Document Retention and Destruction Policy
Overview
This document holds the University's official policy for retention and destructionof both print and electronic documents.
Policy
- 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.
- 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.
- 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.
- Applicability
This policy applies to all physical and electronic records described in Appendix A which are generated in the course of IWU’s operation.
- 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.
- 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.
- 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.
- 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