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Records Retention and Destruction Policy

Policy Statement

Bradley University requires that different types of records be retained for specific periods of time to comply with state and federal laws. Bradley University requires consistent treatment of records. Maintenance, retention, and disposal procedures for university records must be followed systematically by staff in official repositories. This policy is intended to ensure that the university meets legal standards.

Purpose

The purpose of this policy is to ensure that necessary records and documents are adequately protected and maintained and to ensure that records that are no longer needed or of no value are discarded at the appropriate time. The purpose of this policy is also to preserve University history.

Records management and retention policies apply to all records, regardless of format. In today’s environment, employees create and maintain an increasing portion of their records using computers. Electronic records must be managed alongside traditional records to ensure compliance with state and federal regulations.

Individuals responsible for the retention of records are also responsible for the destruction of records following the retention period. Records must be destroyed by shredding or other means to ensure that all sensitive or confidential material can no longer be read or interpreted.

Definitions

For the purpose of this policy, “record” shall be interpreted to mean:

any papers, books, photographs, tapes, films, recordings, or other documentary materials, or any copies thereof, regardless of physical form or characteristics, made, produced, executed, or received by any department or office of the University or by any academic or administrative staff member in connection with the transaction of University business.

The term “electronic record” means any record that is created, received, maintained or stored on University local workstations or central servers. Examples include, but are not limited to:

  1. electronic mail (e-mail)
  2. word processing documents and spreadsheets
  3. databases – all data generated via automated information systems including but not limited to student records, academic records, financial accounting records, and payroll records.

“Official records” are the records maintained by the various university units. Examples include, but are not limited to:

  1. Controller’s Office – all financial records, bonds records, payroll records, student billing and loan records, etc.
  2. IRT (Information Resources & Technology) – electronic records, etc.
  3. Registrar’s Office – student academic records, etc.
  4. Provost Office / Colleges– faculty records, etc.
  5. Human Resources Office – Personnel records, insurance records, etc.
  6. President’s Office – Board minutes, etc.

Procedures

Each department will retain a listing of major documents used and maintained by the department detailing retention and destruction timetables (schedules). These schedules should be in accordance with all state and federal requirements. In addition, each department will review annually its records and forms to determine whether retention of these records and forms is adequate and appropriate.

Records can have historical value, even when no longer of immediate administrative value. If an office has any doubt if a record should be maintained, the appropriate Vice President should be contacted.

In the event of a governmental audit, investigation, or pending litigation, record disposition may be suspended at the direction of a Vice President. When litigation against the University or its employees is filed or threatened, the law imposes a duty upon the University to preserve all documents and records that pertain to the issues. As soon as the University is made aware of pending or threatened litigation, the appropriate University Vice President will notify the appropriate University employees/departments. The litigation hold directive overrides any records retention schedule that may have otherwise called for disposal or destruction of the relevant documents. The appropriate Vice President will inform employees/departments when litigation holds are cleared. Any electronic documents such as e-mail and computer accounts will need to be immediately maintained by the appropriate departments as well as Information Resources and Technology until the hold is released. No employee or department who has been notified of a litigation hold may alter or delete any electronic records that falls within the scope of that hold. Violation of the hold may subject the individual to disciplinary action, up to and including dismissal, as well as personal liability for civil and/or criminal sanctions by the courts or law enforcement agencies.

Records retention

Record retention periods may be increased by government regulation, judicial or administrative consent order, private or governmental contract, pending litigation or audit requirements. Such modifications supersede the requirements listed in this policy.

No document list can be exhaustive. Questions regarding the retention period for any specific document or class of documents not included in these tables should be addressed to the appropriate Vice President.

Please see the attached tables for records retention.

Records Retention and Destruction Policy Tables

Type of Record Document Retention Period
Institutional and Legal Records Articles of Incorporation Permanent
  Charter Permanent
  By-Laws Permanent
  Minutes of Trustee Meetings Permanent
  Minutes of Trustee Committee Meetings Permanent
  Licenses Active
  Expired Licenses 6 years after expiration
  Deeds and Titles Permanent
  Attorney documents Permanent
  Leases Active + 6 years
  Policy statements Permanent
  Campus Crime Reports (annual) Permanent
  Campus Security Act/Student Right to Know Act Compliance Records Active + 3 years
  Federal Compliance Records Active + 3 years
  Data/Statistics on Criminal Offenses 3 years
  Contracts Active + 4 years
  Patents and Trademark Records Permanent
Application Materials for Students who enter 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
Individual Student Records Course Drop/Add Slips 5 years from date of last attendance
  Disciplinary Files Permanent Class Schedules
  5 years from date of last attendance Registration records
  5 years from date of last attendance FERPA Requests
  Life of requested record Transcript Requests
  1 year Academic records
  Permanent Date of Graduation and Degree Award
  Permanent Degree Audit Records
  5 years from date of last attendance Transfer Credit Evaluations
  5 years from date of last attendance Personal Data Forms
  5 years from date of last attendance Name Change Authorizations
  5 years from date of last attendance Disciplinary Files
  Permanent Tuition and Fee Charges
  5 years from date of last attendance  
General Student Records Grade Statistics Permanent
  Applicant Statistics Permanent
  Enrollment Statistics Permanent
  Racial/Ethnic Statistics Permanent
  Student Handbooks Permanent
  Tuition Deferment Forms 5 years from date of last attendance
  Loan Disbursement Forms 5 years from date of last attendance
  Degree Statistics Permanent
Foreign Visitors Foreign Student (I-20) (J and F) Immigration Document Forms 5 years from date of last attendance
  Foreign Scholars (J,H,O,etc.) 3 years after the last day of employment or immigration status
  F-1 and M-1 Visas 1 year following report to INS
  J-1 Visas Active + 3 years
Compliance Records HIPPAA Compliance 6 years
  Title IX Records Active + 5 years
  Title VI Records Active + 5 years
  SEVIS Registration Records Permanent
  Drug Free Schools and Communities Act Compliance Records 4 years
Financial Assistance Records Financial aid transcripts 5 years
  FAFSA Profiles 10 years
  Financial aid awards Active + 5 years
  FISAP/Supporting Documentation 3 years
  Lender's Name and Address Term of entry + 10 years
  Promissory Notes Active + Until loan is paid in full
  State/Outside Grant Scholarship Prog. 5 years
  Gift-fund Scholarships Permanent
Employment Applications and Employment Listings Job Announcements and Advertisements 2 years
  Documentation on Individuals not hired 2 years
  Individuals who are hired Active + 5 years
  Individual employee files and wage history Wage Rate Tables Active + 7 years
Payroll Records Salary or current rate of pay Active + 7 years
  Payroll Deductions Active + 7 years
  Timecards/sheets Active + 7 years
  W-2 Forms Active + 7 years
  W-4 Forms Active + 7 years
Personnel Files General files Active + 7 years  
  IPEDS Reports Active + 7 years  
  Employee manuals/ Faculty Handbook Permanent  
  Employee files/documentation Permanent  
  I-9s 3 years  
  Employment history Life  
  Medical Records Life  
  Faculty tenure/promotion Life  
  Employee Medical and Health Records Life  
  Education Assistance/Tuition Remission Life  
Federal Tax Records Form 941 Active + 7 years
  Form 990 Permanent
  Form 990-T Permanent
  IRS Determination Letter Permanent
  Form 1099s Active + 7 years
  Form W-9 Active + 7 years
  Form 1042s Active + 7 years
State Tax Records Sales and Us Tax Reports and Support Permanent
Accounts Receivable Records/ Purchasing Student billing records 7 years
  Collection records 7 years
  Requisitions and support 7 years
Property records Mortgages Permanent
  Property documents Permanent
Financial Records Balance Sheet Permanent
  General Ledgers Permanent
  Bond Compliance records Permanent
  Statement of Activities Permanent
  Endowment records Permanent
  Account Ledgers Permanent
  Auditor's reports Permanent
Institutional Publications Course Catalogs  
  Statistical Profile  
  Directories  
Facilities Records Layouts/plans Permanent
  Permits Permanent
  Maintenance Permanent
  Hazardous Records Permanent
Litigation Records All records Permanent
Internal Audit Workpapers Workpapers Permanent
Audits Financial Audits Permanent
  A-133 Audits Permanent
  Sub-recipient Audits Permanent
Personnel Benefits 403 (b) retirement plan Permanent
  Life insurance Permanent
  Disability insurance Permanent
  Health insurance Permanent
  Tuition Assistance Program  
Development Donor records Permanent
Personnel Administrative employee files As long as employed
  Faculty Records and Files As long as employed
  Support staff files As long as employed

NOTE: The adoption of this policy does not relieve or otherwise affect the pre-existing obligation of any department to maintain records relating to a matter under litigation, audit, or investigation. All such records should be preserved until the matter to which they relate has been finally resolved and University counsel has approved their disposition.

These tables are not all inclusive and are subject to change. Departments may have retention schedules which are specific to their records. These schedules should be documented and followed accordingly. The university follows the Record Retention and Disposal A Manual for College Decision Makers by Kent M. Meeks and Patricia Kussman.