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Duquesne University
September 10, 2010 Rev. June 15, 2011 Rev. April 2, 2012
Records Retention and
Disposal Policy
Duquesne University
September 10, 2010 Page 2 of 12 Rev. June 15, 2011 Rev. April 2, 2012
Institutional records retention practices are generally mandated by Federal and/or State Law. Such regulatory requirements are very specific, and it is the responsibility of all department heads to comply with these regulations as they pertain to their own areas of responsibility. In addition, department heads are responsible for the safe and secure disposal of all departmental records once they have met the statutory requirements for retention or any self-imposed extension beyond legal requirements.
1. Objective Duquesne University’s records retention and disposal objective is to have the right information available for the right individuals in the appropriate formats at the right times and in the right places provided efficiently and cost effectively for making decisions and for historical reference.
2. Purpose The purpose of this policy is to ensure that:
necessary records and documents are adequately protected and maintained,
regulatory compliance is met, and
records that are no longer needed or are of no value are effectively discarded at the appropriate time
3. Definition University records are defined as all documents, regardless of form (including e-mails and digital files), produced, received, and kept by any department, officer, or employee of the University. Records produced or received by any department or employee of the University in the transaction of University business become University property and are subject to University policy for retention/disposal, access, and publication. Records produced or received by faculty or staff in administrative and University committee service capacities are also considered University records.
4. Administration The Records Retention Committee (RRC) oversees the maintenance and administration of this policy. The RRC consists of representatives from the following offices:
VP of Management and Business - (Committee Chair)
Vice President for Legal Affairs and General Counsel
University Controller
Associate Provost/Associate Academic V.P. for Administration
Human Resources, Director
University Advancement, Director
Admissions, Director
Executive V.P. for Student Life
University Archivist
Dean (any school appointed by Provost)
University Librarian
Purchasing/Support Services, Exec. Director
Computing and Technology Services, Exec. Director
Duquesne University
September 10, 2010 Page 3 of 12 Rev. June 15, 2011 Rev. April 2, 2012
The Records Retention Committee is authorized to perform the following functions: a. identify and evaluate which records should be retained in accordance with this
policy; b. publish a retention and disposal schedule for key institutional records that is in
compliance with local, state, and federal laws; c. monitor local, state, and federal laws affecting records retention; d. annually review the records retention and disposal program; and e. oversee development of a training program for personnel responsible for record
storage, maintenance, and disposal.
Each department head is responsible for compliance with this policy and will periodically review the policy to determine any special circumstances that necessitate changes in retention periods. Requests for changes in retention periods or deviations from specified retention periods should be made to the Records Retention Committee, and may be implemented only after approval by the Records Retention Committee. Each department head will periodically review currently-used records, contracts, and forms to determine whether these records and forms are adequate, appropriate, and needed for each department’s requirements. Each department head is further responsible to periodically dispose of departmental and electronic records not specifically addressed in this policy once such records are no longer required for administration of the departments. In the event of a governmental audit, investigation, or pending litigation, record disposal may be suspended at the direction of the University’s General Counsel.
5. Applicability This policy applies to all records generated in the course of the University’s operation, including both original documents and reproductions. It also applies to records stored on computers and microforms, as well as paper records.
6. Archiving Student records, human resources, financial and legal records will not be archived by the University Archivist. Only records of historical value and publicly available records will be archived by the University Archivist. The University Archivist shall be responsible, in consultation with departments using the records, for the administration, determination of value, use, preservation, storage, and disposition of inactive and archival records. The University Archivist, through standard archival theories, practices and procedures, shall be responsible for collecting, organizing, preserving, and providing access to those records which are of enduring value. All University publications shall also be deposited in the University Archives. This includes photographs, videos/films, student publications, newsletters, announcements, or any other publication by the University.
Departments should contact the University Archivist before disposing of or transferring their inactive records that may be appropriate for University archives. A Records Transfer Form should be completed by the departmental staff when records are to be transferred to the University Archives. The Archivist may also make special requests for material that is judged to be significant for its disposition.
Duquesne University
September 10, 2010 Page 4 of 12 Rev. June 15, 2011 Rev. April 2, 2012
7. Retention Period Guidance The following has been developed from College Legal Information, Inc. and from the book titled, “Record Retention and Disposal; A Manual for College Decision Makers”, by Kent M. Weeks and Patricia Kussmann. All records not archived with the University Archivist should be destroyed in accordance with retention durations specified below and/or when they are no longer needed to support program administration.
Duquesne University
September 10, 2010 Page 5 of 12 Rev. June 15, 2011 Rev. April 2, 2012
INSTITUTIONAL RECORDS RETENTION REQUIREMENTS
LEGAL RECORDS- Retained by Legal Affairs (unless otherwise noted below)
Document Retention Period
Articles of Incorporation PERM
Charter PERM
By-Laws PERM
Minutes of Directors’ Meetings PERM
Minutes of Directors’ Committee Meetings PERM
Attorney Opinion Letters (property) ACT + 4 years
Policy Statements – retained by Human Resource Mgmt. ACT + 2 years
Patent and Trademark Records PERM
LITIGATION RECORDS- Retained by Legal Affairs
Document Retention Period
Claims ACT
Court Documents and Records ACT
Deposition Transcripts ACT
Discovery Materials ACT
Litigation Files ACT + 2
INSTITUTIONAL PUBLICATIONS – Retained by Advancement
Document Retention Period
Alumni Newsletters 3 years
Alumni Directories 3 years
Bulletins and Course Catalogs 10 years
Student Newspapers 3 years
Institutional Newspapers/Newsletters 3 years
Student Directories 5 years
Employee Directories 5 years
APPLICATION MATERIALS/ STUDENTS WHO ENROLL – Retained by Enrollment Management Services
Document Retention Period
Acceptance Letters 5 years after date of last attendance
Applications 5 years after date of last attendance
Correspondence 5 years after date of last attendance
Entrance Exams and Placement Scores 5 years after date of last attendance
Letters of Recommendation Until Admitted (Matriculated) Note: Certain unsolicited information not requested or used beyond the admission process may be returned to the applicant or destroyed. Portfolios, essays, letters of recommendation, and letters requesting additional information to complete the application are primary examples. ACT = while active, employed, or enrolled LIFE = life of affected employee PERM = permanent
Duquesne University
September 10, 2010 Page 6 of 12 Rev. June 15, 2011 Rev. April 2, 2012
INSTITUTIONAL RECORDS RETENTION REQUIREMENTS
APPLICATION MATERIALS/ ACCEPTED STUDENTS WHO DO NOT ENROLL– Retained by Enrollment Management Services
Document Retention Period
Acceptance Letters 2 years after application term
Applications 2 years after application term
Correspondence 2 years after application term
Transcripts 2 years after application term
INDIVIDUAL STUDENT RECORDS – Retained by Enrollment Management Services (unless otherwise noted below)
Document Retention Period
Course Drop/Add – retained at school level 1 year
Disciplinary Files – retained by Judicial Affairs ACT
Pass/Fail Requests - retained at school level 1 year
Class Schedules Retained in Banner system
Registration Forms - retained at school level 1 year
Transcript Requests 1 year
FERPA Requests Retained in Banner system
Academic Records PERM
Advanced Placement - retained at school level 5 years after date of last attendance
Application for Graduation PERM
Foreign Student (I-20) Forms – retained by International Affairs
5 years after date of last attendance
Date of Graduation and Degree Award PERM
Degree Audit Records - retained at school level 5 years after date of last attendance
Transfer Credit Evaluations 5 years after date of last attendance
Personal Data Forms 1 year after date of last attendance
Name Change Authorizations 5 years after date of last attendance
Tuition/Fee Charges – Retained by Controller’s Office
5 years after date of last attendance
Job Placement – retained by Career Services ACT + 5 years
Repayment History – Retained by Controller’s Office
ACT + 5 years
Student Health Records – retained by Student Health Services
7 years after date of last attendance
Request for Medical Withdraw – retained by Provost ACT
FEDERAL TAX RECORDS – Retained by Controller’s Office
Document Retention Period
Form 990 3 years
Form 990-T 3 years
ACT = while active, employed, or enrolled LIFE = life of affected employee PERM = permanent
Duquesne University
September 10, 2010 Page 7 of 12 Rev. June 15, 2011 Rev. April 2, 2012
INSTITUTIONAL RECORDS RETENTION REQUIREMENTS
FINANCIAL RECORDS- Retained by Controller’s Office
Document Retention Period
Account Ledgers ACT + 4 years
Description of Accounting System ACT
Balance Sheets ACT + 4 years
General Ledgers ACT + 4 years
Auditor’s Reports ACT + 4 years
ACCOUNTS RECEIVABLE RECORDS- Retained by Controller’s Office
Document Retention Period
Accounts Receivable 4 years
Accounts Receivable Ledgers 4 years
Receipts 4 years
Uncollected Accounts 4 years
Collection Records ACT
ACCOUNTS PAYABLE RECORDS- Retained by Controller’s Office
Document Retention Period
Invoices 4 years
Accounts Payable Ledgers 4 years
Payment/Disbursement Records 4 years
Expense Reports 4 years
Insurance Payments 4 years
Royalty Payments 4 years
CAPITAL PROPERTY RECORDS – Retained by Controller’s Office
Document Retention Period
Property Records/Inventory ACT + 4 years
Equipment Inventory ACT
Depreciation Schedules ACT + 4 years
Mortgage Records ACT + 4 years
Property Improvement Records ACT + 4 years
Sales 4 years
PURCHASING RECORDS - Retained by Controller’s Office
Document Retention Period
Purchase Orders 4 years
Procurement Card Expense Reports 4 years
ACT = while active, employed, or enrolled LIFE = life of affected employee PERM = permanent
Duquesne University
September 10, 2010 Page 8 of 12 Rev. June 15, 2011 Rev. April 2, 2012
INSTITUTIONAL RECORDS RETENTION REQUIREMENTS
EMPLOYMENT APPLICATIONS/EMPLOYMENT LISTINGS – Retained by Human Resource Management
Document Retention Period
Job Announcements and Advertisements 10 years for unique or high level positions; 5 years for all
others after close of search
Individual Applicants Who Are Not Hired:
Employment Applications 1 year after close of search
Resumes 1 year after close of search
Letters of Recommendation 1 year after close of search
Candidate evaluation forms; notes relative to search 1 year after close of search
PERSONNEL FILES – Retained by Human Resource Management
Document Retention Period
Individual Employee Files
Employment Application/Resume ACT + 6 years*
Employment References ACT + 6 years
Letters of Recommendation ACT + 6 years
Employment History ACT + 6 years*
Promotions ACT + 6 years*
Attendance Records ACT + 6 years
Employee Performance Evaluation ACT + 6 years
Transfers ACT + 6 years
Personnel Actions ACT + 6 years
Disciplinary Warnings and Actions ACT + 6 years
Layoff or Termination ACT + 6 years*
General Files
IPEDS Report 15 years
Background Investigation Results ACT + 1 year
Form I-9 3 years after date of hire or 1 year after termination, whichever is later
Expired Collective Bargaining Agreements PERM
Union Documentation PERM
Notice of Charge of Discrimination-non-faculty ACT + 6 years*
PUBLIC SAFETY RECORDS – Retained by Department of Public Safety
Document Retention Period
Campus Crime Reports (annual) PERM
Campus Crime Reports (interim) PERM
*Retired employee personnel files are kept as long as the former employee is alive + 1 year following their death.
ACT = while active, employed, or enrolled LIFE = life of affected employee PERM = permanent
Duquesne University
September 10, 2010 Page 9 of 12 Rev. June 15, 2011 Rev. April 2, 2012
INSTITUTIONAL RECORDS RETENTION REQUIREMENTS
FACULTY PERSONNEL FILES
Document Retention Period
Correspondence – retained by Provost and Dean ACT + 5 years
Course Evaluation Forms – retained by Department 3 years
Peer Review Documents – retained by Department 4 years
Tenure Records –retained by Provost ACT
Faculty Evaluation – retained by School Dean PERM
INDIVIDUAL EMPLOYEE PAYROLL RECORDS
Document Retention Period
Wage/Salary History – Retained by Human Resource Mgmt. ACT + 6 years
Salary or Current Rate of Pay – Retained by Human Resource Mgmt.
ACT + 6 years
Benefit Deductions – retained by Human Resource Management ACT + 6 years
Other Deductions – I.e. United Way, Gifts, etc. – retained by Payroll (Controller’s Office)
ACT + 6 years
Time Cards or Time Sheets – retained by individual departments Current year + 3 years
W-2 Form – retained by Payroll (Controller’s Office) 6 years
W-4 Form – retained by Payroll (Controller’s Office) 6 years
Garnishments – retained by Payroll (Controller’s Office) ACT
PENSION AND BENEFITS RECORDS – Retained by Human Resource Management
Document Retention Period
Individual Employee Files
COBRA Documentation ACT + 6 years
Benefiency Documentation ACT + 6 years
Salary Reduction Agreement Form ACT + 6 years*
General Files
Summary Plan Descriptions PERM
Open Enrollment Workbook ACT + 10 years
Defined Contribution Retirement Plan (after expiration) 6 years after termination of plan
Post Retirement Medical Plan (after expiration) ACT +6 years* (6 years after termination of plan
RESEARCH GRANT RECORDS- Retained by Controller’s Office
Document Retention Period
Research Grant Records 3 years after final report filed
Equipment Purchased with Grant Funds 3 years after disposition of equipment
Note: If a grant agreement calls for a longer record retention period than specified in this policy, the specified period in agreement must be honored
*Retired employee personnel files are kept as long as the former employee is alive + 1 year following their death. ACT = while active, employed, or enrolled LIFE = life of affected employee PERM = permanent
Duquesne University
September 10, 2010 Page 10 of 12 Rev. June 15, 2011 Rev. April 2, 2012
INSTITUTIONAL RECORDS RETENTION REQUIREMENTS
EMPLOYEE MEDICAL, HEALTH AND SAFETY RECORDS
Document Retention Period
Accident Reports –retained by Risk Management 6 years
Employee Exposure Records – retained by Environmental Health and Safety
30 years
Exposed Employee Medical Records – retained by Risk Management ACT + 30 years
Environmental Health and Safety Records – retained by Environmental Health and Safety
6 years
Employee Medical Complaints – retained by Risk Management 6 years
Employee Injury Records (Workers’ Comp Accident Report) – retained by Risk Management
PERM
FACILITIES RECORDS- Retained by Facilities Management
Document Retention Period
Building Permits ACT + 1 year
Building Plans and Specifications PERM
Office Layouts ACT
Zoning Permits ACT
Operating Permits ACT
Maintenance Records ACT
Motor Vehicle Records ACT
Air or Water Waste Emissions 3 years
Hazardous Chemical Waste Records LIFE
Laboratory Practices ACT
Miscellaneous Records
Document Retention Period
Contracts – retained by originating department ACT + 4 years
Leases – retained by originating department ACT + 6 years
Deeds and Titles – retained by Management and Business PERM
Licenses – retained by originating department ACT
Expired Licenses – retained by originating department 6 years
ACT = while active, employed, or enrolled LIFE = life of affected employee PERM = permanent
Duquesne University
September 10, 2010 Page 11 of 12 Rev. June 15, 2011 Rev. April 2, 2012
8. Email Retention and Disposal Policy *Email files and documents (both electronic and paper copies) are records within the meaning of this policy.
A. Custodians of an Email Message – Definitions
1. The custodians of an email message will be the originator and recipient if these persons are University employees. The custodians are the persons responsible for ensuring compliance with this policy.
2. Although information residing on email server hard drives is periodically backed up, this is not done for archival purposes or to meet the requirements of this policy, but as a safety measure in case of system failure or unlawful tampering. The system administrator is not the custodian of messages that may be included in such back up files. While the institution’s email servers are provided to facilitate the delivery of email and permit archiving of email messages, the responsibility for retention and archiving of an email message rests with the custodians.
3. If the custodian of email files separates employment, it is the responsibility of the relevant administrator to ensure that any email remaining on a University computer is retained or disposed of in compliance with this policy and the institution’s approved records retention and disposal schedule. The administrator should ensure that such action is taken before an email account is closed.
B. Email Retention and Disposition
1. Email should not need to be retained indefinitely. Email that is retained should
be disposed of in accordance with the University’s disposition schedule for paper records with similar content and purpose.
2. Emails of limited or transitory value should be deleted as soon as they no
longer serve an administrative purpose and no longer than the current academic semester or summer session in any case. An example of email of limited or transitory value would be intra-office memos pertaining to the scheduling of routine meetings. Retention of such messages in computers or on servers serves no purpose and takes up space.
3. Emails of lasting value should be retained by archiving or transferring them to
another medium prior to routine deletions (i.e. paper, separate data files), thus permitting email records to be purged at regular intervals. Examples of emails of lasting value would be messages containing interpretations of policy, ongoing or outstanding business or administrative issues, or current litigation.
Duquesne University
September 10, 2010 Page 12 of 12 Rev. June 15, 2011 Rev. April 2, 2012
4. Any records that are subject to audit proceedings or that relate to pending or probable litigation must be retained until the conclusion of the audit or litigation, regardless of an approved disposition schedule that would permit earlier disposition. Any record may be retained separate from e-mail servers longer than the period stated in the disposition schedule, at the discretion of the custodian.
C. Procedures for Retention of Email
1. Retention of hard copy: The custodian should print the email and store the
hard copy in the relevant subject matter file as would be done with any other hard copy communication. Printing the email permits maintenance of all the information on a particular subject matter in one central location, enhancing its historical archival value.
2. Electronic storage of email: Electronically store the email in a file on a disk or
server, so that it may be maintained and stored separate from e-mail servers according to its content definition in accordance with this Policy.
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