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 Policy 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 | |