — leginfo.legislature.ca.gov
- City of San Diego — memorandum of law MS-2026-3 — docs.sandiego.gov
- Atkinson, Andelson, Loya, Ruud and Romo — SB 827 and AB 640 — aalrr.com
- Liebert Cassidy Whitmore — SB 827 ethics and fiscal training — lcwlegal.com
- Burke, Williams and Sorensen — SB 827 expansion of mandatory training — bwslaw.com
- Walnut Valley Water District — public access to ethics and fiscal training records — wwd.ca.gov
- Best Best and Krieger — New Mandatory Trainings for Local Government Officials — bbklaw.com
