effective 12/2017
Information Retention Policy
Contents
- Purpose
- Applicability
- Definitions and Policy Development Process
- POLICY
- Storage of Archived, Paper Records
- Destruction and Disposal Process
- Enforcement
- Information Retention/Destruction/Archival Schedule
- Financial Data (Controller’s Office)
- Payroll Data
- Human Resource Data
- Student, Academic Data
- Financial Aid Data
- Academic Personnel (Office of the Provost)
- Advancement/Alumni Data
- Contracts/Leases Data
- Grant Data (Academic Affairs, Advancement and Controller’s Office
- Facilities and Property Records
- Corporate Records
- Legal Records
- Patent and Trademarks
- Insurance Policies, Claim Information, and other Risk Management Data
- Public Safety Data
- Enforcement
- Enforcement Decision
Purpose
The College is committed to effective record retention to preserve its history, meet legal standards, optimize the use of space and computer storage, optimize the cost of record retention, and ensure that outdated and useless records are destroyed.
Applicability
This policy applies to all faculty, staff members, student employees or volunteers, as well as all any third party service provider supplying services to the College, who create, use or otherwise access or interact with any College records.
Definitions and Policy Development Process
‘Information’ for the purpose of this document, is any tangible (paper, electronic, photographic, etc.) or intangible (digital records in applications, cloud storage, shared drives etc.) records reflecting College educational and business transactions regardless of format (paper, electronic, photographic, etc.). This includes student, administrative, financial, and legal as well as other types of information collected, stored and used by the College. Unless otherwise specifically set forth in this Policy, long-term maintenance and disposition of electronic and digital records shall proceed on the same schedule as paper records.
Albright College has established that records can contain three different classes of data: Public, Restricted, and Highly Sensitive. The Administrative Data Management and Access Policy details these classifications, data stewardship, guidelines and the College’s data classification standard along with a complete list of Data Stewards.
This policy is based on information retention policies at University of Maryland, University of Iowa, University of Massachusetts, and Cornell University. Albright has also researched EDUCAUSE resources to determine best practices where they exist.
POLICY
Storage of Archived, Paper Records
All active and permanent paper records should be archived in the respective areas of operation. All existing security protocols with regards to storing and safeguarding official Albright records should be strictly adhered to. Specifically, archived, paper records should be stored in an appropriate file storage box (e.g. Bankers Box or paper box; click here for other examples) within a locked room or within a locked filing cabinet for the timeframes specified in this policy. The storage box or cabinet drawer should be clearly labeled with a short description of the records and the timeframe covered by the records, e.g. “Accounts payable records 2017-18.” Paper records should not be retained in plastic bags. A log of all stored records should be provided to the Data Trustee on an annual basis including any additions or removals via proper destruction.
Destruction and Disposal Process
When the required retention period expires, the responsible office will initiate the process for the record’s destruction and disposal. The destruction of records shall be authorized by the Data Trustee in the responsible office. All electronic records shall be destroyed in consultation with Information Technology Services and in accordance with the established data removal procedure. All paper records constituting Restricted or Highly Sensitive data records shall be destroyed by high quality shredding in consultation with the Data Trustee and Facilities Services & Operations.
Litigation Hold on Records
Information pertaining to any investigation, legal action or proceeding, litigation, audit, or program review in progress should not be destroyed even if the retention period or disposition date specified for the records has expired. In the event that litigation or an administrative agency claim is reasonably likely to occur, Albright College shall take all appropriate steps to initiate a litigation hold on all relevant records so that this information can be preserved. If you believe that an event has occurred that is reasonably likely to lead to litigation/other claim, please notify the appropriate Data Trustee and Data Steward immediately to ensure all relevant records can be preserved. Please also contact the Vice President for Administrative and Financial Services so that legal counsel can be consulted. Records that are subject to a litigation hold shall not be destroyed in accordance with the procedures discussed in this policy. As such, upon initiation of a litigation hold, these records must be immediately segregated from other records so they are protected from any routine record purges. This is especially critical for emails or other electronic documents.
Enforcement
Where identified, Data Stewards from each area, in consultation with the Data Trustee are responsible for ensuring the compliance of this policy. When Data Stewards are not identified by the Data Access Policy referenced above, the appropriate office is identified by the Information Retention Policy.
Albright College employees are responsible for understanding and complying with all College policies and procedures, including but not limited to the Administrative Data Management and Access Policy. These policies include requirements for protecting and preserving the quality, integrity and confidentiality of administrative data records, as well as logical access controls to administrative data and other Albright technology resources. Data Classification standards, as documented in the Administrative Data Management and Access Policy, must be strictly adhered to.
Information Retention/Destruction/Archival Schedule:
Financial Data (Controller’s Office)
| Type of Records | Recommended Retention |
|---|---|
| Annual Audit Reports and Financial Statements | Permanent |
| Annual Audit Records | 7 years |
| Budget Information, including Projections | 7 years |
| Accounts Receivable including Invoices | 7 years |
| Accounts Payable including Invoices | 7 years |
| Student Accounts Billing Records and Correspondence | 7 years |
| Bank Statements, Bank Reconciliations, and Deposit and Check Information | 7 years |
| General Ledgers including Journal Entries and Supporting Documentation | 7 years |
| Endowment Agreements and Related Donor Documentation | Permanent |
| Investment Transaction Records | 7 years |
| Business Correspondence | Retain 3 years, then review for need |
Payroll Data
| Type of Records | Recommended Retention |
|---|---|
| W-2, W-4 and 1099 forms | 7 years after termination |
| Time Sheets | 7 years |
| Employee Deduction Authorizations | 7 years after termination |
| Payroll Deductions | 7 years after termination |
| Labor Distribution Cost Records | 7 years |
| Payroll Registers | 7 years |
Human Resource Data
| Type of Records | Recommended Retention |
|---|---|
| Personnel | At least 3 years and up to 7 years following termination of employment or until final disposition of a charge or action (if applicable) |
| Applications, Resumes, Selection, and Hiring | At least 1 year after creation/receipt of the document or the employment decision |
| Termination | 7 years |
| Time Cards | 3 years |
| Collective Bargaining Agreements | 7 Years |
| Form I-9 | 3 years after date of hire or 1 year after date of termination, whichever is later |
| Employee Background Checks | 6 years from the date of the background check |
| Unemployment Insurance (PA) | 4 years |
| Wage and Hour Records | Recommended retention period is duration of employment plus 5 years |
| Employee Handbooks | Permanent |
| Employee Benefit Plans | Permanent |
| ERISA Plan Documents | 6 years |
| FMLA Records | 3 years |
| COBRA | Recommended 6 years from date of the record |
| Tax | At least 4 years from the date tax is due or paid |
| OSHA 300 Log (Log, annual summary, OSHA Incident Report forms) | 5 years following end of corresponding calendar year |
Student, Academic Data
| Type of Records | Recommended Retention |
|---|---|
| Academic Actions (dismissal, etc.) | 5 years from graduation or date of last attendance |
| Academic integrity code violation: (and related case files) | Permanent |
| Academic records (including narrative Evaluations, competency assessment, etc.) | Permanent |
| Change of Course documentation (Cont. Ed., Summer, Extramural Studies) | 5 years from date of enrollment |
| Change of Grade documentation | Permanent |
| Change to Student ID Number | Permanent |
| Class Lists (original) | Permanent Consent to Release Personally Identifiable |
| Information (or non-disclosure requests) | Kept until next academic year |
| Course Offerings | Permanent |
| Curriculum Change Authorizations | 5 years from graduation or date of last attendance |
| Disciplinary Records (findings of violation and related case files) | Permanent where penalty imposed is probation, suspension, or expulsion |
| Enrollment Verifications | 1 year from enrollment date |
| Grade Sheets | Permanent |
| Graduation Lists | Permanent |
| Hold or encumbrance authorization | Until released |
| Name Changes | Permanent |
| Original Grade Sheets | Permanent |
| Student Class Schedules | 1 Year from graduation or date of last attendance |
| Student Registration forms | 1 year from registration |
| Term Reports | 5-7 years depending on School |
| Transcripts | Permanen |
| Transcript Requests | 1 year from submission date |
| Transfer Credit Evaluations | 5 years from graduation |
| Veteran Administration Certifications | 5 years from graduation or date of last attendance |
| Withdrawal Authorizations/Leaves of Absence | 2 years |
| Admissions documents for Applicants who do not enroll | 2 years from date of start of application term |
| Advanced Placement Records | 5 years from date of graduation or date of last attendance |
| Letters of Recommendation | Until date of admission |
| Recruitment Materials | Until date of enrollment |
| Residency Certificates | Until date of enrollment |
| Residency Change Documents (non- Resident to Resident) | 5 years from graduation or date of last attendance |
| Student Waivers for Right of Access | Until graduation or date of last attendance |
| Transcripts (high school and other college) | 5 years from graduation or date of attendance |
| International Student Forms (visa documentation, eta.) | 5 years |
| Degree, grade, enrollment, racial/ethnic stats | Permanent |
| Schedule of Classes (institutional) | Permanent |
| State Reports | Permanent |
| Catalogs | Permanent |
| Commencement Programs | Permanent |
| Student Counseling Records | 7 Years |
| Health Center Records | 7 Years |
Student Financial Aid Data
| Type of Records | Recommended Retention |
|---|---|
| Financial Aid Records (for applicants who Do not enroll) | 3 years from application date |
| Financial Aid Records (applicants who Enroll) | 5 years from graduation date |
Academic Personnel (Office of the Provost)
| Type of Records | Recommended Retention |
|---|---|
| Academic Search Records | Same as HR |
| Annual Conflict of Interest Disclosure Statements | 3 years |
| Grievances | No cause findings: 3 years from determination; cause findings: Permanent |
| Personnel files, appointment letters, forms | Same as HR |
| Tenure or promotion dossiers | If approved, 3 years. If tenure denied, 3 years from end of term appointment |
| Trustee decisions regarding academic matters | Permanent |
Advancement /Alumni Data
| Type of Records | Recommended Retention |
|---|---|
| Alumni Records | Permanent |
| Gift and Endowment Records | Permanent for electronic records |
| Gifts of Art | Permanent |
| Original Gift Letter Agreements (signed By President and donor) | Permanent |
| Original gift letter (all others) | Permanent |
| Planned gifts (trusts, life income, Agreements, annuities) real estate gifts | Permanent |
Contracts/ Leases
| Type of Records | Recommended Retention |
|---|---|
| Contracts, leases, and related documents | 7 years |
Grant Data (Academic Affairs, Advancement and Controller’s Office)
| Type of Records | Recommended Retention |
|---|---|
| Original Grant Proposal | Permanent |
| Grant Agreement and Subsequent Modifications | 7 years after close of grant |
| All Formal Correspondence including Requested IRS-Grantee Correspondence | 7 years after close of grant |
| Final Grant Reports, both Financial and Narrative | 7 years after close of grant |
| All Matching Support Documentation | 7 years after close of grant |
Facilities and Property Records
| Type of Records | Recommended Retention |
|---|---|
| Construction | |
| As-built drawings | Life of building plus 10 years |
| Contracts and agreements | 7 years after expiration |
| Environmental Health & Safety | |
| Employee chemical or biological exposure records | Duration of employment plus 30 years |
| Employee medical records other than health insurance claim records and first aid records | Duration of employment plus 30 years |
| Material Safety Data Sheets and/or Chemical Inventory List | 30 years |
| Employee respirator medical evaluations | Duration of employment plus 30 years |
| OSHA safety training records | 3 years from date of training |
| Evacuation drill records | 5 years |
| Fire protection systems records | 5 years |
| Fume hood testing records | 3 years |
| Hazardous waste disposal manifests/reports | 3 years |
| Portable extinguisher training records | 3 years |
| Radiation dose reports | Permanent |
| Radiation safety training records | 3 years |
| Radioactive materials license & Safety Committee reports | Permanent |
| Radioactive material receiving/inventory records | 3 years |
| Real Property | |
| Documents for leases, licenses, construction Contracts, other temporary contracts <$50K | 6 years after expiration of leases or contract term |
| Property deeds, easements, licenses, rights of Way, leases, rights of first refusal, Remainder Interests, mortgages | Permanent |
| Title Insurance Policies | 10 years after disposal of property |
Corporate Records
| Type of Records | Recommended Retention |
|---|---|
| Accreditation Records | Permanent |
| Articles of Incorporation | Permanent |
| Minutes of the Board and Governing Committees | Permanent |
| Bylaws | Permanent |
| Tax Exempt Status/ IRS Determination Letter | Permanent |
| Annual Corporate Filings | Permanent |
| Certificate of Incorporation/ Corporate Records to the State | Permanent |
Legal Records
| Type of Records | Recommended Retention |
|---|---|
| Consent orders | Permanent |
| Court orders | Permanent |
| Judgments | Permanent |
| Releases | Permanent |
| Settlements | Permanent |
Patent and Trademarks
| Type of Records | Recommended Retention |
|---|---|
| Original executed invention disclosure forms | Permanent |
| Original executed United State Patent and Trademark Office assignment forms | Permanent |
| Original Letters, Patents | Permanent |
| U.S. patent/application correspondence papers | Permanent |
| U.S. patent/application filing papers | 1 year after issuance of abandonment |
| Foreign patent/application-related work papers | Permanent |
| Original registered Trademarks | Permanent |
| Trademark-related work papers | Permanent |
| Original executed licensing agreements | Permanent |
| Licensing agreement-related work papers | 7 years from expiration or termination of agreement |
| Royalty Records | Life of technology/patent or trademark plus 7 years |
Insurance Policies, Claim Information, and other Risk Management Data
| Type of Records | Recommended Retention |
|---|---|
| All Insurance Policies (liability, property, et al.) | Permanent |
| Certification of insurance, Indemnification Agreements, Hold-harmless agreements, Contracts | 7 years after expiration of agreement |
| Incident reports – injury / assault | Permanent |
| Incident reports – all other reports | 7 years after report date, unless claim develops |
| Claim Information | Permanent |
Public Safety Data
| Type of Records | Recommended Retention |
|---|---|
| Accident Reports | 7 years |
| Crime Reports | 7 years |
| Property Damage Reports | 7 years |
| Releases and Waivers | 7 years |
| Driver Credentialing | Employees = 7 years; students = 7 years from date of graduation or withdrawal date |
When the required retention period expires, the responsible office will initiate the process for the record’s destruction and disposal. The destruction of records shall be authorized by the Data Trustee in the responsible Office. All electronic records shall be destroyed in consultation with Information Technology Services. All paper records constituting Restricted or Highly Sensitive data records shall be destroyed by high quality shredding.
Information pertaining to any investigation, legal action or proceeding, litigation, audit, or program review in progress should not be destroyed even if the retention period or disposition date specified for the records has expired.
All active and permanent paper records should be archived in the respective areas of operation. All existing security protocols with regards to storing and safeguarding official Albright records should be strictly adhered to.
Enforcement
Where identified, Data Stewards from each area, in consultation with the Data Trustee are responsible for ensuring the compliance of this policy. When Data Stewards are not identified by the Data Access Policy referenced above, the appropriate office is identified by the Information Retention Policy.
Albright College employees are responsible for understanding and complying with all College policies and procedures, including but not limited to the Administrative Data Management and Access Policy. These policies include requirements for protecting and preserving the quality, integrity and confidentiality of administrative data records, as well as logical access controls to administrative data and other Albright technology resources. Data Classification standards, as documented in the Administrative Data Management and Access Policy, must be strictly adhered to.
Policy Purpose
Albright College is committed to effective information retention to preserve its history, meet legal standards, optimize the use of space and computer storage, optimize the cost of information retention, and ensure that outdated and useless records are destroyed.
APPROVALS AND REVISIONS
Approved by Cabinet, December 2017
Please follow this link for a printable copy of this policy.