Records Retention Policy

Policy number: 1.25

Policy section: Institutional Affairs

Revised Date:

1.  Definitions

Definitions of capitalized terms used herein are set forth in Appendix A.

2.  Policy Statement

University records are the property of the University and not of the faculty, staff, students, volunteers, contractors, or other individuals who created them or maintain them. It is the policy of 91��Ƭ�S�ϼ� (the “University”) to require faculty and staff to adhere to University-wide policies and procedures for records retention and disposal. This policy includes instructions for access, preservation, retention, and destruction of University records.

3.  Purpose

The purpose of this policy is to ensure that the University complies with all relevant legal and regulatory requirements, reduces the costs of retaining records, efficiently utilizes physical and electronic storage spaces, protects confidential information, disposes of inactive records, and preserves the history of the University.

4.  Applicability

All faculty and staff are expected to comply with this policy in the creation, preservation, use, and disposal of University records. University records include any form of recorded information, whether physical or electronic, that is relevant to official University business or legal matters.

5.  Roles and Responsibilities

1. Records Coordinator
   1. Function as a liaison between his/her office and University Archives;
   2. Review his/her office’s compliance with this policy and adherence to the outlined procedures;
   3. Set his/her office’s Retention Schedules in conjunction with the Office of Legal Affairs; and
   4. Review and update his/her office’s Retention Schedules on an as needed basis.
2. University Archives
   1. Provide recommendations for maintaining paper or electronic University records of enduring value throughout their life cycle, whether active, inactive, or archival;
   2. Categorize University records and preserves archival records; and
   3. Allow or prohibit access to certain archival records.
3. Office of Legal Affairs
   1. Approve general Retention Schedules and Retention Schedules for specific offices in consultation with the office’s Records Coordinators; and
   2. Order holds on certain records and approve exceptions to Retention Schedules.
4. Office of Information Technology
   1. Provide recommendations for maintaining electronic University records throughout their life cycle, whether active, inactive, or archival; and
   2. Maintain storage systems for electronic records, provide restricted access to electronic records, implement a disaster recovery plan, and ensure timely disposition of records on University electronic systems.

6. Retention Schedule

Retention Schedules mandate the period of time a certain record should be kept, which office is responsible for the record, and whether the record can ultimately be destroyed or permanently retained in the department or transferred to the University Archives. In consultation with the Office of Legal Affairs, the Records Coordinator for each office will establish a Retention Schedule in compliance with relevant legal and regulatory requirements.

7.  Procedures

The Records Coordinator within each office or department must:

1. Designate the appropriate University records within his/her office’s responsibility
2. Implement the office’s record retention procedures
3. Review his/her office’s procedures for compliance with this policy
4. Inform staff within his/her office of record retention procedures and best practices
5. Preserve Inactive Records of archival value or historic significance
6. Transfer archival and historical records to University Archives and keep note of time of transfer
7. Restrict access to confidential information and records containing Personal Information consistent with University policies
8. Dispose of Inactive Records with no archival or historical value according to the time set on the Retention Schedule
9. Consult with University Archives as necessary and appropriate

8.  Storage Standards

1. Physical Records Storage
   Physical records stored in boxes or filing cabinets must have the appropriate space, security, accessibility, and damage prevention measures in place. Boxes and filing cabinets must be clearly labeled with a description or easy-to-understand code so that records can be easily accessed.
   
   A third-party storage facility can be used only if the storage facility’s standards are consistent with the office’s records retention procedures and legal requirements. Any office contracting with a third party must convey the University’s record retention policies and procedures and ensure that the third party’s privacy and security obligations are enforceable by contract.
2. Electronic Records Storage
   Each office must appropriately organize electronic records and maintain a backup system for University electronic records. The backup will be saved during the records’ retention periods in case of human error or failures in hardware or software. Most University systems, whether on-premise or in the cloud, already provide a means to organize records and are backed up regularly. Contact the Office of Information Technology for additional information or assistance on secure electronic data storage.
   
   Before creating and implementing an electronic storage system for records containing confidential information outside of University-provided systems, an office must provide a written description of the confidential information and a copy of all proposed contracts or projects to Office of Information Technology and receive written permission to store such information.

9.  Record Destruction

Once a record is no longer required to be retained under this policy and the relevant Retention Schedule and is inactive, it should be disposed of or destroyed.

1. Physical Records Destruction
   1. Dispose of all non-confidential physical records as standard waste
   2. Shred or otherwise render unreadable confidential physical records
2. Electronic Records Destruction

1. Use simple file or email delete to dispose of non-confidential electronic records.
2. Confidential electronic records stored on University systems, file servers, desktop computers or CDs must be disposed securely. To securely dispose of these records, overwrite the record or physically destroy the media on which it is stored. Contact the Office of Information Technology for additional information or assistance on secure electronic data disposal.

10. Litigation Holds

If an office or department is informed by the Office of Legal Affairs that any records, whether physical or electronic, under their control are potentially relevant to actual, potential, and threatened litigation, those records must be secured and preserved until the Office of Legal Affairs directs them to continue to follow their office’s Retention Schedule. Actual, potential, and threatened litigation places important obligations on the University to maintain certain records.

11. Email

Emails stored on University servers are considered Non-Essential Records and will be deleted according to direction from the Office of Information Technology and not the relevant Retention Schedule. If an email is classified as an official University record, such email must be maintained in either hard copy or electronic format in compliance with Section 8 of this policy. If emails are subject to a litigation hold, all relevant emails should be promptly preserved as directed by the Office of Legal Affairs.

12. Reporting Violations

If any member of the faculty or staff has reason to believe that any other faculty, staff, contractor, or other individual is destroying records or conducting other activities in violation of this policy, he/she should immediately report the suspected violation to his/her supervisor or to the ethics hotline.

13. Related Policies

Policy 8.6 Institutional Data Governance established principles outlining the management, access, and use of data including creation, privacy, security, integrity, confidentiality, and quality.  Policy 8.2 Information Security promotes effective administrative, technical, and physical safeguards for the protection of Personally Identifiable Information and University Data maintained by the University on the University’s Resources.

Appendix A: Definitions

“Active Record” means an original University record currently in use by the office, department, or other area of the university that created it. Records remain active for differing periods of time, depending on the purpose for which they are used.

“Archival Record” means an original University record that has historical or permanent value, is inactive, and can be retained either in the office in which it was created or in the University Archives.

“Confidential Information” means any information that is mandated by contract, law, ethical guidelines, or data owner requirements to be limited to controlled access, or any information that could be used inappropriately or disclosed and could cause substantial harm to individuals or the University.

“Electronic Record” means a University record that is not physical and is maintained in an electronic format.

“Inactive Record” means an original University record that is not considered an active record but required to be preserved pursuant to the Record Retention Schedule.

“Non-Essential Record” means a record created exclusively for convenience or use of individuals or office administrators with no ongoing operational or documentary value. A Non- Essential Record includes duplicate copies, drafts, notes for individual use, and personal correspondence.

“Official Repository” means the office or department designated as having responsibility for maintenance and timely disposal of particular categories of official University records.

“Records Coordinator” means the responsible officer with the authority to oversee the management, storage, and destruction of records of an individual office of the University.

“Retention Schedule” means a document that categorizes and describes the University’s records as a series and provides directions for the period of time a series must be kept and their required method of disposal.

“University Record” means the official or original version of any record, whether Active, Inactive, or Archival, in whatever media under the control of the Records Coordinator according to the relevant Retention Schedule, excluding duplicates and Non-Essential Records.

Adopted: February 10, 2025