1.17 Record Retention
I. Purpose
This policy establishes the guidelines and processes for the retention and disposal of college records. The policy is intended to ensure compliance with local, state and federal laws, proper retention of records, and record disposal when no longer needed or of value to the college.
II. Scope
This policy applies to all college records as herein defined.
III. General
Definitions
Record Access: The public may access college records only by contacting the Open Records Officer and following the procedures outlined in Policy 1.26. Any staff member receiving a public request for records access should direct such requests to the Open Records Officer.
Record: A record is defined as any capture of information which documents the business activities of the college. Such information may be maintained in multiple formats including, but not limited to, paper, optical disk, network storage devices, email, photographs, tapes, recordings or other documentary material prepared by or received by an employee of the college during the conduct of official business. All records, regardless of format, are subject to the retention schedule. Nonrecords, not subject to retention requirements, may include such items as routing slips, phone messages, miscellaneous notices or memoranda, copies of widely distributed materials, rough drafts, and duplicate copies of documents retained for convenience. Whenever there is any question regarding the nature of information, it should be considered a record until determined otherwise.
Record Retention: The college maintains a record retention schedule documenting the holding period for various categories of records. This schedule utilizes the retention periods specified by regulatory agencies when applicable or a retention period specified by college administrative officials when no legal mandate exists. A master schedule is included with this policy; detailed department specific schedules are maintained on the college intranet. Compliance with the retention schedule is the responsibility of management staff in the department accountable for the records and identified as such on the retention schedule. Record management responsibility includes the provision of appropriate storage, security, and destruction, as well as periodic review and update of retention periods. Incidental copies retained in other departments are not subject to the retention schedule. For example, the Payroll department maintains the official records of the college; copies existing in originating departments are not records which must be maintained according to the schedule.
Email Retention: Email as a specific category has no defined amount of time that it should be retained. Retention of email is determined by the nature of the message. All email incoming to or outgoing from a bucks.edu address will be retained by a hosted system for a period of one year. Email retained on this system may be retrieved by authorized college staff only, in conjunction with legal discovery, open records requests, or other investigative requirements. Users may view incoming or outgoing email on their desktop for 12 months from the date of receipt. Email which the user anticipates needing beyond the 12 month retention period for personal reference or to satisfy record retention requirements may be retained indefinitely when transferred to a personal mailbox. Users may not retrieve or download personal email onto college owned computer equipment. Faculty and staff should be aware that any college email transferred to a personal email account or non-college owned computer may subject the computer or email account to legal discovery efforts during litigation.
Record Destruction: When the prescribed retention period for college records has passed, records should be properly disposed of. College records that are confidential in nature must be disposed of by rendering them illegible by shredding or another similar means. Electronic documents should be erased or otherwise rendered unreadable. Confidential records include, but are not limited to, personnel files, student academic records, protected health information and all administrative records of the college. Departments disposing of records appearing on the retention schedule or other confidential records must maintain a log documenting the nature, date, and mechanism for such disposal. Non-records should be discarded when they have outlived their usefulness as determined by the user department.
Litigation Holds: When litigation against the college or its employees is filed or threatened, the college is legally obligated to preserve all records pertinent to the issue in question. Departments must immediately notify the Office of the President if they receive notice of litigation, subpoena, audit or investigation. Immediately upon notice of potential or actual litigation, a litigation hold will be issued by college administration to the specified departments of official records. Litigation holds may also be imposed during the conduct of audits, investigations or dispute resolution. No employee who has been notified of a litigation hold may alter or delete an electronic record that falls within the scope of that hold. A litigation hold suspends all established retention schedules and dictates the retention of all related records until notice of litigation resolution is given.
Consequences of Failure to Comply with Records Retention Requirements: Failure to comply with the record retention requirements established by this policy may result in disciplinary action, up to and including dismissal, and penalties applicable by law.
| Category | Type | Examples of Records | Retention Period Range | Steward |
|---|---|---|---|---|
| Financial | Accounting | Banking, grants, tax forms, AR & property, ledgers, audit reports | 3 years – permanent | Controller |
| Financial | Payroll | Time sheets, IRS forms, salary history, wage tables | 3 years – permanent | Manager, Payroll |
| Financial | Budget/AP | AP records, budget documents, state reports | 3 years – permanent | Asst Vice President, Budget & Internal Audit |
| Financial | Purchasing | Bids, invoices, insurance, incident reports | 7 years – permanent | Director, Purchasing |
| Financial | CFO | Bond documents, contract files, construction management | 3 years – permanent | Vice President, Administrative Services & CFO |
| Institutional | Academic Affairs | Faculty personnel files, Title IX, Grants | Permanent | Provost |
| Institutional | Human Resources | Employment, recruitment, benefits, related litigation | 6 months – permanent | Executive Director, Human Resources |
| Institutional | Archives | History of college | Permanent | Director, Library |
| Institutional | Information Technology Services | Electronically stored data – email, enterprise system databases, instructional files | 3 years – permanent | Asst VP, Chief Information Technology Officer |
| Institutional | Research | Statistics: enrollment, grade, degree; IPEDs reports, surveys | 3 years – permanent | Exec. Director, Research & Assessment |
| Institutional | Trustee - Legal | Open records, ethics/conflict of interest, charter, bylaws, minutes | 3 years –permanent | President |
| Plant | Construction Documents | Building plans, blueprints, permits | Permanent | Executive Director, Physical Plant |
| Public Safety | Security | Crime reports, vehicle use, motor vehicle license verification | 1-7 years | Director, Security & Safety |
| Student | Financial | Loan records & reports, recipient records, program reports | 3 years after aid award, last attended or report submission | Director, Financial Aid |
| Student | Non-Financial | International students, military, Veterans Administration | 3-5 years | Director, Admissions |
| Student | Non-Financial | Academic records, academic actions, applications, degree audits | 1 year -permanent | Director, Records |
| Student | Non-Financial | Schedule of classes | Permanent | Director, Registration |
IV. Procedures
None
V. Approval
Board of Trustees, October 9, 2014
VI. Responsibility
President