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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: January 2020
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.

For guidance on the storage of credit card cardholder data, the University departments and employees should refer to Policy 1510, Accepting and Processing Credit Cards for University Business. Cardholder data includes the primary account number (PAN), cardholder name, service code, and expiration date. Under Policy 1510, cardholder data may not be stored in any paper or electronic format. In addition, units are required to regularly (or at least quarterly) review paper and electronic records for cardholder data and securely shred or otherwise permanently delete any cardholder data located during such investigations. The Merchant Service Oversight Committee (MSOC) will also conduct quarterly audits of compliance with cardholder data storage policies.

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 for Risk Management and Resilience Planning.

Except in unusual situations approved by the Office of Legal Counsel in consultation with the Chief Financial Officer and the Assistant Vice President for Risk Management and Reslielence Planning, 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
	Credit card cardholder data	Departments and employees are prohibited from storing cardholder data in any format (see Policy 1510)
	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