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:
- electronic mail (e-mail)
- word processing documents and spreadsheets
- 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:
- Controller’s Office – all financial records, bonds records, payroll records, student billing and loan records, etc.
- IRT (Information Resources & Technology) – electronic records, etc.
- Registrar’s Office – student academic records, etc.
- Provost Office / Colleges– faculty records, etc.
- Human Resources Office – Personnel records, insurance records, etc.
- 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 | ||
| Registration records | 5 years from date of last attendance | ||
| FERPA Requests | 5 years from date of last attendance | ||
| Transcript Requests | 1 year from date of request | ||
| Academic records | Permanent | ||
| Date of Graduation and Degree Award | Permanent | ||
| Degree Audit Records | Permanent | ||
| 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 | 5 years from date of last attendance | ||
| Tuition and Fee Charges | Permanent | ||
| 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.