623 Document Retention and Destruction Policy

I. Introduction

This policy provides for the systematic review, retention and destruction of records received or created by Centre College (“College”) in connection with the transaction of College business.  The attached Guidelines for Record Retention was prepared in light of federal, state and legal requirements. Because the College does not have a centralized records management office, each department is responsible for the retention, disposal, and transfer of the records it generates.

The Guidelines for Record Retention will assist faculty and staff in identifying those portions of their files that are appropriate for retention and for transfer to the College Archives. Original materials (see Sections III and IV below for details) should be retained in the office of origin according to the Guidelines for Record Retention. When the retained records become of historical interest only, they should be sent to the Archives with an explanation of their importance.

II. Definition of Records

Official records consist of recorded information that are created or received by College employees in the course of performing official functions on behalf of the College. These may include items related to policies, decisions, procedures, operations, and external or internal transactions. These records are the property of the College. See Section III for items that are not official records.

Official records can be recorded in physical form or electronic medium, but should be housed in College-storage or in systems of record that are maintained and approved by the College, instead of personal storage facilities (either physical or electronic). Examples of official records include accounting documents, payroll records, memoranda, letters, reports, books, plans, maps, diagrams, photographs, film, recordings, e-mail, word-processed documents, spreadsheets, databases, and imaging systems.  Examples of College-approved storage facilities are office filing cabinets, Jenzabar, Millennium, Navigate, or Alfresco. All storage locations should be listed on the records retention schedule.

III. Retention Schedules

Records should be retained according to the Guidelines for Record Retention. It is important to note that there is only one official record. Duplicate copies may exist in several different departments. The custodian of that record is responsible for the retention and destruction of that record. Duplicate copies should not be retained for any longer than what is prescribed in the Guidelines for Record Retention (which can be found by logging into CentreNet at Master Records Retention Schedule).

The Guidelines for Record Retention summarize many of the common College records and their respective retention period. Each office that generates official records must develop, update, and adhere to the official retention schedule pertinent to the responsibilities carried out in that office. These schedules include:

• Description of Official Record
• Location of the official record
• Departmental owner of the record (senior administrator supervising the department) and steward of the record (employee who has day to day charge of the creation, maintenance, and disposal of the record)
• Format of the record (paper or electronic)
• Identification of whether the record contains education records of students, personally identifiable information, or personal financial information (as protected by various state and federal laws and regulations)
• Recommended minimal retention period (Note that guidance on retention times for many types of official records are provided by law and/or professional associations)
• Retention period (which may be longer than mandated by law)

   

  It is important to retain critical documents, but many items do not need to be retained. Records that should be disposed of at the end of their retention period include:

   

• Records of specific financial transactions
• Routine letters of transmittal and acknowledgment
• Memoranda that are not personally addressed—except for one record copy from the issuing senior staff member
• Requests for publications or information after the requests have been filled
• Replies to questionnaires if the results are recorded and preserved either in the Archives or in a published report (which also should come to the Archives).

   

  Items without a retention period, which may be discarded directly from the office when they are no longer needed for administrative purposes, include:

   

• All blank forms and unused printed or duplicated materials
• All other duplicate material, including received e-mail messages from other offices on campus: the originating office should keep only the original; keep annotated copies
• Papers, reports, working papers, and drafts that have been published
• Artifacts and memorabilia. The Archives does not collect non-paper objects except in cases of great importance to the history of the College and manageable physical size and condition. Please contact the Archivist to discuss options for preservation of such objects.

Where a record may fit into one or more categories with different retention periods, the record should be maintained for the longer retention period.

If any person subject to this policy believes, or is informed by or on behalf of the College, that the College records are relevant to actual or potential litigation (whether the College is suing or being sued by a third party) or an actual or potential governmental investigation or audit, then those records must be preserved until the College’s legal advisors determine the records are no longer needed. This exception supersedes any previously or subsequently established destruction schedule for those records.

  IV. Transfer to Archives

After the specified retention period in the office of origin, items of historical value should be transferred to the Archives, consistent with policies adopted for and by the College archivist or recommendations made by the archivist on a case-by-case basis.

Records commonly transferred to the Archives:

• Constitutions and bylaws, minutes and proceedings, transcripts, lists of officers and College committees, offices, and departments
• Office and department files: correspondence and memoranda (incoming and outgoing), annual reports, subject files concerning projects, activities, and functions
• Historical files documenting policies, decisions, committee and task force reports, questionnaires
• Publications issued by the College or its subdivisions
• Audiovisuals: photographs, films, and sound and video recordings
• Personal papers of students, faculty, and staff that relate to the College’s work.

When materials are transferred, they should be kept in the order in which they were created and maintained in the campus office. A letter briefly identifying the material and describing the activity to which it relates should accompany the transfer.

V. Disposal

Disposal of records which have been maintained pursuant to this Policy and which need not be archived or kept should be destroyed regularly, at least annually. It should not be deferred until records become a pressing storage problem. When there is doubt about whether a record may be destroyed, the office of record should review the Guidelines for Record Retention and consult with the Archivist. Any sensitive or identifying personal information existing in such records (such as social security number, driver's license number, mother's maiden name, account number or code, or personal financial information) must be disposed of in a manner that will prevent unauthorized individuals from accessing the information.

When the required retention period of a record has passed, the record must be destroyed as follows:

Paper records:  Paper records should be either (a) discarded, preferably in recycle bins if the records do not contain confidential or personal information or (b) securely shredded or otherwise rendered unreadable if the records contain any confidential or personal information.

Electronic records:  Electronic records should be destroyed in the manner prescribed by the College’s Chief Information Officer.