Document Retention Policy

Purpose

This policy provides guidance for the systematic review, retention, and destruction of documents received or created by Limestone University in connection with the transaction of University business. This policy applies to all records and documents regardless of physical form and contains guidelines for how long certain documents should be kept and how records should be destroyed (unless under a legal hold). The policy is designed to promote compliance with applicable laws and regulations, eliminate accidental destruction of records, facilitate operations, and reduce costs by encouraging efficiency and freeing up valuable storage space.

OVERVIEW

Limestone University requires consistent treatment of records. Maintenance, retention, and disposal procedures of University records must be followed systematically by staff in designated official repositories. In addition, duplicate or multiple copies of these records retained in locations other than official repositories must also be disposed of when they are outdated and no longer useful.

This policy is intended to ensure that the University:

• Meets legal standard
• Optimizes the use of space
• Minimizes the cost of record retention
• Preserves the University’s history
• Destroys outdated and useless records

DEFINITIONS

These definitions apply to these terms as they are used in this policy:

Active Record: A record with current administrative use for the unit that generated it. Records remain active for varying numbers of years, depending on the purpose for which they were created (See attached schedule).

Archival Record: A record that is inactive, not required to be retained in the Office where it originated or was received, and has permanent or historic value. Archival records are retained and preserved indefinitely in the University Archives or other permanent storage place approved by the appropriate Dean or Vice President. If it has been determined through consultation with the University Archivist that the records are archival, they may be transferred to University Archives.

Non-Archival Record: The University Archivist must provide prior authorization to dispose of any document or record within the scope of this policy. If it is determined a document should be disposed of, destroy it in one of the following ways:

1. Recycle non–confidential paper records
2. Shred small to medium-sized batches of confidential records in an onsite locked Shred bin provided on campus.
3. Contact the University Archivist to make arrangements for the destruction of large batches of records
4. Erase or destroy electronically stored data; consult with IT regarding properly destroying electronic records.
5. Departments are responsible for contacting any hosted locations to destroy documents annually.

Official Repository The unit designated as responsible for the retention and timely destruction of particular types of official University records. Such responsibility is assigned to the unit’s administrative manager or a designee.

Departments and units that maintain University records are called “official repositories.” These administrative units are responsible for following established record retention management practices. Each unit’s administrative manager or a designee must:

• Implement the unit’s and/or Office’s record management practices in accordance with the Retention Schedule
• Ensure that these management practices are consistent with this policy
• Educate staff within the administrative unit in understanding sound record management practices
• Preserve inactive records of historic value and transfer those records to the University Archives
• Ensure that access to confidential files is restricted. Long-term restrictions on access to selected archival records should be specified at the time of their transfer to the University Archives
• Destroy or make arrangements for University Archives to destroy records that have no archival value in accordance with the Retention Schedule.

Questions about these responsibilities should be directed to the University Archivist, who will work closely with units to ensure an understanding of this policy and implementation of these responsibilities.

University Archives: A component of the Document Retention Policy promotes knowledge and understanding of the University’s origins, aims, programs, and goals and facilitates effective records management. This includes permanent retention of official records and reports of the University, its Officers, and component parts; maps and architectural records; audiovisual materials, including still photographs and negatives, motion picture film, oral history interviews, audio and video tapes; and artifacts and ephemera documenting the University’s history.

University Archivist: The individual responsible for (1) designating which official University records are archival and (2) effecting the transfer of archival records from the Office in which they originated or were received to the University Archives at such times and in the manner and form prescribed by the Archives, and subject to the appropriate retention and disposition schedules that are outlined in this document.

University Record: The original copy of any record.

Retention Schedule The official retention schedule of the University is attached as Table 1. The Retention Schedule lists the Official Repository for specific records and the retention period.

The information listed in the retention schedule below is intended as a guideline and does not contain all the records the University keeps or may be required to keep in the future. Questions regarding the retention of documents not listed in this chart should be directed to the President.

Note that from time to time, the University may issue a notice, known as a “legal hold,” suspending the destruction of records due to pending, threatened, or otherwise reasonably foreseeable litigation, audits, government investigations, or similar proceedings. No records specified in any legal hold may be destroyed, even if the scheduled destruction date has passed, until the legal hold is withdrawn in writing by the President.

1. Electronic Documents and Records.

Electronic files will be retained as if they were paper documents. Therefore, any electronic files that fall into one of the document types on the above schedule will be maintained for the designated amount of time.

If a user has sufficient reason to keep an e-mail message, the message should be printed in hard copy and kept in the appropriate file or moved to an “archive” computer file folder. Backup and recovery methods will be tested regularly.

2. Emergency Planning.

University records will be stored in a safe, secure, and accessible manner. Documents and financial files essential to keeping the Organization operating in an emergency will be duplicated or backed up at least every week and maintained off-site.

3. Document Destruction.

The President is responsible for the ongoing process of identifying University records that have met the required retention period and overseeing their destruction. Destruction of financial and personnel-related documents will be accomplished by shredding.

Document destruction will be suspended immediately upon any indication of an official investigation or when legal proceedings are filed or appear imminent. Destruction will be reinstated upon the conclusion of the investigation or legal proceedings.

4. Compliance.

Failure to follow this policy may result in possible civil and criminal sanctions against the University and its employees and possible disciplinary action against responsible individuals. The President and Board Chair will periodically review these procedures with legal counsel and/or the University’s certified public accountant to ensure that they follow applicable laws and regulations.

Changes or Additions to the Retention Schedule

Caution: Departments and units that are not official repositories and retain duplicate or multiple copies of University records should dispose of them when they are no longer useful but no longer than the retention period set forth on the Retention Schedule.

Adopting this policy does not relieve or otherwise affect the pre-existing obligation of any department to maintain records relating to a matter under litigation, government audit, or investigation. All such records should be preserved until the matter to which they relate has been finally resolved, and the General Counsel has approved their disposition. Any questions about applying this exception should be directed to the Data Governance Committee.

Each Official Repository and the University Archivist should review document retention on an annual basis and destroy documents in accordance with the Retention Schedule. Consequently, documents may be maintained longer than the date that the Retention Schedule indicates for their destruction until the annual review date.