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Policy 2708: Managing University Records

Subject Area: Miscellaneous
Responsible Office: The Office of Legal Counsel
Sponsor: Vice President and General Counsel
Originally Issued: June 2009
Revised: N/A
Refer Questions To: The Office of Legal Counsel


Purpose: This policy sets forth a general framework for meeting the University’s obligations to review, retain, and destroy University records consistent with laws, regulations, and internal University recordkeeping objectives that may change from time to time. This policy is intended to supplement rather than supersede the current document retention and destruction policies of any academic or administrative department of the University. Please contact the Office of Legal Counsel if any such existing policies conflict with the guidance in this policy.

Applicability: This policy applies to all academic and administrative departments of the University and all University employees having a responsibility to maintain or destroy University records.

Scope: This policy applies to all University records, which means any documents generated, received, or maintained in connection with any operations of the University. Typically, personal documents (including e-mails) of non-employees subject to the University’s Eligibility and Acceptable Use Policy are not considered to be University records. For guidance on electronic discovery, see Financial Policy No. 2709, Electronic University Records Relevant to Pending or Anticipated Litigation.

Policy

This policy sets forth general categories of University records and provides general retention guidelines for each category. Notwithstanding these general guidelines, each academic and administrative department is responsible for: (i) identifying all laws and regulations that apply to its own recordkeeping; (ii) notifying the Office of Legal Counsel of all such laws and regulations and recommending revisions or additions to these requirements as appropriate; (iii) monitoring its own compliance; (iv) destroying documents in an appropriately secure and effective manner; and (v) documenting compliance with this policy, particularly with respect to the storage and destruction of University records.

Revisions or additions to the following requirements will be made by the Office of Legal Counsel in consultation with the Chief Financial Officer and the Assistant Vice President of the Office of Risk Management and Safety.

Except in unusual situations approved by the Office of Legal Counsel in consultation with the Chief Financial Officer and the Assistant Vice President of the Office of Risk Management and Safety, the costs of reviewing, retaining, and destroying University records pursuant to this Policy will be borne by the academic or administrative department that maintains the records at issue.

Employees who knowingly fail to comply with this Policy or any other departmental document retention and destruction policy may be subject to discipline.

Academic Program Records
Accreditation and licensing Permanent
Catalogs and course descriptions Permanent
Dissertations and terminal Master’s theses (undergraduate theses included only if prize-winning) Permanent
Degrees awarded Permanent
Accounting, Banking, Budget, Finance, and Tax Records
Annual audits, financial statements, related workpapers Permanent
Banking: accounts payable, accounts receivable, fund transfers, 1099 forms, deposit slips, check registers, electronic fund transfer records 7 years
Bank statements and reconciliations 3 years
Bond financing 7 years after payment in full
Budget reports Permanent
Expenses 7 years
Cash and credit card receipts, petty cash vouchers 3 years
Depreciation schedules Permanent
General Ledgers Permanent
Invoices 7 years
Investment and endowment records Permanent
Journal entries 7 years
Purchasing and procurement 10 years after completion
Quarterly financial management reports 3 years
Student accounts receivable Permanent
University tax returns, information returns, applications for tax-exempt status, IRS correspondence, audits Permanent
Corporate Records
Annual Reports Permanent
Articles of Incorporation, Bylaws Permanent
Board of Trustees and Board Committee policies, resolutions, minutes Permanent
Construction drawings and plans Permanent
Contracts, after performance or termination 10 years
Fixed assets Permanent
Development and Alumni Records
Alumni records Permanent
Fundraising Permanent
Gift and trust agreements and related correspondence Permanent
Employment and Benefits Records
Accident and Worker’s Compensation 5 years
Affirmative Action plan documents and reports Permanent
Employment applications 3 years
Employment and separation agreements Permanent
Grievances and complaints 7 years if finding of no cause; all others, permanent
Immigration records (e.g., I-9 forms) 3 years after separation
Insurance and benefit plans 7 years
Occupational injury or illness 5 years after separation
Payroll registers, payroll tax returns Permanent
Personnel files 10 years after separation
Evaluation, promotion, discipline, and discharge 10 years after separation
Retirement and pension plan documentation Permanent
Search committee records 5 years
Earnings, withholding, and deductions 7 years; year-end records (e.g., W-2, 1099), permanent
Tenure and promotion of faculty Permanent
Time cards 7 years
Union contracts Permanent
Unemployment taxes Permanent
Legal, Intellectual Property, Risk Management, and Safety Records
Conflict of interest (trustees, officers, senior administrators) Permanent
Contracts, after performance, termination, or expiration 10 years
Accidents, crimes, and emergencies 7 years
Environmental and hazardous materials reports, studies, and remediation Permanent
Insurance policies Permanent
Litigation judgments, settlement agreements, and consent decrees Permanent
Leases, after expiration or termination 6 years
OSHA documents 5 years
Patent, copyright, and trademark applications, maintenance costs, and royalty records Permanent
Permits, approvals, and licenses 7 years after expiration
Real estate and fixed asset records Permanent
Publications, Libraries, and Archives
Awards and published book editing files Permanent
Editing files for rejected books, marketing files, production documents, and advisory board records 7 years
Journal editorial records, advertising records, circulation files 5 years
Publication agreements and permissions to reproduce Permanent
Museums and Galleries
Accession, acquisition, appraisal records, inventories, exhibit records, insurance records, and administrative reports Permanent
Loan records 10 years after return
Research Records
Grant and contract applications for sponsored research 7 years after completion of research
Human subject and animal research Permanent
Research logs and data 7 years after completion of research
Student Records
Admissions applications 5 years from graduation or date of last attendance, 2 years if not enrolled
Academic records (transcripts are permanent) 5 years
Career advising 3 years
Discipline records 5 years from last incident, permanent if involves suspension or expulsion
Student affairs, extracurricular activities and athletics 6 years
Housing records 5 years after graduation or last attendance
Financial aid, student loan, and scholarship records 4 years after later of graduation or payoff
Disability accommodation records 7 years
Tuition and expense payment records 8 years