Records Retention and Disposal Policy - Duquesne University€¦ · Records Retention and Disposal Policy . Duquesne University September 10, 2010 Page 2 of 12 Rev. June 15, 2011

Duquesne University

September 10, 2010 Rev. June 15, 2011 Rev. April 2, 2012

Records Retention and

Disposal Policy

Duquesne University

September 10, 2010 Page 2 of 12 Rev. June 15, 2011 Rev. April 2, 2012

Institutional records retention practices are generally mandated by Federal and/or State Law. Such regulatory requirements are very specific, and it is the responsibility of all department heads to comply with these regulations as they pertain to their own areas of responsibility. In addition, department heads are responsible for the safe and secure disposal of all departmental records once they have met the statutory requirements for retention or any self-imposed extension beyond legal requirements.

1. Objective Duquesne University’s records retention and disposal objective is to have the right information available for the right individuals in the appropriate formats at the right times and in the right places provided efficiently and cost effectively for making decisions and for historical reference.

2. Purpose The purpose of this policy is to ensure that:

necessary records and documents are adequately protected and maintained,

regulatory compliance is met, and

records that are no longer needed or are of no value are effectively discarded at the appropriate time

3. Definition University records are defined as all documents, regardless of form (including e-mails and digital files), produced, received, and kept by any department, officer, or employee of the University. Records produced or received by any department or employee of the University in the transaction of University business become University property and are subject to University policy for retention/disposal, access, and publication. Records produced or received by faculty or staff in administrative and University committee service capacities are also considered University records.

4. Administration The Records Retention Committee (RRC) oversees the maintenance and administration of this policy. The RRC consists of representatives from the following offices:

VP of Management and Business - (Committee Chair)

Vice President for Legal Affairs and General Counsel

University Controller

Associate Provost/Associate Academic V.P. for Administration

Human Resources, Director

University Advancement, Director

Admissions, Director

Executive V.P. for Student Life

University Archivist

Dean (any school appointed by Provost)

University Librarian

Purchasing/Support Services, Exec. Director

Computing and Technology Services, Exec. Director

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The Records Retention Committee is authorized to perform the following functions: a. identify and evaluate which records should be retained in accordance with this

policy; b. publish a retention and disposal schedule for key institutional records that is in

compliance with local, state, and federal laws; c. monitor local, state, and federal laws affecting records retention; d. annually review the records retention and disposal program; and e. oversee development of a training program for personnel responsible for record

storage, maintenance, and disposal.

Each department head is responsible for compliance with this policy and will periodically review the policy to determine any special circumstances that necessitate changes in retention periods. Requests for changes in retention periods or deviations from specified retention periods should be made to the Records Retention Committee, and may be implemented only after approval by the Records Retention Committee. Each department head will periodically review currently-used records, contracts, and forms to determine whether these records and forms are adequate, appropriate, and needed for each department’s requirements. Each department head is further responsible to periodically dispose of departmental and electronic records not specifically addressed in this policy once such records are no longer required for administration of the departments. In the event of a governmental audit, investigation, or pending litigation, record disposal may be suspended at the direction of the University’s General Counsel.

5. Applicability This policy applies to all records generated in the course of the University’s operation, including both original documents and reproductions. It also applies to records stored on computers and microforms, as well as paper records.

6. Archiving Student records, human resources, financial and legal records will not be archived by the University Archivist. Only records of historical value and publicly available records will be archived by the University Archivist. The University Archivist shall be responsible, in consultation with departments using the records, for the administration, determination of value, use, preservation, storage, and disposition of inactive and archival records. The University Archivist, through standard archival theories, practices and procedures, shall be responsible for collecting, organizing, preserving, and providing access to those records which are of enduring value. All University publications shall also be deposited in the University Archives. This includes photographs, videos/films, student publications, newsletters, announcements, or any other publication by the University.

Departments should contact the University Archivist before disposing of or transferring their inactive records that may be appropriate for University archives. A Records Transfer Form should be completed by the departmental staff when records are to be transferred to the University Archives. The Archivist may also make special requests for material that is judged to be significant for its disposition.

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7. Retention Period Guidance The following has been developed from College Legal Information, Inc. and from the book titled, “Record Retention and Disposal; A Manual for College Decision Makers”, by Kent M. Weeks and Patricia Kussmann. All records not archived with the University Archivist should be destroyed in accordance with retention durations specified below and/or when they are no longer needed to support program administration.

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INSTITUTIONAL RECORDS RETENTION REQUIREMENTS

LEGAL RECORDS- Retained by Legal Affairs (unless otherwise noted below)

Document Retention Period

Articles of Incorporation PERM

Charter PERM

By-Laws PERM

Minutes of Directors’ Meetings PERM

Minutes of Directors’ Committee Meetings PERM

Attorney Opinion Letters (property) ACT + 4 years

Policy Statements – retained by Human Resource Mgmt. ACT + 2 years

Patent and Trademark Records PERM

LITIGATION RECORDS- Retained by Legal Affairs


Claims ACT

Court Documents and Records ACT

Deposition Transcripts ACT

Discovery Materials ACT

Litigation Files ACT + 2

INSTITUTIONAL PUBLICATIONS – Retained by Advancement


Alumni Newsletters 3 years

Alumni Directories 3 years

Bulletins and Course Catalogs 10 years

Student Newspapers 3 years

Institutional Newspapers/Newsletters 3 years

Student Directories 5 years

Employee Directories 5 years

APPLICATION MATERIALS/ STUDENTS WHO ENROLL – Retained by Enrollment Management Services


Acceptance Letters 5 years after date of last attendance

Applications 5 years after date of last attendance

Correspondence 5 years after date of last attendance

Entrance Exams and Placement Scores 5 years after date of last attendance

Letters of Recommendation Until Admitted (Matriculated) Note: Certain unsolicited information not requested or used beyond the admission process may be returned to the applicant or destroyed. Portfolios, essays, letters of recommendation, and letters requesting additional information to complete the application are primary examples. ACT = while active, employed, or enrolled LIFE = life of affected employee PERM = permanent

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APPLICATION MATERIALS/ ACCEPTED STUDENTS WHO DO NOT ENROLL– Retained by Enrollment Management Services


Acceptance Letters 2 years after application term

Applications 2 years after application term

Correspondence 2 years after application term

Transcripts 2 years after application term

INDIVIDUAL STUDENT RECORDS – Retained by Enrollment Management Services (unless otherwise noted below)


Course Drop/Add – retained at school level 1 year

Disciplinary Files – retained by Judicial Affairs ACT

Pass/Fail Requests - retained at school level 1 year

Class Schedules Retained in Banner system

Registration Forms - retained at school level 1 year

Transcript Requests 1 year

FERPA Requests Retained in Banner system

Academic Records PERM

Advanced Placement - retained at school level 5 years after date of last attendance

Application for Graduation PERM

Foreign Student (I-20) Forms – retained by International Affairs

5 years after date of last attendance

Date of Graduation and Degree Award PERM

Degree Audit Records - retained at school level 5 years after date of last attendance

Transfer Credit Evaluations 5 years after date of last attendance

Personal Data Forms 1 year after date of last attendance

Name Change Authorizations 5 years after date of last attendance

Tuition/Fee Charges – Retained by Controller’s Office


Job Placement – retained by Career Services ACT + 5 years

Repayment History – Retained by Controller’s Office

ACT + 5 years

Student Health Records – retained by Student Health Services


Request for Medical Withdraw – retained by Provost ACT

FEDERAL TAX RECORDS – Retained by Controller’s Office


Form 990 3 years

Form 990-T 3 years

ACT = while active, employed, or enrolled LIFE = life of affected employee PERM = permanent

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FINANCIAL RECORDS- Retained by Controller’s Office


Account Ledgers ACT + 4 years

Description of Accounting System ACT

Balance Sheets ACT + 4 years

General Ledgers ACT + 4 years

Auditor’s Reports ACT + 4 years

ACCOUNTS RECEIVABLE RECORDS- Retained by Controller’s Office


Accounts Receivable 4 years

Accounts Receivable Ledgers 4 years

Receipts 4 years

Uncollected Accounts 4 years

Collection Records ACT

ACCOUNTS PAYABLE RECORDS- Retained by Controller’s Office


Invoices 4 years

Accounts Payable Ledgers 4 years

Payment/Disbursement Records 4 years

Expense Reports 4 years

Insurance Payments 4 years

Royalty Payments 4 years

CAPITAL PROPERTY RECORDS – Retained by Controller’s Office


Property Records/Inventory ACT + 4 years

Equipment Inventory ACT

Depreciation Schedules ACT + 4 years

Mortgage Records ACT + 4 years

Property Improvement Records ACT + 4 years

Sales 4 years

PURCHASING RECORDS - Retained by Controller’s Office


Purchase Orders 4 years

Procurement Card Expense Reports 4 years


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EMPLOYMENT APPLICATIONS/EMPLOYMENT LISTINGS – Retained by Human Resource Management


Job Announcements and Advertisements 10 years for unique or high level positions; 5 years for all

others after close of search

Individual Applicants Who Are Not Hired:

Employment Applications 1 year after close of search

Resumes 1 year after close of search

Letters of Recommendation 1 year after close of search

Candidate evaluation forms; notes relative to search 1 year after close of search

PERSONNEL FILES – Retained by Human Resource Management


Individual Employee Files

Employment Application/Resume ACT + 6 years*

Employment References ACT + 6 years

Letters of Recommendation ACT + 6 years

Employment History ACT + 6 years*

Promotions ACT + 6 years*

Attendance Records ACT + 6 years

Employee Performance Evaluation ACT + 6 years

Transfers ACT + 6 years

Personnel Actions ACT + 6 years

Disciplinary Warnings and Actions ACT + 6 years

Layoff or Termination ACT + 6 years*

General Files

IPEDS Report 15 years

Background Investigation Results ACT + 1 year

Form I-9 3 years after date of hire or 1 year after termination, whichever is later

Expired Collective Bargaining Agreements PERM

Union Documentation PERM

Notice of Charge of Discrimination-non-faculty ACT + 6 years*

PUBLIC SAFETY RECORDS – Retained by Department of Public Safety


Campus Crime Reports (annual) PERM

Campus Crime Reports (interim) PERM

*Retired employee personnel files are kept as long as the former employee is alive + 1 year following their death.


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FACULTY PERSONNEL FILES


Correspondence – retained by Provost and Dean ACT + 5 years

Course Evaluation Forms – retained by Department 3 years

Peer Review Documents – retained by Department 4 years

Tenure Records –retained by Provost ACT

Faculty Evaluation – retained by School Dean PERM

INDIVIDUAL EMPLOYEE PAYROLL RECORDS


Wage/Salary History – Retained by Human Resource Mgmt. ACT + 6 years

Salary or Current Rate of Pay – Retained by Human Resource Mgmt.

ACT + 6 years

Benefit Deductions – retained by Human Resource Management ACT + 6 years

Other Deductions – I.e. United Way, Gifts, etc. – retained by Payroll (Controller’s Office)

ACT + 6 years

Time Cards or Time Sheets – retained by individual departments Current year + 3 years

W-2 Form – retained by Payroll (Controller’s Office) 6 years

W-4 Form – retained by Payroll (Controller’s Office) 6 years

Garnishments – retained by Payroll (Controller’s Office) ACT

PENSION AND BENEFITS RECORDS – Retained by Human Resource Management


Individual Employee Files

COBRA Documentation ACT + 6 years

Benefiency Documentation ACT + 6 years

Salary Reduction Agreement Form ACT + 6 years*

General Files

Summary Plan Descriptions PERM

Open Enrollment Workbook ACT + 10 years

Defined Contribution Retirement Plan (after expiration) 6 years after termination of plan

Post Retirement Medical Plan (after expiration) ACT +6 years* (6 years after termination of plan

RESEARCH GRANT RECORDS- Retained by Controller’s Office


Research Grant Records 3 years after final report filed

Equipment Purchased with Grant Funds 3 years after disposition of equipment

Note: If a grant agreement calls for a longer record retention period than specified in this policy, the specified period in agreement must be honored

*Retired employee personnel files are kept as long as the former employee is alive + 1 year following their death. ACT = while active, employed, or enrolled LIFE = life of affected employee PERM = permanent

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EMPLOYEE MEDICAL, HEALTH AND SAFETY RECORDS


Accident Reports –retained by Risk Management 6 years

Employee Exposure Records – retained by Environmental Health and Safety

30 years

Exposed Employee Medical Records – retained by Risk Management ACT + 30 years

Environmental Health and Safety Records – retained by Environmental Health and Safety

6 years

Employee Medical Complaints – retained by Risk Management 6 years

Employee Injury Records (Workers’ Comp Accident Report) – retained by Risk Management

PERM

FACILITIES RECORDS- Retained by Facilities Management


Building Permits ACT + 1 year

Building Plans and Specifications PERM

Office Layouts ACT

Zoning Permits ACT

Operating Permits ACT

Maintenance Records ACT

Motor Vehicle Records ACT

Air or Water Waste Emissions 3 years

Hazardous Chemical Waste Records LIFE

Laboratory Practices ACT

Miscellaneous Records


Contracts – retained by originating department ACT + 4 years

Leases – retained by originating department ACT + 6 years

Deeds and Titles – retained by Management and Business PERM

Licenses – retained by originating department ACT

Expired Licenses – retained by originating department 6 years


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8. Email Retention and Disposal Policy *Email files and documents (both electronic and paper copies) are records within the meaning of this policy.

A. Custodians of an Email Message – Definitions

1. The custodians of an email message will be the originator and recipient if these persons are University employees. The custodians are the persons responsible for ensuring compliance with this policy.

2. Although information residing on email server hard drives is periodically backed up, this is not done for archival purposes or to meet the requirements of this policy, but as a safety measure in case of system failure or unlawful tampering. The system administrator is not the custodian of messages that may be included in such back up files. While the institution’s email servers are provided to facilitate the delivery of email and permit archiving of email messages, the responsibility for retention and archiving of an email message rests with the custodians.

3. If the custodian of email files separates employment, it is the responsibility of the relevant administrator to ensure that any email remaining on a University computer is retained or disposed of in compliance with this policy and the institution’s approved records retention and disposal schedule. The administrator should ensure that such action is taken before an email account is closed.

B. Email Retention and Disposition

1. Email should not need to be retained indefinitely. Email that is retained should

be disposed of in accordance with the University’s disposition schedule for paper records with similar content and purpose.

2. Emails of limited or transitory value should be deleted as soon as they no

longer serve an administrative purpose and no longer than the current academic semester or summer session in any case. An example of email of limited or transitory value would be intra-office memos pertaining to the scheduling of routine meetings. Retention of such messages in computers or on servers serves no purpose and takes up space.

3. Emails of lasting value should be retained by archiving or transferring them to

another medium prior to routine deletions (i.e. paper, separate data files), thus permitting email records to be purged at regular intervals. Examples of emails of lasting value would be messages containing interpretations of policy, ongoing or outstanding business or administrative issues, or current litigation.

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4. Any records that are subject to audit proceedings or that relate to pending or probable litigation must be retained until the conclusion of the audit or litigation, regardless of an approved disposition schedule that would permit earlier disposition. Any record may be retained separate from e-mail servers longer than the period stated in the disposition schedule, at the discretion of the custodian.

C. Procedures for Retention of Email

1. Retention of hard copy: The custodian should print the email and store the

hard copy in the relevant subject matter file as would be done with any other hard copy communication. Printing the email permits maintenance of all the information on a particular subject matter in one central location, enhancing its historical archival value.

2. Electronic storage of email: Electronically store the email in a file on a disk or

server, so that it may be maintained and stored separate from e-mail servers according to its content definition in accordance with this Policy.