Brevard College Operating Policy – Record Retention and Destruction Record Retention and Destruction Policy 1) Purpose
The purpose of this Policy is to ensure that necessary records and documents of Brevard College are adequately protected and maintained and to ensure that records that are no longer needed by Brevard College or are of no value are destroyed consistently as stated in the policy. This Policy is also for the purpose of aiding employees of Brevard College in understanding their obligations in retaining electronic documents - including e-mail, Web files, text files, sound and movie files, PDF documents, and all Microsoft Office or other formatted files. The institution maintains records for various reasons, including:
To comply with all federal laws as well as state and local laws and requirements of professional accrediting bodies regarding the retention and disposition of records;
To preserve the history of the institution for future generations;
To ensure adequate documentation in the event of litigation or an administrative agency charge
2) Policy
This document represents the Brevard College’s policy regarding the retention and disposal of records and the retention and disposal of electronic documents. 3) Administration
Attached as Appendix A is a Record Retention Schedule that is approved as the initial maintenance, retention and disposal schedule for physical records of Brevard College and the retention and disposal of electronic documents. The Vice President for Business and Finance (the “Administrator”) is the officer in charge of the administration of this Policy and the implementation of processes and procedures to ensure that the Record Retention Schedule is followed. The Administrator is also authorized to: suggest modifications to Senior Staff and/or the Board of Trustees of the College from time to time to ensure that it is in compliance with local, state and federal laws and includes the appropriate document and record categories for Brevard College; monitor local, state and federal laws affecting record retention; annually review the record retention and disposal program; and monitor compliance with this Policy. The Administrator is responsible for designating an official record holder in each area of the college. The official record holder in each area will make sure that the record creator in that area complies with the institution’s retention policy for that subunit. In addition, the official record holder will make sure that records are transferred to archives and/or destroyed, as provided in each area policy. 4) Suspension of Record Disposal In Event of Litigation or Claims
In the event Brevard College is served with any subpoena or request for documents or any employee becomes aware of a governmental investigation or audit concerning Brevard College or the commencement of any litigation against or concerning Brevard College, such employee shall inform the Administrator and any further disposal of documents shall be suspended until such time as the Administrator, with the advice of counsel, determines otherwise. The Administrator shall take such steps as is necessary to promptly inform all staff of any suspension in the further disposal of documents.
Approved by the Brevard College Board of Trustees, June 29, 2009
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5) Method of Destruction (Paper Documents) In the age of identity theft and data breech reporting requirements, it is critical that records are disposed of in a manner that protects the institution, its employees and students. Unless otherwise directed, Brevard College’s method of destruction is shredding of the document. Applicability This Policy applies to all physical records generated in the course of Brevard College’s operation, including both original documents and reproductions. It also applies to the electronic documents described above. Unofficial records are not subject to this policy. Unofficial records include:
Extra copies of official records (copies of originals are not official records);
Faculty records created or received in the course of professional activities or faculty research, such as interview or survey results, databases, or manuscripts (records created or received by faculty in the course of teaching, advising, committee work or departmental, program or administration work are official records).
As identified from time to time, any other items deemed unofficial by the Administration of the College.
Key Definitions a) Official records – Official records are records that are created or received in any format in the course of
Brevard College’s business. Official records are the property of Brevard College and must be maintained, preserved, or destroyed in accordance with this policy. Official records include, but are not limited to: correspondence, minutes, memos, drawings, maps, computer data, reports, newsletters, published materials, institutional policies and procedures, financial records, purchase requisitions, journals, grant documentation, and other records pertaining to fiscal information. b) Essential records – Essential records contain information essential to re-establish or continue Brevard
College in the event of a disaster. Those include legal and financial documents determining the rights of employees, students, and the community at large. Examples include personnel records, leases and contracts, deeds and easements, patents, engineering drawings of campus buildings, constructions specifications, student records, and accounting records. Failure to Comply All employees, independent contractors, volunteers or vendors who are subject to this policy may be subject to sanctions or violations of this policy, up to and including termination of employment, cancellation of contract or removal from the institution. Changes to the Policy This policy may be modified by the Administration of the College, as needed, to ensure that it is compliant with local, state, and federal laws and includes the appropriate document and record categories for Brevard College. This Policy was approved by the Executive Committee of the Board of Trustees of Brevard College on June 29, 2009.
Approved by the Brevard College Board of Trustees, June 29, 2009
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APPENDIX A – RECORD RETENTION SCHEDULE The Record Retention Schedule is organized as follows: SECTION TOPIC A. B. C. D. E. F. G. H. I. J. K. L. M.
Accounting and Finance Contracts Corporate Records Correspondence and Internal Memoranda Information Technology Electronic Documents Grant Records Insurance Records Institutional Research Records Legal Files and Papers Miscellaneous Payroll Documents Retirement Documents and Supporting Employment Data
A.
ACCOUNTING AND FINANCE
N. O. P. Q. R. S. T. U. V. W. X.
General Personnel Records Other Academic Personnel Records Property Records Tax Records Advancement/Development Admissions Office Registrar’s Office Athletic Records Financial Aid Office Health, Counseling and Student Affairs Facility Service Records
Record Type
Retention Period
Accounts Payable ledgers and schedules
7 years
Accounts Receivable ledgers and schedules
7 years
Annual Audit Reports and Financial Statements
Permanent
Annual Audit Records, including work papers and other documents that relate to the audit
7 years after completion of audit
Annual Plans and Budgets
5 years
Bank Statements
7 years
Employee Expense Reports
7 years
Endowment and Trust Records
Life of endowment or trust
General Ledgers
Permanent
Interim Financial Statements
7 years
Notes Receivable ledgers and schedules
7 years
Purchasing records
7 years
Policy and Procedure Manuals
7 years
Investment Records
7 years after sale of investment
Credit card records
3 years
Credit card record retention and destruction: All records showing customer credit card number must be locked in a desk drawer or a file cabinet when not in immediate use by staff. Once the credit card information has been transmitted to the bank, then the credit card number will be eliminated from the document.
Approved by the Brevard College Board of Trustees, June 29, 2009
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B.
CONTRACTS Record Type Contracts and Related Correspondence (including any proposal that resulted in the contract and all other supportive documentation)
Retention Period 7 years after expiration or termination
C. CORPORATE RECORDS Record Type
Retention Period
Corporate Records (minute books, signed minutes of the Board and all committees, corporate seals, articles of incorporation, bylaws, annual corporate reports, IRS tax exemption)
Permanent
Licenses and Permits
Permanent
Documents related to self-study visit and reports, recommendations, and responses Board of Trustee agendas, minutes, and other related materials D.
10 years Permanent
CORRESPONDENCE AND INTERNAL MEMORANDA General Principle: Most correspondence and internal memoranda should be retained for the same period as the document they pertain to or support. For instance, a letter pertaining to a particular contract would be retained as long as the contract (7 years after expiration). It is recommended that records that support a particular project be kept with the project and take on the retention time of that particular project file. Correspondence or memoranda that do not pertain to documents having a prescribed retention period should generally be discarded sooner. These may be divided into two general categories: 1.
Those pertaining to routine matters and having no significant, lasting consequences may be discarded at any time within two years. Some examples include:
Routine letters and notes that require no acknowledgment or follow-up, such as notes of appreciation, congratulations, letters of transmittal, and plans for meetings. Form letters that require no follow-up. Letters of general inquiry and replies that complete a cycle of correspondence. Letters or complaints requesting specific action that have no further value after changes are made or action taken (such as name or address change). Other letters of inconsequential subject matter or that definitely close correspondence to which no further reference will be necessary. Chronological correspondence files.
Please note that copies of interoffice correspondence and documents where a copy will be in the originating department file should be read and destroyed, unless that information provides reference to or direction to other documents and must be kept for project traceability. 2.
Those pertaining to non-routine matters or having significant lasting consequences should generally be retained permanently.
Approved by the Brevard College Board of Trustees, June 29, 2009
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E. INFORMATION TECHNOLOGY
F.
Software licenses
Life of software (3 years)
Software license keys, media, manuals
Life of software
Floor plans with network, voice, CATV, jack locations
Life of building
ELECTRONIC DOCUMENTS 1.
Electronic Mail: Brevard College recommends that emails be deleted from the mail server within 30 days of receipts or transmittal All Brevard College business-related e-mail that the employee wishes to retain should be downloaded to the employee’s office computer or user directory on the O drive. Staff will not store or transfer Brevard College-related e-mail on non-work-related computers except as necessary or appropriate for Brevard College purposes. Staff will take care not to send confidential/proprietary Brevard College information to outside sources. Staff with more than 30MB in their e-mail account will be unable to send or receive messages until the size of their account is reduced. Staff will be notified by the email server when their account size approaches 30 MB. Backups performed by the IT department are not for the purpose of archiving e-mail and do not log or otherwise categorize or reference e-mail contents.
2.
Electronic Documents: PDF documents – The length of time that a PDF file should be retained should be based upon the content of the file and the category under the various sections of this policy. The employee should review documents annually and delete routine and unnecessary PDF files. PDF files the employee deems vital to the performance of his or her job may be stored on the employee’s ‘O Drive’.
3.
Web Page Files: Internet Cookies Brevard College does not automatically delete electronic files beyond the dates specified in this Policy. It is the responsibility of all staff to adhere to the guidelines specified in this policy. Each day Brevard College will run a tape backup copy of all electronic files (including email) on Brevard College’s servers, as specified in the Brevard College Disaster Recovery Plan. This backup tape is a safeguard to retrieve lost information within a one-year retrieval period should documents on the network experience problems. The tape backup copy is considered a safeguard for the record retention system of Brevard College, but is not considered an official repository of Brevard College records. All monthly and yearly tapes are stored offsite according to Brevard College’s Disaster Recovery Policy. In certain cases a document will be maintained in both paper and electronic form. In such cases the official document will be the electronic document.
Approved by the Brevard College Board of Trustees, June 29, 2009
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G.
GRANT RECORDS Generally, all (non-federal) grant records should be archived three years after the end of the grant. Otherwise, the below listed retention periods apply. All federally-funded grants programs should be archived for seven years after completion of the grant. Record Type
Retention Period
Original grant proposal
7 years after completion of grant period
Grant agreement and subsequent modifications, if applicable All requested IRS/grantee correspondence including determination letters and “no change” in exempt status letters
7 years after completion of grant period
Final grantee reports, both financial and narrative
7 years after completion of grant period
All evidence of returned grant funds
7 years after completion of grant period
All pertinent formal correspondence including opinion letters of counsel
7 years after completion of grant period
Report assessment forms
7 years after completion of grant period
Documentation relating to grantee evidence of invoices and matching or challenge grants that would support grantee compliance with the grant agreement Pre-grant inquiry forms and other documentation for expenditure responsibility grants Grantee work product produced with the grant funds H.
7 years after completion of grant period
7 years after completion of grant period 7 years after completion of grant period 7 years after completion of grant period
INSURANCE RECORDS Record Type
Retention Period
Annual Loss Summaries
10 years
Audits and Adjustments
3 years after final adjustment
Certificates Issued to Brevard College
Permanent
Claims Files (including correspondence, medical records, injury documentation, etc.)
Permanent
Group Insurance Plans – Active Employees
Until Plan is amended or terminated
Group Insurance Plans – Retirees
Permanent or until 6 years after death of last eligible participant
Inspections
3 years
Insurance Policies (including expired policies)
Permanent
Journal Entry Support Data
7 years
Loss Runs
10 years
Releases and Settlements
25 years
Approved by the Brevard College Board of Trustees, June 29, 2009
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I.
J.
K.
INSTITUTIONAL RESEARCH RECORDS Record Type
Retention Period
IPEDS surveys
10 years (available on line)
US News surveys
10 years
Academic Libraries surveys
7 years
Commercial publication surveys (Peterson’s, College Board, etc0
5 years
NCAA survey
5 years
AAUP surveys
5 years (available on line)
Other surveys and institutional research records, such as Fact Book and trend data
5 years minimum or as directed by document or review organization
LEGAL FILES AND PAPERS Record Type
Retention Period
Legal Memoranda and Opinions (including all subject matter files)
7 years after close of matter
Litigation Files
1 year after expiration of appeals or time for filing appeals
Court Orders
Permanent
Requests for Departure from Records Retention Plan
10 years
MISCELLANEOUS Record Type
Retention Period
Consultant’s Reports
2 years
Material of Historical Value (including pictures, publications)
Permanent
Policy and Procedures Manuals – Original
Current version with revision history
Policy and Procedures Manuals – Copies
Retain current version only
Annual Reports
Permanent
NOCA processing acknowledgment form- Mail Services
2 years per Privacy Act of 1974
Forwarding address of previous students
18 months
Strategic planning records
20 years (archive)
Faculty Council/Staff Council/Student government minutes
Permanent
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L.
M.
PAYROLL DOCUMENTS Record Type
Retention Period
Employee Deduction Authorizations
4 years after termination
Payroll Deductions
Termination + 7 years
W-2 and W-4 Forms
Termination + 7 years
Garnishments, Assignments, Attachments
Termination + 7 years
Labor Distribution Cost Records
7 years
Payroll Registers (gross and net)
7 years
Time Cards/Sheets
2 years
Unclaimed Wage Records
6 years
RETIREMENT DOCUMENTS AND SUPPORTING EMPLOYEE DATA General Principle: Retirement documents and supporting employee data shall be kept in such a manner that Brevard College can establish at all times whether or not any pension is payable to any person and if so the amount of such pension.
N.
Record Type
Retention Period
Retirement Records
Permanent
GENERAL PERSONNEL RECORDS Record Type
Retention Period
Commissions/Bonuses/Incentives/Awards
7 years
EEO- I /EEO-2 – Employer Information Reports
2 years after superseded or filing (whichever is longer)
Employee Earnings Records
Separation + 7 years
Employee Handbooks
1 copy kept permanently
Employee Medical Records
Separation + 6 years
Employee Personnel Records (including individual attendance records, application forms, job or status change records, performance evaluations, termination papers, withholding information, garnishments, test results, training and qualification records)
6 years after separation
Employment Contracts – Individual
7 years after separation
Employment Records – Correspondence with Employment Agencies and Advertisements for Job Openings
3 years from date of hiring decision
Faculty/Staff grievances
5 years
Job postings
Permanent
Approved by the Brevard College Board of Trustees, June 29, 2009
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O.
P.
Q.
Record Type
Retention Period
Employment Records – All Non-Hired Applicants (including all applications and resumes – whether solicited or unsolicited, prior to hiring the position applied for, results of post-offer, pre-employment physicals, results of background investigations, if any, related correspondence)
2-4 years (4 years if file contains any correspondence which might be construed as an offer)
Job Descriptions
3 years after superseded
Unemployment claims
6 years
Personnel Count Records
3 years
Payroll deduction authorization forms
3 years
Forms I-9
3 years after hiring, or 1 year after separation if later
OTHER ACADEMIC PERSONNEL RECORDS Record Type
Retention Period
Appointment Letters
6 years after separation
Resumes/Vita
Until separation (move to personnel)
Full and Part-time contracts
Until separation (move to personnel and keep permanently)
Performance evaluations
Until separation (move to personnel)
Course evaluations
Until separation (move to personnel)
Grievance proceedings
Until separation (move to personnel)
PROPERTY RECORDS Record Type
Retention Period
Correspondence, Property Deeds, Assessments, Licenses, Rights of Way
Permanent
Original Purchase/Sale/Lease Agreement
Permanent
Property Insurance Policies
Permanent
TAX RECORDS Corporate Tax records shall be kept for as long as the contents thereof may become material in the administration of federal, state, and local income, franchise, and property tax laws. Record Type
Retention Period
Tax-Exemption Documents and Related Correspondence
Permanent
IRS Rulings
Permanent
Approved by the Brevard College Board of Trustees, June 29, 2009
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R.
S.
Record Type
Retention Period
Excise Tax Records
7 years
Payroll Tax Records
7 years
Tax Bills, Receipts, Statements
7 years
Tax Returns – Income, Franchise, Property
Permanent
Tax Workpaper Packages – Originals
7 years
Sales/Use Tax Records
7 years
Annual Information Returns – Federal and State
Permanent
IRS or other Government Audit Records
Permanent
ADVANCEMENT/DEVELOPMENT Record Type
Retention Period
Records of Contributions
Permanent
Brevard College’s or other documents evidencing terms of gifts
Permanent
ADMISSIONS OFFICE Record Type
Retention Period
Administrative Records concerning office responsibilities (reports, minutes, correspondence, memorandum and other related records) important to business activities. Useless documents should be recycled or shredded.
7 years
Publications
Permanent (1 copy only)
Student Applications – rejected or not enrolled
2 years
Prior to SEVIS (1 year after completion of studies); Post SEVIS Permanent Enrolled Student Applications – transfer to Registrar’s Office Immigration Records
T.
REGISTRAR’S OFFICE Record Type Academic Action authorization (dismissal, etc.) Academic Student Advising Notes
Retention Period 5 years after graduation or date of last attendance 5 years after graduation or date of last attendance
Academic Transcript
Permanent
Administrative Records concerning office responsibilities (reports, minutes, correspondence, memorandum and other related records) important to business activities.
7 years
Approved by the Brevard College Board of Trustees, June 29, 2009
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Record Type
Retention Period
Application for admissions, advanced placement, correspondence, declaration of major, pass/fail requests, personal data, transfer credit evaluations, withdrawal authorizations,
5 years after graduation or date of last attendance
Catalog
Permanent
Class Lists – maintain within college electronic record system
Permanent
Commencement Programs
Permanent
Degree Audit
5 years after graduation or date of last attendance
Enrollment Verification
1 year after verification
FERPA: requests for formal hearings, requests for release of information, written decisions of hearing panel, waivers for rights of access, correspondence Grade Rosters – maintain within college electronic record system
U.
Permanent 1 year
Graduation Application
1 year after graduation or date of last attendance
Graduation List
Permanent
Registration and schedule adjustment forms
1 year after date submitted
Schedule of Classes
Permanent
Transcript Request
1 year after date submitted
Veterans Administration student files
3 years after graduation or date of last attendance
ATHLETIC RECORDS Record Type
Retention Period
Concession/Ticket sales
5 years
Eligibility records for verification to NCAA
5 years
Equipment files and reports
5 years
Game arrangement records
5 years
Parental consent records
7 years
Recruiting files if student matriculates Recruiting files if student does not matriculate Scores, teams statistics for each game, season and sport Approved by the Brevard College Board of Trustees, June 29, 2009
5 years Permanent 2 years Page 11 of 13
V.
W.
Team Rosters
2 years
Training Room medical and insurance records
7 years from last contact
FINANCIAL AID OFFICE Record Type
Retention Period
Copies of signed agreements required by funding agencies, such as workplace conditions, lobbying statements, etc.
Destroy when superseded or obsolete
Federal and State regulation manuals, guidebooks and memorandum issued by federal and state agencies that monitor and regulate financial aid programs
Destroy when superseded or obsolete
Prospective Students not enrolled
2 years after receipt
Rosters listing each financial aid account for students receiving aid
10 years
Original signed promissory notes and signed repayments schedules for Perkins Loans must be kept in a locked fireproof container
Until loan is paid in full or loan is assigned to the Department of Education for collection
Student files concerning financial aid awarded.
5 years after graduation or student terminates enrollment, whichever is later.
Fiscal Operations Report and Application to participate (FISAP)
3 years after submission
State Grant audit reports
7 years
HEALTH, COUNSELING AND STUDENT AFFAIRS Record Type
Retention Period
Working administrative files
Destroy when reference value ceases
Immunization Records
Permanent
Controlled drug file and drug dispensing files
3 years after release from audits
Judicial Records (general, related to fines, restitution)
7 years
Judicial Records (involving suspension or expulsion)
Permanent
OSHA incident file
50 years
Student Handbooks
5 years (archive one copy)
Individual student counseling files
10 years after termination of counseling
Discipline records involving suspension or expulsion
Permanent
Individual student health files
10 years after student leaves college
Approved by the Brevard College Board of Trustees, June 29, 2009
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X.
FACILITY SERVICE RECORDS Record Type
Retention Period
Heating Plant Reduced pressure back flow preventer test report
10 years
Existing fuel burning equipment safety test report
2 years
Annual Air Emissions report
10 years (then archive)
Annual boilers and pressure vessels report
10 years
Facilities Services Building certificate of occupancy
2 yrs from date of new certificate
Motor vehicle certificate of title
Until vehicle is sold
Material Safety Data Sheets
Useful life of item
Elevator Certification
1 year (destroy when new certificate is issued) Permanent
Campus Building Blueprints Asbestos building report survey and remediation documents Construction Manuals
Permanent Permanent
Fire alarm annual inspection reports
2 years (destroy when new certificate issued)
Annual agreement and report of building sprinkler system Smoke detector inspection affidavit
2 years (destroy when new certificate issued) 2 years (destroy when new certificate issued)
Safety and Security Safety and Security policies and statistics report
Approved by the Brevard College Board of Trustees, June 29, 2009
7 years per federal statute (archive one copy)
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