Document Retention and Destruction Policy

Overview

This document holds the University's official policy for retention and destructionof both print and electronic documents.

Policy

1. Purpose

This policy provides for the systematic review, retention and destruction of documents received or created by Indiana Wesleyan University in connection with the transaction of institutional business. This policy covers all records and documents, regardless of physical form (including electronic documents), contains guidelines for how long certain documents should be kept and how records should be destroyed. The policy is designed to ensure compliance with federal and state laws and regulations, to eliminate accidental or innocent destruction of records and to facilitate IWU’s operations by promoting efficiency and freeing up valuable storage space.

2. Document Retention and Destruction Schedule

Attached as Appendix A is a Document Retention and Destruction Schedule that IWU approved as the initial maintenance, retention and disposal schedule for physical records and the retention and disposal of electronic records. The Vice President for Business Affairs (“Administrator”) is the officer in charge of the administration of this policy and the implementation of processes and procedures to ensure that the Document Retention and Destruction Schedule is followed. The Administrator is also authorized to:

• make modifications to the Document Retention Schedule 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 the University;
• monitor local, state and federal laws affecting record retention;
• annually review the record retention and disposal program; and
• monitor compliance with this Policy.

3. Electronic Documents and Records

Electronic Mail: Not all email needs to be retained. Length of retention depends on the subject matter.

Staff shall retain all business related emails by saving/transferring those items to archived folders no later than every six (6) months. If email chains are to be retained, only the last communication in the chain should be saved/transferred to the archive file. Business emails that should be retained include those involving completed and ongoing transactions and matters within the scope of the employee’s job responsibility. Questions regarding emails to be retained should be directed to the employee’s supervisor. Files attached to emails should be separately retained in accordance with document retention provisions of the category of this policy applicable to the document.

Emails not saved/transferred to archived folders such as personal emails, spam and duplicative emails should be deleted no later than every six (6) months.

Employees shall not store or transfer IWU related email on non-work-related computers except as necessary or appropriate for legitimate business purposes as authorized by the applicable Vice President.

Electronic Records (including Microsoft Office Suite and PDF files): The length of retention depends on the subject matter of the record and these electronic records shall be retained in accordance with the periods applicable to the subject matter of the record.

In certain cases a record will be maintained in both paper and electronic form. In such cases, the official record will be the electronic record. 

4. Applicability

This policy applies to all physical and electronic records described in Appendix A which are generated in the course of IWU’s operation.

5. Responsibilities

Departments and units that maintain University records are official repositories. These administrative units are responsible for establishing appropriate record retention management practices in compliance with this policy. Each department manager must:

• Implement record-management practices in accordance with this policy;
• Preserve inactive records of historic value and transfer those records to the University archives;
• Ensure that access to confidential files is restricted; and
• Destroy inactive records that have no archival value upon passage of the applicable retention period. When the prescribed retention period has passed, a determination of whether to preserve or dispose of the records must be made. To decide if the record is of historic value to the University, consult the University archivist, who has the authority to designate which records are archival.

6. Disposal of Records

Records that are to be disposed of in accordance with the policy shall be handled in one of the following ways:

• non-confidential paper records recycled;
• confidential records shredded or otherwise rendered unreadable;
• electronically stored data erased or destroyed.

Note: No record list can be exhaustive. Questions regarding the retention period for any specific record or class of records not included in these tables should be addressed to the Administrator.

Caution: Departments and units that are not official repositories and retain duplicate or multiple copies of these University records should dispose of them when they are no longer useful.

7. Suspension of Record Disposal

Document destruction will be suspended immediately upon any indication of an official investigation or when a lawsuit is filed or appears imminent. Destruction will be reinstated under the direction of the Office of Risk Management and Legal Affairs upon conclusion of the investigation.

8. Ownership of University Records

University records are property of Indiana Wesleyan University.  No employee has any right in or to such records, nor shall any employee remove, limit access to, or destroy such records except in accordance with applicable University policy.

APPENDIX A

Document Retention and destruction Schedule

 

Record Type	Description	Retention Period
Admissions	Un-Enrolled Applicants	3 years from decision date
	Enrolled Students	5 years from graduation date
Campus Police	Incident/Investigation reports	7 years
	Clery disclosures and related data	Permanent
	Daily Logs	Permanent
Environmental Health and Safety	OSHA Logs and Summaries	5 years from year reported
	Evacuation drill records; fire protection systems records; hazardous waste disposal manifests and reports.	5 years
Financial Aid	Financial Aid Records	3 years from graduation or date of withdrawal
	DOE Audit Determination	5 years from conclusion of audit
Financial / Accounting	Audited Annual Financial Statements and Audit Reports	Permanent
	Debt financing records (bonds, line of credit, etc.)	7 years after active record period
	Other (grant reporting, journal entries, surveys, audit support work files, etc.)	7 years after active record period
Human Resources	Applicant records – not hired	1 year
	Benefit plan documents and related filings / disclosures	Permanent
	Colleague and CARS records of employee name, date of birth, demographic data, position(s) held, dates of employment, and eligibility for rehire	Permanent
	Employee benefit eligibility-related	7 years after termination
	Employee Personnel Records	7 years after termination
Institutional / Governance	Bylaws, Articles of Incorporation, accreditation records, Board of Trustee minutes	Permanent
Intellectual Property	Patent/trademark applications and correspondence; invention disclosures/assignments	Permanent
Medical	Health Center Records	7 years
	Records pertaining to employee exposure to toxic or harmful agents or substances	30 years (40 years for inorganic arsenic exposure)
	Employee injury and illness reports	5 years
	FMLA	3 years
	ADA Accommodation	1 year from record creation or taking of the action
Record Type	Description	Retention Period
Payment Card Data	Credit, debit, other card numbers	No payment card data may be retained after a transaction is successfully processed and reconciled.  Once processed and reconciled, all data must be destroyed by cross-cut shredding or deletion.
Payroll	Federal and state information returns	7 years
	Other	3 years after termination of employment
Planning and Construction	As-built plans	Permanent
	Design/Construction Contracts	7 years after completion
Procurement	Purchase orders, invoices, purchase card reconciliations, etc.	7 years after active record period
	Vendor set up related forms (W-9, W-8, etc.)	Permanent
Publications, Statistical Documents, and Reports	Commencement programs, course catalogs, degree statistics, enrollment statistics, race/ethnicity reporting	Permanent
Real Estate Records	Acquisition documents (deeds, etc.)	Permanent
	Tax filings and payments	7 years after filing
	Leases, licenses, etc.	7 years after expiration
Risk and Legal	Contracts (includes agreements and MOUs)	7 years from date of final payment / performance
	Consent orders, court orders, judgments, releases, settlements	Permanent
	Claims and litigation files where IWU is a party	10 years after final disposition
	Liability Insurance Policies	Permanent
	Certificates of Insurance	Permanent
	Driver Applications / BMV checks	7 years after employment ends
	Off-campus travel applications	7 years after trip completion
Sponsored Program Records	All associated records	7 years after grant completion
Student Educational Records	Transcripts (IWU, other schools, AARTS/SMARTS), deceased file, list of graduated students, diploma files, grades/changes/rosters, authorization to release information, course waiver exemption, ECE forms, foreign academic review, academic records (including narrative evaluations, competency assessments, etc.), name change, withdraw form, subpoenas, prior learning assessment summary, test scores, transfer course summary, and military forms, receipts, evaluation and educational transcripts.	Permanent
	Other	5 years after graduation / final withdrawal
Tax Records	All IWU state, federal, and local filings	Permanent
	All IWU state, federal, and local filing supporting documentation	7 years after filing
	Payroll, Vendor, and Student-related information returns	7 years after active record period
Record Type	Description	Retention Period
University Advancement	Annuity, property, major donor, planned giving, estate, scholarships, and alumni records	Permanent
	Colleague contribution reports, Colleague donor roster reports, church match scholarship agreements and statements.	7 years
	Thank you letters (Scholarship), and year-end statements	3 years after donor’s death
	Tax Form(s)	Later of 3 years after donor’s death, or 7 years after filing year

Scope

This policy will affect all University employees and offices.

History

13-Apr-2016 - Initial draft created.  Updated 4/14/16.

 

Policy information

Originally Issued: 3/22/10

Revised:  4/11/16 (Executive Council)

Owner

Office of Risk Management & Legal Affairs

Approved by

Vice President for Business Affairs, University President

Additional remarks

There are no known exceptions to this policy at this time