Document Retention Policy

Purpose:

This policy is intended to ensure that the College complies with appropriate legal requirements for documentation of its activities, has access to the documents required for business purposes, and identifies documents whose retention is not required.

Definition of Retention:

For the purposes of this policy, documents are considered to be retained if they meet the following criteria:

  • Financial information is considered retained if it is contained in the accounting system, payroll system and appropriate folder on the server or in paper files.
  • Corporate information is considered retained if it is placed, in paper form, in the corporate files maintained in the Clerk’s office or in electronic files on its server.
  • Employment information is considered retained if it is contained in the College’s human resources database, its payroll system and electronic files on its server or in its paper files.
  • Student records are considered retained if they are contained in electronic format on the server or, in the case of transcripts or other permanent records of students’ academic histories, in paper files.

This policy assumes that the College continues its practice of regular, off-site back-ups of electronic files.  If this practice changes the College should revisit the definition of retention.

Documents maintained in either e-mail or voicemail format are not considered retained for the purposes of this policy.  E-mail documents should be converted to another electronic format, or printed; voicemails should be transcribed.

Litigation:

In the event any documents retained under this policy become material, or potentially material, to litigation filed by or against the College, the retention limits for these documents are suspended.  Any such documents must be retained until the appeal periods for litigation have passed, or as specified in any settlement agreement or court order.  This includes circumstances under which litigation has not yet been filed, but which might be reasonably expected by the College.  The determination of the applicability of this section rests with the president or his or her designee in consultation, if necessary, with counsel.

Destruction of Documents:

Documents that are not designated for retention under this policy may be discarded by the College staff at their convenience; but any such documents that become material, or potentially material, to litigation filed by or against the College must be retained until the appeal periods for litigation have passes or as specified in any settlement agreement or court order.  The officers having charge of human resources, information technology, and finance will develop a protocol for an annual review of documents held by the College and designate (subject to the approval of the president or his or her designee) documents to be discarded.

 

Type of Document

Retention Period

FINANCIAL RECORDS

 

Accounts receivable, payable ledgers, schedules.  (This requirement is satisfied by retention of monthly AR schedule, and by electronic back-up of accounting system).

7 years

Audit reports, Financial Statements (year end): general ledgers, trial balance, journal entries.  (This requirement is satisfied by retention of annual audits and schedules prepared for the audit, as well as back-up of accounting system in a format that allows reconstruction of all transactions and journal entries)

Permanently

Bank statements, deposit records, electronic fund transfer documents, canceled checks, bank reconciliations, and voided checks.  This includes investment accounts.

7 years

Chart of accounts.  (This requirement is satisfied by electronic back-up of accounting system).

Permanently

Checks (for important payments & purchases)

Permanently

Contracts, mortgages, notes and leases

7 years following the expiration of the contract.

Correspondence (with customers and vendors, including grantors).  This applies to correspondence that sets or amends terms and conditions but does not apply routine correspondence generated in the course of receiving or providing the service.

2 years

Donations

7 years

Deeds, mortgages, and bills of sale for capital equipment.  Sales of used computer equipment to staff and other organizations for amounts under $500 are not included.

Permanently

Depreciation schedules

Permanently

Expenses Analyses/expense distribution schedules.  (This requirement is satisfied by electronic back-up of accounting system).

7 years

Grants and related correspondence (foundations and grantors).  This includes proposals for funding, grant letters, amendments to grants, and progress reports.

7 years after closure of grant.

Invoices (to customers, from vendors)

7 years

Loan documents and notes

Permanently

Tax returns and worksheets

Permanently

CORPORATE RECORDS

 

Correspondence (legal and audit)

Permanently

Articles of Incorporation, charter, bylaws, minutes and other incorporation records

Permanently

Insurance Policies (expired)

3 years

Insurance records, current accident reports, claims, policies, etc.

Permanently

Trademarks, patents and related papers

Permanently

EMPLOYMENT AND PAYROLL

 

Employment records.  This includes documents related to hires, rehires, tests, evaluations, promotions, transfers, demotions, selection for training, layoff, recall, termination or discharge.  This specifically includes requests for reasonable accommodation under the ADA, and the disposition of such requests.

 

3 years following the last date of the employee’s employment

I-9 Forms

3 years after date of hire or 1 year after termination

EEOC reports

Permanently

Records of job-related injuries and illnesses, specifically, logs with dates and summaries and details of accidents.

5 years

Garnishments

7 years

Payroll records & summaries including records related to employee’s leave, sufficient to document compliance with the Family and Medical Leave Act.

7 years

Personnel files (terminated employees)

3 years after termination

Retirement and pension records including Summary Plan Descriptions (ERISA)

Permanently

Timesheets

7 years

Withholding tax statements (FICA, FUTA, Federal Income) This is satisfied by retaining IRS Form 941, and its state equivalents.

7 years

Workers compensation documentation

10 years

ACADEMIC AND STUDENT RECORDS

 

Accreditation documents, including self-study and external evaluative report

Permanently

Accreditation documents, other

5 years after submission of self-study

administrative records, including faculty schedules, student assignments, course assignments

1 year after academic year ends

Student complaint files (exclusive of discrimination claims)

4 years after closure

Student application records (matriculated students)

5 years after graduation or last course taken

Student application records (non-matriculated students)

1 year after receipt

Course catalogs, brochures

Permanently

Transcripts

Permanently

Student accommodations (ADA)

5 years after graduation or last attendance

Instructor’s grade reports, related records, course records

2 years after completion of course

Internship records, assessments

5 years after graduation or last attendance

Advisor’s notes/records

1 year after graduation or last attendance

Academic actions (dismissals, change of status, etc.)

5 years after graduation or last attendance

Student disciplinary records

5 years after graduation or last attendance

Commencement programs, graduation lists

Permanently

International students: immigration records

5 years after graduation or last attendance

FERPA requests and disclosures

Life of requested record

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