ADM 370 – Records Retention and Destruction Policy at McPherson College
Overview
This policy and procedure provides for the systematic review, retention and destruction of documents received or created in the transaction of McPherson College (“College”) business. The policy is designed to ensure compliance with federal and state laws and regulations.
It is the policy of the College to ensure that its records are preserved to provide documentation of the College’s history and to be retained for the periods of time necessary to satisfy the College’s business and legal obligations. The records will be disposed in accordance with an established records retention and disposition schedule. Certain records are permanent records and may never be destroyed
Each department or office on campus will be responsible for creating and maintaining a record retention and destruction policy. All departments will appoint a Records Custodian who will be responsible for implementing the policy.
Definitions
Record
A record is anything containing information reflecting College educational and business transactions regardless of format (paper, digital, photographic, recordings, etc.). Typical records include official publications, fiscal data, incoming/outgoing correspondence including email, meeting minutes, reports, student files, and employee files.
Active Records
Records that are generally referred to once a month or that are needed to support the current business activity of an office or division.
Inactive Records
Records that have not been needed for at least one year or for which the active period has passed.
Permanent Records
Also known as archival records, permanent records have historical, administrative, or research value to the College and the College will keep these records indefinitely.
Retention Schedules
An internal document describing categories of records, providing a length of time they should be kept and includes instructions. The retention schedule for McPherson College is included in this document.
Retention Period
Minimum required length of time for which a College office or department is responsible for maintaining records.
Records Destruction
The physical or electronic destruction of a record after it has become obsolete or otherwise in accordance with this policy.
Disposition of Records
The terminal treatment of records, either through destruction or permanent storage.
Records Custodian
Each college department or office will assign a records custodian who will have the responsibility for ensuring effective implementation of the policy in his or her area.
Litigation Hold
A communication issued as the result of current or anticipated litigation, audit, and government investigation or other similar matter that suspends the normal process regarding the retention and disposition of College records.
Policy Details
Paper Files
Many of the records kept by McPherson College are in hard copy form, kept in paper files. These files may include student, parent, or employee information. It is up to each department to determine what action is necessary to secure the files. This may include locked filing cabinets, fire proof filing cabinets, securing behind locked doors, or in one of the college’s vaults.
Employees are expected to exercise judgment regarding the content and purpose of a paper file in determining whether it needs to be retained as a College record, and, if so, the length of the retention period. Any questions about retention of paper files should be directed to the Records Custodian in each department or office.
Email
Email sent or received over the College’s computer system may constitute a form of College record. While not all emails are business records, all College emails are property of the College and are subject to discovery in the event of litigation against the College or any of its employees or students. Consequently, the administration has the ability and the right to view the email of all members of the College community.
Faculty and employees of the College are not obligated to retain all emails indefinitely; such a policy would clearly impose an impossible burden both on the College community and on the College’s computer network. Rather, individual employees and faculty members are expected to exercise judgment regarding the content and purpose of the email in determining whether it needs to be retained as a College record, and, if so, the length of the retention period. Any questions about retention of email should be directed to the Records Custodian in each department or office.
Electronic Documents
Information saved electronically on a college computer or network may be considered a College record. While not all electronic documents are College records, all documents stored on College computers or networks are considered College property and are subject to discovery in the event of litigation against the College or any of it’s employees or students. Consequently, the administration has the ability and the right to view the electronic files of all members of the College community.
Faculty and employees of the College are not obligated to retain all electronic documents indefinitely; such a policy would clearly impose an impossible burden both on the College community and on the College’s computer network. Rather, individual employees and faculty members are expected to exercise judgment regarding the content and purpose of the document in determining whether it needs to be retained as a College record, and, if so, the length of the retention period. Any questions about retention of electronic documents should be directed to the Records Custodian in each department or office.
Litigation Holds
Where the College has actual notice of litigation or of a government investigation or audit, or has reason to believe that such events are likely to occur, it has the obligation to take steps to preserve documents that might be implicated in such litigation or investigation. In such event, the College will take steps to identify all paper and digitally maintained files that may contain documents relevant to the case, including emails. The department head of an affected department or office will be notified and will notify members of their office to preserve such documents indefinitely. If an employee or faculty member receives such a preservation notice, it does not necessarily mean that they are involved in the litigation or investigation. Rather, it means that the evidence that the College is required to preserve may be in the employee or faculty member’s possession or control, and that the employee or faculty member has an obligation to preserve such information effective immediately. In the event of a litigation hold, all policies for the disposition of documents must be suspended with respect to those matters that are the subject of the hold. Electronic information should be preserved in its original electronic form on the media on which it is stored. Electronic information should not be transferred from the media on which it is stored to a different media for the duration of the litigation hold unless such transfer is necessary to preserve the integrity of the information for the duration of the hold, and such transfers should be made only after consultation with the IT department to preserve the integrity of the electronic data. In addition, the employee and/or faculty member that receives the notice should similarly preserve any new information that is generated that may be relevant to the litigation or investigation by saving it in a segregated file. A staff or faculty member’s failure to preserve documents after having received a preservation notice can have extremely serious consequences for the College. Accordingly, a failure to comply with a litigation hold will subject employees to discipline, up to and including termination, and will be deemed misconduct that will subject faculty members to discipline in accordance with the appropriate Handbook.
Procedures
Essential Functions of Records Custodians
Each department has the responsibility for designating a Records Custodian and ensuring that the Custodian understands and is following with the records retention requirements applicable to that particular unit. The supervisor is also required to sign off on either destruction of documents at the conclusion of their retention period.
The Records Custodian is expected to: understand the records created within the department or office; follow this policy to make decisions on retention and disposition of records and provide guidance to others who are involved in preparing records for storage; be responsible for ensuring that everyone in the office is aware of this policy; establish the level of confidentiality and security appropriate to specific types of records and help the department or office maintain and monitor confidentiality and security.
Accessibility and Safekeeping of Records
Records, especially financial records, must be easily retrievable for examination by authorized individuals, including auditors. Access to electronic records is subject to College rules regarding information security. Records Custodians should work with the IT department to ensure that electronic documents are maintained in a format that preserves accessibility.
Disposition of Records
- The Records Custodian is responsible for periodically determining which College records in their particular office or department have reached the end of their retention period and should therefore be destroyed.
- The Records Custodian is required to sign off on the destruction of documents.
- Paper records must be shredded or other arrangements must be made for the documents to be destroyed.
- The Records Custodian should consult with the IT department regarding the destruction of electronic documents.
Records Destruction
Records should be securely maintained for the period of retention either in the office or department where they were created or used. Records that may be destroyed at any time include:
- material that is not considered a “record” (see definition of record);
- duplicates of an official copy which is stored and retained by another office such as
- personnel records, financial and budget information, copies of information used in an
- employee search;
- records that have served their purpose and are no longer needed such as drafts of reports
- and notes that have been turned into meeting minutes.
When there is doubt about whether or not a record may be destroyed, the Records Custodian should review the retention schedule and/or their supervisor.
Destruction includes:
Recycling – generally appropriate for public documents of other organizations, magazines, annual reports, newsletters, announcements, and drafts of policies or other memoranda which are not confidential.
Shredding – using a cross-cut shredder for all documents that should not be read by other after they are no longer needed. This is essential for any document containing personal information, information that is student protected information under FERPA, health related information, or financial information.
Discipline:
Failure to follow this policy will subject employees to discipline up to and including termination
of employment, and will subject faculty to discipline in accordance with the Employee Handbook, except in the case of guest faculty, who are subject to discipline in accordance with the guest faculty member’s contract.
General Retention and Destruction Schedule Statement
This schedule applies to all types of records, regardless of media or format, including documents, email, photographs, audiotapes, videotapes, CDs, and DVDs. Retention periods reflect minimum time periods. Records may be retained for longer periods of time at the discretion of the custodian or as required by legal counsel. Do not destroy any records while they are subject to audit or investigation.
Records that are in storage areas such as basements or attics are often at risk of water damage or destruction and should be evaluated in light of this schedule.
McPherson College is committed to providing researchers with the material they need. However, due to the confidential nature of certain records, access to some materials may be limited. Restrictions are placed on the use of records in order to protect the rights to privacy of individuals and the institution.
Access restrictions to records are divided into three categories:
General Distribution
Records in this category are open without restriction. Records in general distribution are the publications issued to the general public at the time of their creation, such as announcements, official college publications, calendars, brochures, and committee reports. This also includes the College charter, history and description of the College, building and grounds, visiting speakers, endowed chairs and professorships, College events and commencements, degrees, honors, awards and prizes, public relations, conferences, academic programs, and graduate programs. After processing, records of this type are open immediately without restriction. Examples: Annual Report of the President, General Committee meeting minutes, photographs.
Restricted Distribution
Records in this category are restricted, but access may be granted depending on the request. Records in this category may contain personal information regarding students, parents, present or past employees. These records are stored in locked cabinets, offices or rooms, or may be stored in a database that requires a password to access. In order to access these records the requestor will need to show a legitimate need to view the information. Examples: Student Financial Aid information or Employee Compensation data.
Permission to examine does not imply the right to publish any part of a document.
General Retention and Destruction Schedule
| General Type | Description | Retention Period | Location |
| Board of Trustees Records | Meeting minutes, agenda, reports, proposals, and supporting documentation | Permanent | President’s Office |
| Articles of Incorporation | Includes the documents the College is chartered under and the by-laws | Permanent | Business Office |
| IRS Determination Letter | IRS Determination Letter | Permanent | Business Office |
| Legal Records | Documentation of legal cases involving the College | Permanent | Department Records Custodians and/or HR |
| Grievance Files | Documentation of grievances initiated by faculty and staff | Retained as long as personnel file is retained. | HR and/or Academic Affairs |
| Environmental Reports/OSHA Investigations | Investigation documentation or reports | Permanent | Facilities |
| Insurance Policies | All policies in effect on behalf of the College, students, faculty and staff | Maintain as long as active | Business Office |
| College Tax Records | Documentation of the College’s compliance with tax filing requirements | Permanent | Business Office |
| External and Internal Audit Records | Created by internal or external auditors to document their reviews, findings and recommendations | Permanent | Business Office |
| Real Property Leasing/Rental Records | Documentation of the lease and rental of property | Retain 7 years after expiration of the lease. | Department Records Custodian and/or Business Office |
| Social Security Reports and Deposits | Periodic reports of wages and social security contributions paid by the College to each employee | Retain for 7 years | Business Office |
| Unemployment Compensation Benefit Files and Reports | Documentation on eligibility of former employees for unemployment benefits and when these employees receive compensation charged against the College’s account | Retain for 5 years | HR and/or Academic Affairs |
| W-2 Listings | Documentation of salaries paid and taxes withheld for employees | Retain for 7 years | Business Office |
| Authorization/Allocation Letters | Awards of federal financial aid to the College | Permanent | Financial Aid |
| Payroll Records | Documentation of payroll, payroll deduction authorizations, garnishment records, pre-payroll reports and payroll check registers | Retain 7 years after termination | Business Office and/or HR |
| Time Sheets | Documentation of hours worked by employees | Retain for 7 years | Business Office |
| Bank Records | Transactions recorded in the College bank accounts and their reconciliation to the general ledger. | Retain 7 years after end of fiscal year | Business Office |
| Employee Benefit Plan Files | Documentation on employee enrollment in benefit plans | Retain 7 years after termination of employment. | HR |
| Staff Appraisals, Promotion, Demotion and Discharge Documentation | Records documenting periodic evaluation, work performance and employment record of College staff | Retain 7 years after employee separation from College | HR |
| Enforcement – Campus Incident Reports | Documentation of incidents that occur on campus that violate College and/or local laws and regulations. They contain case number, arrest report, incident report, date, time, complainant, address and details of the report (IAW Cleary Act) | 5 years after graduation or separation | Student Life Office |
Financial Records
| General Type | Description | Retention Period | Location |
| Financial Records – General | Budget worksheets, printouts, account books, ledger, purchase records, purchase orders, travel expense reports | 7 years following the activity. | Business Office |
| Financial Records- Debt Financing | All documents related to debt financing | Permeant | Business Office |
| Financial Documentation | Tuition and fee info, annual endowment fund reports, annual financial statements | Permeant | Business Office and/or President’s Office |
| Annuity Records | Records pertaining to the management of annuities | Permeant | Business Office |
General College Records
| General Type | Description | Retention Period | Comments |
| Academic Committee Records | Minutes, reports and other materials generated by College- wide committees including charges, substantive correspondence and work product, and reports and documents about or related to the operation of college- wide committees or other offices around the College.
|
Permanent | Academic Affairs and/or President’s Office |
| President’s Records | Records related to proposals, historical reports and notes from meetings | Permanent | President’s Office |
Student Records
| General Type | Description | Retention Period | Location |
| Student Records – Admission Files | Application records for admission to the College created for undergraduate, graduate and transfer student applicants.The files may include | Permanent Registered students. Retain 2 years: Unregistered applicants. | Admissions Office and/or Academic Records Office |
| Student Records – Registrar | Student grades, transcripts, evaluations | Permanent | Academic Records Office |
| Student Records – Graduation Lists | Lists of individuals who have successfully completed the degree requirements and have been graduated from the College | Permanent | Academic RecordsOffice |
| Student Records – Registration | Documentation of a student’s course registration and changes to registration | Retain 6 months after the transaction is completed | Academic RecordsOffice |
| Student Records – Financial Aid | Records showing evidence of providing financial aid including financial aid applications, federal student aid forms, federal tax forms, award letters and confirmations, verification records, interview records, students scholarships, fellowships and awards | 5 years after graduation or separation. | Financial Aid Office |
| Student Records – Health Services | Records include medical as well as mental health histories, clinical notes, immunization records, and related correspondence. | 5 years after graduation or separation. | Student Life Office |
| Student Records – Student Discipline | Records relating to proceedings and decisions resulting from violations of the student conduct code, honor code, or other College policies | Suspensions and expulsions retained with the student’s permanent record. All other, retained 5 years. | Student Life Office |
| Student Records – Athletic Participation | Records, including photographs, awards, etc. related to student participation in athletics | Undefined period | Database |
| Student Records – Activities and Government | Records related to student participation in special activities, student clubs, associations, and the Student Senate.
Records related to any student organization or club. |
Undefined period | Database |
| Student Records – Career Counseling Office | Records related to an individual student such as counseling notes and letters of recommendation. | 5 years after graduation or separation. | Student Life Office |
Personnel Records
| General Type | Description | Retention Period | Comments |
| Employee Recruitment |
Applications, Resumes, Position Announcements, Advertisements, Promotions, Opportunities to work overtime |
1 year from date of personnel action to which any record relates | HR and/or Business Office |
| Employee Selection | Employment Tests, Physical Exams, Training Agreements, Hiring Documents, Records regarding Promotion, Demotion, Transfer, etc
I9s (separate from official personnel file) |
1 year from date of action to which the record relates. Training Docs- 3 years from the training program completion Retained for three years after initial date of hire, or one year after the date employment ends—whichever is later.
|
HR and/or Business Office |
| Employee Compensation | Payroll records, Individual Contracts, Wage and Rate Tables, Work-Time Schedules, Child Labor Law Info, | 3 years from date of termination | HR and/or Business Office |
| Employee Compensation | Tax Withholdings | 4 years from date of filing tax return/report | HR and/or Business Office |
| Employee Benefit Plans | Plan information | Duration of plan and for at least 1 year after plans’ termination | HR and/or Business Office |
| Discrimination Charge Investigations | Internal Complaints and terminations | 1 year from termination | HR and/or Dean of Students |
| Discrimination Charge Investigations | Personnel Records concerning charges | Until final disposition of the charges | HR and/or Dean of Students |
| Discrimination Charge Investigations | Employment Records related to individual with disability | 1 year from the date the record is made or the personnel action involved is taken, whichever occurs later | HR and/or Dean of Students |
| Discrimination Charge Investigations | Personnel Record for anyone who’s employment was involuntarily terminated | 1 year from the date of the termination | HR and/or Business Office |
| Employee Leave of Absence | Payroll information, FMLA records, FMLA policies | 3 years from date the leave ended | HR and/or Business Office |
| Faculty Professional Papers | Records related to faculty teaching, curriculum, committee work, or biographical materials | Permanent | Faculty members are encouraged to contact the College Archives upon retirement because these records often have permanent value to the College. |
| Faculty Tenure and Promotion | All records related to appointment and subsequent history of individuals to join the faculty, including correspondence | Permanent | Academic Affairs Office |
Advancement Records
| General Type | Description | Retention Period | Location |
| Constituent Records | Includes personal information about alumni, donors and friends of the college. Giving history, newspaper clippings, correspondence. | Permanent | Advancement/Alumni Office |
Faculty Group Records
| General Type | Description | Retention Period | Comments |
| Faculty GroupRecords – General Office Records | Records related to theroutine daily administration of the department including memoranda, meeting minutes, correspondence, and administration of programs | Until no longer administrativelyuseful. | Stored by each faculty group |
| Course and Curriculum Records | Includes college catalogs/bulletins, course schedules, syllabi and course outlines | Permanent | Academic Affairs |
Contract Records
| General Type | Description | Retention Period | Comments |
| Grant Administration | Records related to the administration offederal and other grants, contracts, sponsored research projects, and agreements from negotiation to final performance such as grants-in-aid, state contracted services, and vendor contracts. | 7 years after final payment orcompletion of all obligations under the grant or contract and all subsequent renewals, whichever is later.
|
Business Office |
Computer Services
| General Type | Description | Retention Period | Comments |
| Technology Inventory | This record may be used to inventory equipment, software, telephones, etc. It may contain the tag number, location, serial number, price, account source, etc. | ACT = until the annual report for the fiscal year in which the item was disposed is audited. | |
| Software License Agreements | These agreements define how many users are licensed to access each software application. | Expiration | |
| Internet Access Policies/Agreement | These documents define the terms of use and access of the Internet, information technology resources, vpn access, etc. The documents are used to generate user accounts for staff, teachers and students. | ACT = retain current documents for current users. | |
| Technology Service Requests | This record is used to document problems with equipment and to generate repair tickets. It may contain the user name, a description of the problem, the location of the equipment, the date/time the request was received and resolved, etc. | FY+3 | |
| Technology Network Maps/Documents | These records are used to map and define the technology infrastructure and the wiring of phone lines. They may include security information, identification numbers, passwords, etc. | Until they are superseded. | |
| Communications | Some staff are issued 2-way radios, cell phones, pagers, etc. to facilitate communication. These files contain service contracts, employee contracts, FCC licenses, distribution lists, etc. | ACT = until the equipment is returned by the staff or disposed of. | |
| Technology Training | The information technology staff may conduct training about the use of computer software or equipment for school district employees. These files contain the curricula materials. | ACT = until course materials are superseded by a new version, or until the course is dropped entirely from the training curriculum. | |
| Security Videos | Security systems record activity that takes place in select locations. The systems may be motion activated. Videotapes are often re-used in accordance with a regular rotation cycle, unless they are needed as evidence for an incident. This series applies to both analog and digital video recordings. | Creation + 14 days | |
| Student Directories | These directories list all students attending the school. They may contain grade, classroom, student name, address, phone number, etc. | ACT = while of reference value to MC | |
| Faculty and Staff Directories | These district-wide guides are published annually, and identify the teacher’s name, school, grade, phone number, and address. | ACT = while of reference value to MC |
Facility Management Records
| General Type | Description | Retention Period | Comments |
| BlueprintsManuals
Warranties |
As-Built Construction Plans | Life of building then5yrs after final
disposition of building
|
Facilities |
| BlueprintsManuals
Warranties |
Building Plans andSpecifications
|
Life of building then5yrs after final
disposition of building
|
Facilities |
| BlueprintsManuals
Warranties |
Equipment andOperating Manuals
|
Until no longer useful | Facilities |
| BlueprintsManuals
Warranties |
Warranties | Life of the Warranty | Facilities |
| Compliance | EPA Audit and Compliance Records | Permanent | Facilities |
| InspectionTest | Annual Property Insurance Inspection | 10 Years | Facilities |
| InspectionTest | Boiler Certificates | 1 Year (shred when new cert is issued) | Facilities |
| InspectionTest | Elevator Inspection | 1 Year (shred when new cert is issued) | Facilities |
| InspectionTest | Fire Alarm and Drill Records | 3 Years | Facilities |
| InspectionTest | Fire Alarm Annual Inspection Report | Permanent | Facilities |
| InspectionTest | Fire Sprinkler System Annual Test Report | Permanent | Facilities |
| Plans andProcedures | Emergency Response Plans and Procedures | Until Superseded | Facilities |
| ReportsRecords
Files |
Asbestos RemovalRecords | Permanent | Facilities |
| ReportsRecords
Files |
Backflow PreventionReport | 10 Years | Facilities |
| ReportsRecords
Files |
Bid and CompetitiveSelection Records | Until Completion of Project | Facilities |
| ReportsRecords
Files |
Estimates and Quotes | 1 Year | Facilities |
| ReportsRecords
Files |
Capital Projects ConstructionRecords | Permanent | Facilities |
| ReportsRecords
Files |
Contracts andAgreements | 10 Years | Facilities |
| ReportsRecords
Files |
Equipment Maintenance Records | Life of the Equipment | Facilities |
| ReportsRecords
Files |
Hazardous Chemical Waste Records | Permanent | Facilities |
| ReportsRecords
Files |
Incident Report(Security) | Permanent | Facilities |
| ReportsRecords
Files |
Safety Data Sheets(SDS) | Permanent | Facilities |
| ReportsRecords
Files |
Motor Vehicle Certificate of Title | Until Vehicle is Sold | Facilities |
| ReportsRecords
Files |
Motor Vehicle Maintenance Records | Until Vehicle is Sold | Facilities |
| ReportsRecords
Files |
Packing Slips | 1 Month | Facilities |
| ReportsRecords
Files |
Project Files(General Construction) | 5 Years | Facilities |
| ReportsRecords
Files |
Property Damage Reports | Permanent | Facilities |
| ReportsRecords
Files |
Purchase Orders | 1 Year | Facilities |
| ReportsRecords
Files |
Space Utilization Report | Until Superseded | Facilities |
| ReportsRecords
Files |
Vehicle Accident Report | 3 Years After Final Disposition of Vehicle | Facilities |
| ReportsRecords
Files |
Work Orders (completed) | 3 Years | Facilities |