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Records Management and Retention Policy 

This Records Management and Retention Policy (the 鈥淧olicy鈥) affirms 色中色 University鈥檚 (鈥溕猩 or the 鈥淯niversity鈥)1 commitment to the effective management and retention of its records as necessary to fulfill its educational mission, comply with legal requirements, and preserve its history.  色中色 complies with applicable federal, state, and local laws and discipline-specific standards in its management of University records.  This Policy is reviewed periodically for accuracy and compliance purposes. 

I. Purpose
The purpose of this Policy is to: (1) establish an efficient University-wide records management system for identifying, maintaining, retrieving, preserving, and destroying records, (2) ensure that records are adequately protected, (3) preserve University history, (4) ensure that records that are no longer needed or of no value are destroyed at the appropriate time and in the appropriate manner, and (5) comply with legal, contractual, and accreditation requirements for the retention, privacy, and security of records.

II. Scope
This Policy applies to each University record, as more particularly defined in Section IV.E below.

III. Applicability
This Policy applies to all employees and/or non-employee representatives who conduct business for or on behalf of the University (鈥淎pplicable Members鈥).

IV. Definitions

  1. Custodian of Record - The designated department, as identified in the Record Retention Table, that is responsible for retaining and timely destroying University records in accordance with this Policy. Each department is responsible for identifying a Data Steward and one or more Record Management Administrators who will fulfill the roles set forth in Sections V.F.i. and V.F.ii. belo
  2. Data Steward - Individual(s) who have the responsibilities set forth in Section V.F.i. below.
  3. Department - All academic, clinical, and/or administrative offices of the University.
  4. Office of Information Technology (IT) - The University information technology office (the 鈥淚T Office鈥), and/or, as applicable, any other organizational technology group within the University that maintains University information or resources.
  5. Record - Any type of record, file, document and other form of information created, received or transmitted in the ordinary course of the University鈥檚 business, regardless of format, whether on paper, electronic (e.g., cloud-based files, A/V recordings, locally stored files), microform (e.g., microfilm, microfiche, magnetic tapes, and CD-ROM), or another medium, and as more particularly set forth in the Record Retention Table. Active Record:
    1. A Record that is currently being used in the ordinary course of University business.
    2. Inactive Record:  A Record that is no longer being used in the ordinary course of University business but must be retained until the end of its Record Retention Period.
    3. Expired Record: A Record that: (a) is no longer being used in the ordinary course of University business, (b) has met or exceeded the Record Retention Period, and (c) is not a Historical Record.
    4. Historical Record:  A Record that is no longer being used in the ordinary course of University business that is permanently retained for its historical value.
  6. Record Management Administrator(s) 鈥 Individual(s) who have the responsibilities set forth in Section V.F.ii. below.
  7. Record Retention Period - The period of time during which the Custodian of Record is responsible for retaining a specified Record in accordance with the Record Retention Table.  
  8. Record Retention Table 鈥 A chart set forth in Appendix A attached hereto listing the: type of record, Custodian of Record, and the applicable Record Retention Period.
  9. University Data Classification - See Data Classification Policy
  10. University Information - See Information Technology Acceptable Use Policy

V. Procedures

  1. University Records and Record Retention Table

Active Records, Inactive Records, and Historical Records must be maintained in accordance with the Record Retention Table and this Policy.  Expired Records must be destroyed in accordance with this Policy.  The Record Retention Table designates the Custodian of Record for each type of identified Record.

A type of Record not identified on the Record Retention Table must be destroyed once the administrative need is fulfilled.   Any requested exception to the Record Retention Table that is deemed to meet an administrative need must first be approved by the Office of the Provost or the appropriate Vice President.

The Record Retention Table identifies Historical Records.  Any Historical Record must be sent to the University Archives and will reside there permanently.  

If two or more categories apply to a particular type of Record, each having a different retention period, the longer period governs.  To facilitate compliance with this Policy, all Record Retention Periods expiring during a calendar year may be extended to the last day of such calendar year.  Thus, all Records expiring during a calendar year must be destroyed by the last day of that calendar year. 

  1. Non-University Records

All Non-University records (i.e., any communications not listed in the Record Retention Table, informal communications) should be destroyed after the administrative need is fulfilled as determined by the Custodian of Record.  

  1. Copies of University Records

Departments and Applicable Members that are not the designated Custodian of Record for an identified University record are required to only retain copies and drafts of such University records to the extent necessary to conduct University business.  Such University Departments and/or Applicable Members must destroy such copies/drafts once they are no longer needed to conduct University business unless subject to a litigation hold (see Section V.D.). The designated Custodian of Record for an identified Record should only retain originals of Inactive Records and destroy all copies and drafts.

  1. Litigation Holds

University Counsel will issue a litigation hold, as required, as part of the University鈥檚 response to actual or potential litigation, subpoenas, administrative proceedings, governmental investigations or audits, or other legal proceedings (a 鈥淟egal Proceeding鈥). A litigation hold requires the University to retain all Records that may be relevant to the Legal Proceeding. In the event a litigation hold is necessary, the University Counsel will send a preservation notice to specific employees who may have Records containing information that is relevant to the Legal Proceeding. Employees who receive a preservation notice must maintain such Records in accordance with the terms of the notice and must not alter or delete them. 

An electronic record must be preserved in its original electronic form so that it (and all information contained within it, including metadata) can be retrieved, if necessary, later. It is not sufficient to print a hard copy of the electronic record. 

University employees must immediately notify University Counsel if they become aware that a Legal Proceeding has been initiated or have notice, should know, or reasonably can anticipate further Legal Proceedings. 

A litigation hold remains in effect until the University Counsel formally terminates the litigation hold by written notice. Unless University Counsel provides guidance to the contrary, when a litigation hold is terminated, Records previously covered by the litigation hold should be retained in accordance with the applicable Retention Period under this Policy without regard to the litigation hold. 

  1. Security-Confidential Information

Many Records contain confidential information which is protected by University policies and procedures, as well as federal, state, and local laws and regulations, including but not limited to the Family Educational Rights and Privacy Act (鈥淔ERPA鈥), the Health Insurance Portability and Accountability Act (鈥淗IPAA鈥), the Gramm-Leach-Bliley Act, and the Fair and Accurate Credit Transactions Act of 2003.  This Policy shall be implemented in a manner consistent with all such policies, procedures, laws, and regulations, as amended from time to time. 

  1. Records Management Responsibilities

Records management is the responsibility of all Applicable Members of the University.

  1. Responsibilities of Departmental Data Steward  
    The Data Steward of each University Department is responsible for: 
    1. Developing and maintaining practices and procedures that meet the specific requirements under this Section V and Section VI below;
    2. Ensuring Applicable Members of the Department comply with this Policy;
    3. Reporting any potential or actual non-compliance with this Policy to their respective Vice President;
    4. Alerting appropriate offices regarding needs for additional storage (e.g., IT for cloud-based storage that is approaching its limit) in a timely manner and managing, coordinating, or notifying associated budgetary processes. Certain cloud storage platforms are institutionally managed and will require escalation of discussion to the appropriate institutional team of decision makers;
    5. Designating one or more Record Management Administrators (depending on the organizational structure). If a Department is small or has fewer records management obligations, the Data Steward of the Department may consider serving as the Record Management Administrator; if a Department is large or has more or complex records management obligations, the Data Steward should consider designating more than one Record Management Administrator; and
    6. Designating an alternate Record Management Administrator in the event the current Record Management Administrator for the Department is unavailable.
       
  2. Responsibilities of Record Management Administrator
    The Record Management Administrator(s) must implement the Department鈥檚 established record management practices and procedures.  Specifically, the Records Management Administrator(s) is responsible for: 
    1. Coordinating retention, preservation, and destruction of Records in accordance with this Policy and the Department鈥檚 records management practices and procedures as they pertain to this Policy;
    2. Coordinating the Department鈥檚 efforts to comply with and respond to any issued litigation holds, internal or external investigations, court orders, or other requests for Records in a timely manner;
    3. Managing the space constraints of various record storage locations. This includes auditing records to determine what data has expired, destroying Expired Records, as well as Non-University records and copies/drafts (in consultation with the Custodian of Record), and migrating files to alternate University-sanctioned storage locations; and
    4. Communicating needs for additional storage to the Data Steward, all within a timely manner to be respectful of the University resources.
       
  3. Responsibilities of Applicable Members
    All Applicable Members are responsible for the Records in their possession.  Applicable Members are responsible for reviewing the content of the Records they use in conducting University business and complying with this Policy.  

    The IT Office is not responsible for determining whether an electronic record must be retained or destroyed in accordance with this Policy. Every Applicable Member is responsible for complying with this Policy and the record management practices and procedures established by their Department.  

    Failure to comply with this Policy may result in disciplinary action, up to and including termination of employment, and/or legal action.  If an Applicable Member believes another Applicable Member is violating this Policy (e.g., destroying University records required to be retained), such Applicable Member should immediately contact the Vice President in their division to report such incident. 

VI. Requirements for Department Record Management Practices and Procedures

A Department鈥檚 practices and procedures must cover all aspects of records management, including identifying, maintaining, retrieving, preserving, and destroying University records in accordance with this Policy.  Such practices must consider business needs as well as legal and security requirements.  In addition, such practices should allow for efficient access and retrieval of Records. 

  1. Protective and Security of Confidential Information

Departments must implement practices that protect confidential information contained in Records in accordance with relevant laws and University policies.  Such protection must be applied in maintaining Active Records, storing Inactive Records and Historical Records, and destroying Expired Records.  Thus, the level of security that applies to an Active Record must be maintained when such a Record becomes an Inactive Record or a Historical Record.  

  1. Physical Storage Practices

A Department鈥檚 storage facility practices must allow for efficient compliance and response to any litigation hold, internal or external investigation, court order, or other request for Records in a timely manner.  A Department鈥檚 storage facility practices must ensure a good faith effort to preserve all Records in their original condition while also ensuring efficient retrieval of such Records.  Departments should secure any physical on-campus storage facility to avoid unauthorized access.  In addition, such a facility and setup should protect such Records from common physical damage such as pest infestation, fire, smoke, sprinkler damage, water damage, and/or magnetic field damage.  

  1. Retention Practices

Records must be retained by the Custodian of Record in the following manner: 

  1. Hardcopies must be retained in hardcopy form unless converted to electronic format in a University managed system; and 
  2. Electronic records stored within a University managed system must comply with the requirements under Sections VI.A and B above and other applicable University policies.  The Custodian of Record is responsible for consulting with the IT Office to ensure such compliance. 

 

  1. Destruction of Expired Records

If the Custodian of Record believes that an Expired Record has historical value and should be permanently retained as a Historical Record, they should consult with their respective Vice President.  Otherwise, all Expired Records must be destroyed by the Custodian of Record in the following manner: 

  1. Hardcopy Destruction - Expired Records in hardcopy form that do not contain confidential information should be recycled.  Expired Records in hardcopy form that do contain confidential information must be shredded in a confidential manner that renders them unreadable, and that would prevent them from being reconstructed.  Security of the Expired Records must be maintained by the Custodian of Record until proper destruction is performed.
  2. Electronic Records - Emails and other electronic documents (e.g., Word and Excel documents and pdfs) should be deleted.

The Custodian of Record is responsible for consulting with the IT Office to ensure that Expired Records contained in a University-managed system are properly destroyed.  Devices or other media that store electronic records (e.g., hard drives, servers, and cloud-based locations) should be destroyed or erased in a manner consistent with media sanitization methods which include disintegration, incineration, pulverization, or melting.  The type of sanitization required will depend on the type of device and the nature of the information contained in the device. Such destruction methods require trained professionals and must be conducted by authorized personnel.  Please contact the IT Office for instructions.

This policy was reviewed and approved in March 2024 by University Council.  


1 色中色 University includes its schools, centers, institutes, divisions, subsidiaries, and affiliates.

APPENDIX A: RECORD RETENTION TABLE
ACADEMIC AFFAIRS
Type of RecordCustodian of RecordRecord Retention Period 
Faculty Handbook/PoliciesOffice of the ProvostElectronic- static copy each academic year (previously paper)
Faculty Tenure, Promotion and Review process recordsOffice of the ProvostElectronic- permanent (previously paper)
Student Academic Standards process records/outcomesOffice of the ProvostElectronic - Permanent Paper - 7 years from last incident
Education student placement records (teacher certification)Education Department7 years following completion of the program
Other academic program recordsOffice of the Provost/Individual Faculty 
 
1 calendar year after completion of the course, if not returned to the student.  Electronic records stored in Canvas are kept Permanent. 
Behavioral and Community Health student recordsSchool of Behavioral and Community Health 10 years following completion of the program
Rehabilitation Sciences student recordsRehabilitation SciencesPermanent
Nursing student records (PA SBON)Helen S. Breidegam School of Nursing and Public Health7 years after program completion
BUSINESS AND FINANCE
Type of RecordCustodian of RecordRecord Retention Period 
1098-T formsOffice of Student Accounts7 years
1099-MISC FormsBusiness Office7 years
Accounts Payable invoices & vouchersBusiness Office7 years
Annual audited financial statementsBusiness OfficePermanent
Annual financial statement workpapers, account reconciliations, supporting schedules, journal entries 
Business Office
Permanent
Bank statements and reconciliationsBusiness OfficePermanent
Bond records and accounting statementsFinance Office/Business OfficePermanent
Budget work papers and reportsFinance OfficePermanent
Capital asset recordsBusiness OfficePermanent
Contracts/leasesBusiness OfficeLength of Contract + 7 years
Depreciation recordsBusiness OfficePermanent
Direct deposit formBusiness Office5 years after expiration/replacement
EIT/LST formBusiness Office4 years after separation
Endowment records Finance OfficePermanent
Escheated check informationBusiness Office3 years
Form 990Business OfficePermanent
Form 1042Business Office7 years
Form I-9Business Office3 years after separation
Form W-4Business Office4 years after separation
General ledger (including subsidiary ledgers)Business OfficePermanent
Grants and associated documentation
Business Office
3 years after grant completed, or as required by the funder
Insurance policies and claim detailsBusiness Office10 years after policy end date or until pending claim is resolved
Investment recordsFinance Office10 years
Payroll historyBusiness Office4 years
Payroll tax returns (W-2, SS, Unemployment)Business Office7 Years
Perkins payment recordsOffice of Student Accounts3 Years from date PIF, canceled, or assigned to DOE
Procurement card documentationBusiness Office7 years
Real estate documents, property deeds, and easementsFinance OfficePermanent
Sales tax returnsBusiness Office7 years
Tax exemption certification - Federal, StateBusiness Office Permanent
Tuition billing and payment recordsOffice of Student AccountsPermanent
Wage garnishment recordsBusiness Office4 years after separation
CAMPUS SAFETY
Type of RecordCustodian of RecordRecord Retention Period 
Animal law enforcement recordsUniversity Police Department2 years
Calibration recordsUniversity Police Department5 years
Citations (Traffic and Non-Traffic)University Police Department3 years, if not part of criminal history case file
Clery Act records (timely warning, crime log, annual security report, etc.)University Police Department7 years after filing
Community relations filesUniversity Police DepartmentAs long as of administrative value
Complaints/Incident reports/Offense reports/Initial activity reportsUniversity Police Department3 years, if not part of criminal history case file
Court ordersUniversity Police DepartmentAs long as of administrative and/or legal value, if not part of criminal history case file
Criminal history and case files: Homicides or suspicious deathsUniversity Police Department75 years
Criminal history and case files: Summary casesUniversity Police Department5 years after closing of investigation
Criminal history and case files: All other casesUniversity Police Department20 years after closing of investigation
Criminal history dissemination recordsUniversity Police Department2 years, if no criminal record is found. Retain the same length of time as a case file if a criminal record is found.
Daily activity recordsUniversity Police Department3 years
Department firearms and ammunition recordsUniversity Police Department2 years after superseded or obsolete
Dispatcher's logsUniversity Police Department3 years after last entry
Hunting accident reportsUniversity Police Department2 years
Internal affairs case files/incident logsUniversity Police DepartmentIncident log - 7 years after last entry Substantiated charges - 3 years after separation of employment Unsubstantiated Charges - 3 years after closing of investigation or comply with union rules if applicable
Master name indexUniversity Police DepartmentAs long as of administrative value
Missing person fileUniversity Police DepartmentUntil case considered closed
Motor vehicle recordsUniversity Police DepartmentAccident report - 5 years after closing of investigation if not part of Criminal History Case File Police requests for removal of abandoned or impounded vehicle - 2 years Recommendation of special driver examinations - 1 year Parking violations - 1 year after all fines have been paid
Pennsylvania uniform crime reporting program worksheets/printoutsUniversity Police Department2 years
Permits and related applicationsUniversity Police Department3 years after expiration
Property records (evidence/found/recovered) 
 
University Police Department6 years after the property is no longer in the custody of the Police Department, if the record is not part of criminal history case file
Temporary detention recordsUniversity Police Department3 years, if not part of criminal history case file
Temporary detention recordsUniversity Police Department4 years
Towing recordsUniversity Police DepartmentAs long as of administrative value
Training recordsUniversity Police DepartmentAs long as of administrative value
Vacation/vacant house check recordsUniversity Police Department30 days unless used as evidence
Video/audio tapesUniversity Police Department30 days unless used as evidence
Waivers/release formsUniversity Police DepartmentAs long as of administrative and/or legal value
CENTER FOR GLOBAL EDUCATION
Type of RecordCustodian of RecordRecord Retention Period 
International student forms (I-20, I-94, Visa, etc.)Center for Global Education3 years after the student is no longer pursuing a full course of study or 3 years from the time of denied reinstatement
COMPLIANCE
Type of RecordCustodian of RecordRecord Retention Period 
Institutional PoliciesCompliance, Training and Development/Policy OwnersElectronic- static copy each academic year (previously paper)
Veteran/Military connect student academic recordsVeteran & Military Services/RegistrarSee Registrar Section
Veteran/Military connect student benefits/financial recordsVeteran & Military Services/Financial AidSee Financial Aid Section
Equal Opportunity/Title IX grievance process recordsEqual Opportunity & Title IXElectronic- permanent (previously paper- 7 years from last incident)
Pregnancy/Parenting recordsEqual Opportunity & Title IXElectronic- permanent (previously paper- 7 years)
DEVELOPMENT AND ALUMNI ENGAGEMENT
Type of RecordCustodian of RecordRecord Retention Period 
Copies of donation checksDevelopment and Alumni Engagement7 years
Contact and giving informationDevelopment and Alumni EngagementPermanent
Credit card information and/or gift slipsDevelopment and Alumni EngagementTransaction processed and credit card information is shredded immediately
Donor giving cards (prior to Jenzabar)Development and Alumni EngagementPermanent
Gift receiptsDevelopment and Alumni EngagementPermanent
Gift acknowledgment lettersDevelopment and Alumni Engagement10 years or longer (depending on the donor)
Phonathon card information (name, address and giving information, and credit card information if a gift is received)Development and Alumni EngagementApproximately 2 weeks during the phonathon process.  Credit card information is shredded following the phonathon.
Tuition billing and payment recordsOffice of Student AccountsPermanent
Wage garnishment recordsBusiness Office4 years after separation
ENROLLMENT AND FINANCIAL AID
Type of RecordCustodian of RecordRecord Retention Period 
Admission lettersAdmissions1 year after application term
Correspondence, relevantAdmissions1 year after application term
Waiver of rights of access (admissions)Admissions1 year after application term
Application for admission or readmissionAdmissions1 year after application term
Entrance examination reports/ test scoresAdmissions1 year after application term
Letters of recommendation (admissions)Admissions1 year after application term
Transcripts (high school or other colleges)Admissions1 year after application term
Records relating to administration of Federal Perkins Loan, FWS, SEOG, Federal Pell Grant, Veteran benefitsOffice of Financial Aid Services3 years after the end of the award year in which the FISAP is submitted
Records relating to student or parent borrower鈥檚 eligibility for Direct LoansOffice of Financial Aid Services3 years after the end of the award year in which the student last attended the institution
Records relating to participation in FFEL or Direct Loan Program (reports & forms)Office of Financial Aid Services3 years after the end of the award year in which the records are submitted
Records regarding loan, claim, expenditure (audit, program review, investigation documents)Office of Financial Aid ServicesThe resolution of that questioned loan, claim, or expenditure; or (ii) The end of the retention period applicable to the record.
State grant award listings and rostersOffice of Financial Aid Services5 years from the date the institution completes certification of the final reconciliation roster
A copy of the academic calendar with all possible start dates within each termOffice of Financial Aid Services/Registrar5 years from the date the institution completes certification of the final reconciliation roster
The date and amount of each credit of PA State Grant fundsOffice of Financial Aid Services/Office of Student Accounts5 years from the date the institution completes certification of the final reconciliation roster
The payment of any overpayment or return of PA State Grant fundsOffice of Financial Aid Services5 years from the date the institution completes certification of the final reconciliation roster
ENVIRONMENTAL HEALTH AND SAFETY
Type of RecordCustodian of RecordRecord Retention Period 
Chemical inventoryEnvironmental Health and Safety Department5 Years (multiple departments)
Emergency air monitoring and environmental samplingEnvironmental Health and Safety DepartmentPermanent
Fire drillsEnvironmental Health and Safety Department7 years (multiple departments)
Fire life system maintenanceEnvironmental Health and Safety Department3 years (multiple departments)
Hazardous material spills: major spills involving emergency services and clean upEnvironmental Health and Safety DepartmentPermanent
Hazardous waste disposal manifests and reportsEnvironmental Health and Safety Department10 years - 色中色 (waste vendors maintain records)
Incident & investigation reportsEnvironmental Health and Safety Department5 years
Occupational work exposuresEnvironmental Health and Safety DepartmentPermanent
Unplanned fire/fire-related incidents/injuriesEnvironmental Health and Safety Department7 years (multiple departments)
FACILITIES
Type of RecordCustodian of RecordRecord Retention Period 
Building/site plan specificationsFacilities OfficePermanent
Building/zoning/occupancy permitsFacilities OfficePermanent
Capital construction project contractsFacilities OfficeLength of Contract + 7 years
Maintenance recordsFacilities Office10 years
Operating permits (e.g., elevators)Facilities Office3 years from expiration
HUMAN RESOURCES
Type of RecordCustodian of RecordRecord Retention Period 
Attendance 鈥搒ick, vacation, or personal (covers FMLA needs)Office of Human Resources5 years
ApplicationsOffice of Human Resources3 years 
COBRA recordsOffice of Human Resources3 years
Conflict of interest Office of Human Resources3 years
Employee benefit plansOffice of Human Resources3 years after termination 
Employment Policies/HandbookOffice of Human ResourcesElectronic- static copy each academic year (previously paper)
ERISAOffice of Human ResourcesPermanent
FMLA - dates, notices of FMLA leave given to employer, mandatory employee notices, any record of disputesOffice of Human Resources3 years
Employment eligibility verification - Form I-9Office of Human Resources3 years after date of hire or one year after last date of employment, whichever is later 
Job descriptions/postings/searchesOffice of Human Resources3 years 
OSHA logsOffice of Human Resources5 years beyond posting date 
Payroll historyOffice of Human ResourcesPaper - 4 years  Electronic - Permanent
Personnel filesOffice of Human Resources4 years after separation.  Thereafter pertinent info should be entered into the database.
Reasonable accommodation recordsOffice of Human Resources3 years beyond separation
Unemployment formsOffice of Human Resources4 years after separation
Worker鈥檚 comp (accident reports and job-related injury claims)Office of Human Resources5 years after separation 
INFORMATION TECHNOLOGY
Type of RecordCustodian of RecordRecord Retention Period 
Jenzabar application logsDatabase, Applications, and Integrations72 hours
SQL database transaction logsDatabase, Applications, and Integrations1,650 days OR Maximum rows: 4.9 million records
Endpoint protection logsInformation SecurityStandard log entries - 30 days Alerts and incidents - 180 days
Firewall logsInformation Security30 days
SIEM recordsInformation Security30 days
BackupsInfrastructureDaily - 14 days / Weekly - 8 weeks / Monthly - 12 months / Yearly - 5 years
Decommissioned virtual machinesInfrastructure1 year
Duo logsInfrastructure180 days
Google Workspace and Microsoft365 accounts (user records)InfrastructureStudents - 1 year after graduation Employees - 1 year after the end of employment Emeriti - Permanent  Retirees - Administrative discretion
Linux server logsInfrastructure30 days
Microsoft Active Directory accounts (user records)InfrastructurePermanent
Microsoft Windows server logs 
 
InfrastructureApplication logs - 30 days Security logs - ranges from hours to days System logs - 30 days
Okta logsInfrastructure180 days
Remote monitoring and management logs Infrastructure90 days
Help desk software (Asset records, user records, ticket/incident records)User SupportTerm of subscription
Mobile device managementUser SupportAsset records - Deleted upon disposal User records - Term of the subscription
Equipment contractsUser SupportPermanent
JotformUser SupportTerm of subscription
INSTITUTIONAL RESEARCH
Type of RecordCustodian of RecordRecord Retention Period 
External surveys that Institutional Research administers (IPEDS, Common Data Set, Middle States, etc.)Institutional ResearchPermanent
Princeton Review, U.S. News and World Report, and University recruitment surveysInstitutional ResearchPermanent
Enrollment reports Institutional ResearchPermanent
JZ datamart officialInstitutional ResearchPermanent
LEGAL
Type of RecordCustodian of RecordRecord Retention Period 
Government regulatory compliance filingsCounselPermanent
Litigation files/claimsCounsel10 years from termination of litigation or service of subpoena; for claims with no litigation, 3 years or until claimant turns 21 years of age, whichever is later
Opinion lettersCounsel10 years
MARKETING AND COMMUNICATIONS
Type of RecordCustodian of RecordRecord Retention Period 
Institutional publicationsOffice of Marketing & CommunicationsPermanent
Press releasesOffice of Marketing & CommunicationsPermanent
PRESIDENT鈥橲 OFFICE
Type of RecordCustodian of RecordRecord Retention Period 
Board of Trustees recordsOffice of the President 
 
Permanent
Committee meeting records Office of the PresidentPermanent
President鈥檚 Office files Office of the President7 years and then evaluate for necessity
REGISTRAR
Type of RecordCustodian of RecordRecord Retention Period 
Academic advisement records (Academic Advisement, Career Services, Educational Opportunity Programs, Learning Centers, and Services to Students with Disabilities)Office of the Registrar5 years after graduation or date of last attendance
Academic warning (notice of academic action related to academic non- performance/deficiency)Office of the Registrar5 years after graduation or date of last attendance
Academic suspension (notice of academic action related to academic non-performance/deficiency)Office of the RegistrarPermanent
Academic records - miscellaneous (narrative evaluations, competency assessments, etc.)Office of the RegistrarPermanent
Correspondence, student (related to academic records, inquiries)Office of the Registrar5 years after graduation or date of last attendance
Grievance/complaint by student (various course/exam related issues, not grade of FERPA disputes)Office of the RegistrarUntil administrative need is fulfilled
Leave of absenceOffice of the RegistrarUntil administrative need is fulfilled
Major changes, certification of 2nd majors, minorsOffice of the RegistrarUntil administrative need is fulfilled
Petitions (exceptions to academic rules)Office of the RegistrarUntil administrative need is fulfilled
TranscriptsOffice of the RegistrarPermanent
Enrollment verifications (verifications of enrollment, graduation, GPA, and other related academics)Office of the RegistrarUntil administrative need is fulfilled
Residency verification records (documents in support of verifying residency in state for tuition purposes)Office of the RegistrarUntil administrative need is fulfilled
Transcript requests (official transcript requests by student)Office of the RegistrarUntil administrative need is fulfilled
Application for degree or other credential (degree application, record of degree name, etc.Office of the Registrar5 years after graduation or date of last attendance or until administrative need is fulfilled  
Graduation lists (lists of graduates for graduating class)Office of the RegistrarPermanent
Substitutions/waivers (approval to meet program requirements with administrative action)Office of the RegistrarUntil administrative need is fulfilled
Grade appeal/complaint (student final grade dispute)Office of the Registrar1 year after course completion
Grade change forms (record of authorization to change grades)Office of the RegistrarUntil administrative need is fulfilled
Grade reports (midterm)Office of the RegistrarEnd of term
Grade submission sheets/data (original records of grades submitted at end of term)Office of the RegistrarPermanent
Name change authorizationsOffice of the RegistrarUntil administrative need is fulfilled
Personal data information forms (change of address, race/ethnicity questionnaires, and other demographics)Office of the RegistrarUntil administrative need is fulfilled
Transfer credit evaluationsOffice of the Registrar5 years after graduation or date of last attendance
Class lists (record of class rosters for each term)Office of the RegistrarUntil administrative need is fulfilled
Course repeat form/approvalOffice of the RegistrarUntil administrative need is fulfilled
Credit/no credit, audit, or pass/no pass approvals (authorization from various enrollment options)Office of the RegistrarUntil administrative need is fulfilled
Enrollment changes (record of student add/drop/withdraw from class)Office of the RegistrarUntil administrative need is fulfilled
Hold or encumbrance authorizations (registration)Office of the RegistrarUntil administrative need is fulfilled
Registration/enrollment records (initial registration forms, current enrollment records)Office of the RegistrarUntil administrative need is fulfilled
Withdrawal/cancellation of enrollment records (record of request to withdraw from all classes)Office of the RegistrarUntil administrative need is fulfilled
Electronic Data - Data change logs (electronic log of changes to enrollment and other data, including date/time stamp information and user that changed data if that data is maintained separately in system)Office of the Registrar10 years
Electronic Data - Emails and other electronic communications that authorize academic/enrollment actions and /or provide directory/non directory information about a studentOffice of the RegistrarUntil administrative need is fulfilled
Electronic Data - Enrollment data (electronic records of enrollment include classes, including records of drop, add and enrollment change activityOffice of the Registrar10 years
Electronic Data - Grade data (electronic record of submitted grades and grade changes, including date/time stamp and user data)Office of the RegistrarPermanent
Electronic Data - Student Demographic Information (electronic student data including student characteristics, date of birth, former names, address information, photo ID and ethnicOffice of the Registrar50 years
Catalogs (published annually or bi- annually, record of courses, degrees, and programs of study offered)Office of the RegistrarPermanent
Commencement programs (published record of graduates for publicOffice of the RegistrarPermanent
Degree Statistics (record of degrees granted by institution per graduation term and/or annually)Office of the RegistrarPermanent
Enrollment Statistics (per term report of enrolled by students, e.g. by class, by course, totals, headcount, and FTE)Office of the RegistrarPermanent
Grade distribution and other grade statistics (report of grades given, including summary grade point statistics by class)Office of the RegistrarPermanent
Race/ethnicity reporting (report of student enrollment, graduation, and other metrics by race and ethnic origin)Office of the RegistrarPermanent
Instructor evaluations (by students)Office of the Registrar4 years following evaluation
Veterans鈥 administrationOffice of the Registrar3 years after graduation or date of last attendance certifications
SEMINARIES
Type of RecordCustodian of RecordRecord Retention Period 
Acceptance letterSeminary Offices5 years after graduation
Application supporting documents - references, essay(s), letters of recommendationSeminary OfficesDestroy upon acceptance
Type of RecordCustodian of RecordRecord Retention Period 
Background checksSeminary OfficesPermanent
Change of program letterSeminary Offices5 years after graduation
Continuing Education Requirement artifactsSeminary OfficesDestroy upon graduation
Dismissal letter (not related to or governed by the Academic or Student Codes of Conduct)Seminary OfficesPermanent
Independent study form & syllabusSeminary OfficesPermanent
ThesisLibraryPermanent
STUDENT LIFE
Type of RecordCustodian of RecordRecord Retention Period 
SHARE and Threat assessment recordsStudent LifePermanent
Student accommodation records Disability & AccommodationsPaper - 5 years after last date of attendance (after 2032, all paper files will be destroyed) Electronic - Permanent
Student therapy records Counseling CenterPaper - 7 years (after Fall 2026, all paper files will be destroyed) Electronic - Permanent
Student discipline recordsStudent Accountability & Conflict TransformationPaper - 7 years as of the last incident Electronic - Permanent
Student health recordsHealth Center8 years after last service
Student internship records (Handshake)Career Services & Civic EngagementPermanent
Volunteer background clearancesCivic Engagement7 years