Information Technology, Documents, & Records

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Records Retention

Introduction

The College Archives is the official depository for non-current college records having lasting administrative or historical value. All documents, correspondence, accounts, files, manuscripts, publications, photographs, recordings, drawings, or other material regardless of physical or digital format and characteristics, which are created or maintained by college officers, staff, or faculty members in the performance of assigned administrative duties are considered “college records” and are the property of the College. Pursuant to a 1974 action of the Board of Trustees, no such records are to be discarded, destroyed, or otherwise disposed of except after consultation between the College Archivist and the administrative officers, department heads, or committee chairs responsible for the custody of these records during their active life. Approval either to transfer inactive college records to Archives or to destroy them after an agreed-upon period may take the form of written records disposition schedules or other agreements between the Archivist and the custodian of the records. A number of general “blanket” authorizations for disposal of certain classes of routine records have already been issued – please contact the Archives if you have any questions. One copy of every publication issued by the College or any college agency should always be forwarded to the Archives.  Restrictions on access to records transferred to Archives may be negotiated by the agency or office of transmittal. Reference service provided by the Archives to the College may include searching records to provide specific pieces of information, making copies of particular documents, or making records available for consultation in the Archives. Offices and departments which transfer records to Archives may request the return of records to the transmitting office, if transfer to Archives is found to have been premature. In addition to official college records as defined above, the Archives may also accept donations of professional and personal papers belonging to individual members of the College community, records of student organizations, or other material documenting aspects of the life or business of Carleton College that may be given to the Archives for preservation and use.

The need for this Record Retention Policy arose in light of new Federal Rules of Civil Procedure relating directly to document and data retention, including electronic documents and e-data.  The new Rules establish procedures for discovery by litigation opponents of electronic information.  The Rules also provide protections against sanctions being imposed on a litigant in the event that information which could be relevant to the case has been destroyed pursuant to a document or information retention policy.  Although the Rules technically apply only in cases in federal court, the principles are likely to be applied by any court.

There are two basic concepts raised by the new Rules – general and specific.  The specific is that if Carleton has notice that a claim which could end up in court has been or is reasonably likely to be asserted against it, then Carleton must place a “litigation hold” on the destruction of documents (electronic or hard copy) which are relevant to the case or may lead to the discovery of relevant evidence.  Simply put, if Carleton has notice that it might get sued, it must take affirmative steps to preserve information, including sending notice to everyone at Carleton who might have information and instructing them not to destroy any documents or data, and putting a hold on, or stop to, any automatic destruction processes.

The general concept is that it is in Carleton’s interest to implement retention procedures that result in the destruction of documents and data which do not need to be retained either for legal or institutional reasons.  There are a number of reasons why retention procedures make sense, four of which are:

1. the Rules state that “absent exceptional circumstances, a court may not impose sanctions under these rules on a party for failing to provide electronically stored information lost as a result of routine, good-faith operation of an electronic information system”;
2. the cost to the College of producing discoverable information will be lower if there is less information to produce;
3. variations in destruction practices by individuals in the absence of a retention policy could cause a court to infer that information was destroyed when it should not have been; and
4. relief from a significant burden on the College in the storing of data and documents for a period longer than required by law or in the College’s interest.

Data & Record Retention Team

Chief Technology Officer (jscannell@carleton.edu, X4077)
Director of Development Operations (sschulz@carleton.edu, X5979)
Registrar (trodriguez@carleton.edu, X4290)
Senior Associate Dean of Admissions and Director of Student Financial Services (dhayden@carleton.edu, X4138)
Comptroller (lthornto@carleton.edu, X4171)
Director of Human Resources (kcardena@carleton.edu, X4068)
College Archivist (tlamb@carleton.edu, X7015)

RECORDS RETENTION POLICY

A.     Purpose

Proper retention of records is essential to conducting the business of the College; to protecting the legal interests of the College, students, and employees; to preserving the College’s history; and to complying with applicable state and federal laws and regulations.  In addition, the College is obligated to preserve records when litigation is threatened or pending.  For the purposes of efficiency and management of physical and digital storage resources, it is also important that unneeded records be disposed of in a timely manner.

This policy applies to all departments, divisions, offices, and employees of the College.  Personnel are required to be familiar with and to adhere to this policy, as it pertains to the types of records/documents in the Document and Data Retention Schedule below.

B.      Records Defined

For the purposes of this policy, “records” include documentary material, regardless of media, produced in the course of College business.  The most common types of records generated and their retention periods are addressed in the Document and Data Retention Schedule.  Any questions concerning records not specified in the schedule should be directed to the Data and Record Retention Team before a record is destroyed.  “Records” also include copies of original materials that are themselves different from the original (e.g., a copy of a document with marginal handwritten notes).

“Records” do not include extra copies of materials of which an official copy has been retained, nor do they include personal or transitory correspondence/materials (see Section D below).  “Records” also do not include “transitory documents” (including e-mails) that are not included in any of the categories in the records retention schedule.  “Transitory documents” can be destroyed when no longer needed.  “Transitory documents” include items such as letters of transmittal or acknowledgements; requests for routine information; notices of staff/department meetings or events; communications to students concerning class schedules or assignments; records that are kept in the sole possession of the maker, are used only as a personal memory aid, and are not accessible or revealed to any other person except a temporary substitute for the maker of the record; personal correspondence or other documents not related to the business of the College; and the like.

C.      Data and Record Retention Team

The Data and Record Retention Team is responsible for implementing the College’s records retention policy and procedures.  The Data and Record Retention Team is authorized to perform the following functions:

1. Identify records generated by and received by the College that should be retained.
2. Publish a record retention procedure schedule that complies with any applicable state and federal laws and regulations.
3. Monitor state and federal laws and regulations affecting record retention.
4. Answer questions from college personnel concerning record retention.
5. Periodically review the record retention procedure and schedule and update as necessary.
6. Develop a training and awareness program on record retention for the College personnel.
7. Develop guidelines for appropriate destruction of College records.
8. Develop guidelines to maintain confidentiality of records as necessary.
9. Monitor departments for compliance with the record retention policy and procedure.
10. Authorize deviation from the retention procedures or schedule, usually for a research or other academic purpose, on a case-by-case basis.

D.     General Record Retention Rules

The following are general rules pertaining to record retention.  There may be additional rules and procedures governing particular types of records.

1. College personnel are required to check the record retention schedule before disposing of materials generated in the course of College business.
2. If a particular type of document does not appear to be covered by the schedule, consult with the Data and Record Retention Team.
3. Only one copy of a document should be retained, by the party or department responsible for it (see Document Custodian).  Where possible, the retained document should be the original.  Permanent records may be transfer to College Archives by the Document Custodian on a scheduled basis.
4. Drafts and notes concerning a document should be destroyed unless they are important to documenting official business or action of the College, in which case they will be stored with the document.
5. Except as noted in the retention schedule, the retention period runs from the date the record was created or received.
6. In the case of pending or reasonably anticipated litigation, the college will impose a “litigation hold,” which will be communicated to all persons whom the college has reason to believe may be in possession of documents that are either relevant or may lead to the discovery of admissible evidence pertaining to the case.  The imposition of a “litigation hold” means that all retention periods are suspended for applicable documents and no such documents shall be destroyed or altered until notification that the litigation matter has been concluded.
7. E-mails are computerized documents that should be treated like any other record and are subject to the same retention schedule.
8. Documents stored in OnBase should be treated like any other record and are subject to the same document retention schedule.
9. Any questions as to whether a particular type of document is “transitory” and can be destroyed should be directed to the Data and Record Retention Team.

E.      Records Retention Schedule

The Document and Data Retention schedule includes records by office and category; the retention period in days, months, and years and the document custodian.

F.       Record Destruction

Documents may be disposed of in a manner convenient to the person undertaking the destruction.  Documents with confidential, private, or sensitive information should be shredded.

G.     Policy Management

This policy will be reviewed on an annual basis by the Data & Record Retention Team.  The policy will be posted on the Carleton web site in the Campus Handbook; updates will be communicated on an annual basis.

 Document and Data Retention Periods

Core institutional database records (i.e. Ellucian Colleague; Ellucian Advance) are retained indefinitely; the retention period indicated below applies to paper records and ancillary files.  Ancillary files including documents on personal computers and other servers (i.e. Collab; OnBase).

Type of Record	Time Period for Retention	Document Custodian
Academic Department Records Concerning Students	6 Years from Graduation or date of last attendance	Registrar
Accounting		Business Office
Accounts Payable Ledgers and Supporting Documentation	5 Fiscal years
Accounts Receivable Ledgers and Supporting Documentation	5 Fiscal years
All Accounting Subsidiary Records	5 years
Annual Budget	Permanent
Annual Financial Reports	Permanent
Bank Reconciliations and Bank Statements	5 Fiscal Years
Capital Equipment Records (if purchased with federal funds)	3 Years after disposition of equipment
Capital Equipment Records (unless purchased with federal funds	Life of Asset
Cash Receipts/ Deposits	5 Fiscal Years
Depreciation Records	Life of Asset
Sales Tax Returns	6 Years
Other Student Loan Records (Perkins FSA HB Feb 2012)	3 Years after loan is paid in full, cancelled, or assigned elsewhere
Perkins Loan Files	10 Years after loan is paid in full, cancelled, or assigned elsewhere
Tax returns and worksheets	Permanent
Vendor Contracts	3 Years from completion of contract
W-9 on file for Vendor ________________________________________________ Grants	3 Years after last use ____________________ 3 Years from the date of submission of the final expenditure report (Optional: See 2 CFR 200.334 for more information)
Admissions Materials for Students Who Do Not Enroll
Financial Aid Records (Students who do not Enroll)	3 Years from end of academic year in which student applied	Student Financial Services
All other Admissions Materials	3 Years from end of academic year in which student applied	Admissions
Documents Supporting other Selection Decisions	3 Academic years from date of decision	Admissions
Federal/State Required Statistics and Reports	Permanent	Admissions
Admissions Materials for Students Who Enroll (see Student Records)	Permanent	Dean of Students
Alumni
Alumni Directories	Permanent	Alumni Relations Office
Alumni Newsletters/ News E-Mails	Permanent	Alumni Relations Office
Annual Fund Solicitations	Permanent	Alumni Annual Fund
Annual Fund Phonathon Materials	Permanent	Alumni Annual Fund
Alumni Database (Alumni, Parents; Friends)	Permanent	Development
Letters of Intent and Gift Agreements	Permanent	Business Office
Stewardship Reports	Permanent	Development
Prospect Reports	Permanent	Development
Art Museum		Gallery
Deed of Gifts	Permanent
Exhibition Contracts	Permanent
Exhibit Publications	Permanent
Purchases and Sale Documentation	Permanent
Career Center  and Career Placement Records	Permanent	Career Center College Archives
Corporate and Foundation Relations (CFR)
Grant Proposals	Permanent	CFR
Closed Grant File	Permanent	CFR
IDC Proposal and Supporting Documentation	Permanent	Business Office
Corporate Records		Office of the President Archives
Articles of Incorporation	Permanent
Bylaws	Permanent
Amendments	Permanent
Board of Trustees Minutes	Permanent
Board of Trustees Board Packets	Permanent
Records of College – Affiliated Enterprises	7 years after enterprise dissolution or after College ceases affiliation
Dean of the College
Academic Search Committee Materials (advertising materials, applicant files, Search Committee records)	3 Full academic years from year search completed	Dean of the College
Course Offerings/Course Catalogue	Permanent	Registrar
Faculty Handbook	Permanent	Dean of College
Faculty Tenure Records	Permanent	Dean of the College Archives with Restricted Access (evaluation pending)
Faculty Contract Renewal Materials, if denied	Permanent	Dean of College
Grievances	Permanent	Dean of College
Minutes of Faculty Meetings and other Governance Meetings	Permanent	Dean of College
Bonds, Tax Exempt		Business Office
Bond Closing Transcripts and Supporting Documentation	Term of Bond, plus 3 years	Business Office
Documents Relating to Capital Expenditures Financed or Refinanced with Bond Proceeds	Term of Bond, plus 3 years	Business Office
Record of Investments, Investment Agreements, Arbitrage Reports and Trustee Statements Related to the Bond Issuance and Expenditures	Term of Bond, plus 3 years	Business Office
Environmental Health and Safety Faculty Records	8 years	Facilities
External Relations
Commencement Programs	Permanent	External Relations
Press Releases	Permanent	Medial Relations
Sports Information Releases	Permanent	Sports Information
Human Resources		Human Resources
Affirmative Action/Equal Opportunity Officer Investigations, if denied	6 Years from academic year of last employment
Affirmative Action/Equal Opportunity Officer Investigations, if granted	Permanent
COBRA Notices and Enrollment Forms	6 Years after termination
Disability Benefits Records	Life of employee
Employee Personnel Files	6 Years after termination
ERISA Documents including Benefit Plan Descriptions & Summary Plan Documents	6 Years
Faculty CV’s and Personal Information Card	Permanent
FMLA Records	3 Years from end of leave
Medical Records & Records of Exposure to Toxic Substances	Length of Employment plus 30 years
Non – Academic Search Committee Materials (advertising materials, applicant files, interview records)	1 Year following search completed
Retirement Benefits Accrued	Life of employee or beneficiary
Sick Leave Benefits	Life of employee
Staff Handbook	Permanent
Workers’  Compensation Files	Life of employee
I9	3 Years after date of hire or 1 Year after employment ends whichever is LATER
Direct Deposit Authorization/Student Account Authorization	1 year after
Authorization	Employment ends
W4	4 Years after the end of the calendar year
Insurance		Risk Manager
Certificate of Insurance	7 Years after expiration
Insurance Policies	7 Years after expiration
Accident Reports and Claims	7 Years after case is settled
Litigation Records – Consent Orders, Judgments, Court Orders Disposing of Litigation, Releases and Settlement Agreements	Permanent
Litigation Records – Documents of Historical Significance (e.g. Trial Transcripts, Deposition Transcripts, and Trial and Litigation Records – Documents of Historical Significance (e.g. Trial Transcripts, Deposition Transcripts, and Trial and Deposition Exhibits in cases of significance to the history of the College)	Permanent
Investments		Investment Office
Subscription Agreements for Hedge Fund or Private Equity Investments	7 Years after termination
NACUBO Endowment Study	Permanent
Quarterly Valuation Reports	Permanent
Payroll		Business Office
Time Cards	5 Years after the end of the calendar year
Payroll Registers and Reports	5 Years after the end of the calendar year
International Students – Copies of Passport, VISA, I94, FNIS Backup	5 Years after the end of the calendar year
Wage Garnishments	5 Years after the end of the calendar year
W2	5 Years after the end of the calendar year
1042S	5 Years after the end of the calendar year
941	5 years after the end of the calendar year
Property and Facilities Records		Facilities
As Built Drawings	Permanent
Building Permits	1 Year after final Completion
Deeds	Permanent
Leases	5 Years from expiration of lease
Construction/Remodeling	Permanent
Plans and Specifications	Permanent
Purchase Agreements	Permanent
Routine Incidental Maintenance	3 Years from completion
Sale Agreements	Permanent
Title Insurance Policies	7 Years after sale of property
Publications
Carleton’s Magazine – The Voice	Permanent	Archives
Other Printed Publications	Permanent	Archives
Security		Security
Accident/Incident Reports	7 Years
Clery Act Logs	3 Years
Clery Act Statistics	3 Years
Clery Act Warning Notices	3 Years
Property Loss or Damage Reports	7 Years
Student Records – reference AACRAO’s Retention of Records:  Guide for Retention and Disposal of Student Records
Academic Standing Committee Actions (Dismissal, Suspension, etc.)	Until graduation or 2 Years after withdrawal 5 Years after suspension ; 10 Years after expulsion	Dean of Students
Academic Advising Files	1 Year after Carleton graduation or date of last attendance; policy currently varies department	Academic Advisor
Academic Records	Permanent	Dean of Students
Advanced Placement and other Placement Test Records/Scores	5 Years from Carleton graduation or date of last attendance	Registrar
Change of Grade Forms	Permanent	Registrar
Class Lists	Permanent	Registrar
Commencement Program	Permanent	Dean of Student Archives
Curriculum Change Authorizations	1 Year from Carleton graduation or date of last attendance	Dean of Students
Enrollment Verifications and Good Student Discount Insurance Authorizations	1 Year	Registrar
Requests for Non – Disclosure of Directory Information	1 Year from Carleton graduation or date of last attendance	Dean of Students
Dean’s Recommendations/Consent to Release Personally Identifiable Information	Later of 5 years from Carleton graduation or 2 years from date of request	Dean of Students
Financial Aid Records (students who enroll)	Total of 7 Years (4 years of enrollment + 3 years post graduation)	Student Financial Services Office
International Student Forms	10 Years from Carleton graduation or date of last attendance	International Student Programs
Medical Leave Agreements	1 Year from Carleton graduation or date of last attendance	Dean of Students
Name Change Authorization	Permanent	Registrar
Non-grad Letter	Permanent	Registrar
SAT/UNSAT Requests	4 Years from Carleton graduation	Registrar
Student Education File  – except for Admission Application, including Entrance Exam Reports, Advanced Placement Records; High School or other College Transcripts; Directory Information; Campus Job Evaluations; Notices of Awards or Honors; Evidence of Extracurricular Activities and other information provided by the student which is indicative of post-college activities, all of which is transferred to the Alumni Record maintained by Central Records permanently.	6 Years from Carleton graduation or date of last attendance	Dean of Students
Student Handbook	Permanent	Dean of Students
Student Health Records	8 Years from Carleton graduation or date of last attendance	Student Health & Counseling
Teaching Licensure Applications	Permanent	Registrar
Transcript Requests ( Registration Forms, Drop/Add, Pass/Fail or Registration Change Petitions)	Permanent	Registrar
Transcripts from Other Colleges and Consortia	Permanent	Registrar
Transfer Credit Evaluations	6 Years from Carleton graduation or date of last attendance	Registrar
Veterans Administration Certifications	3 Years after Carleton graduation or date of last attendance
Withdrawal Authorizations/Leave of Absence	Carleton graduation or two years after withdrawal from the College	Dean of Students
Information Technology – General Server Operation and Individuals’ Files Managed by ITS (Retention of other information Limited by Specifications listed elsewhere.)		Information Technology Services (ITS)
Server Data Retention – System Logs		ITS
Web server logs (which may include account names)	Log entries are kept for up to 1 year, after which general server backup retentions apply (see below).
Any log that associates a User ID (account name) or other Personal Identification with an IP address and/or access to any web page or other Network Service on or off campus, except where required to record financial transactions, etc.	Logs are recoverable between 90 days and 365, depending on system.  [Check with web server logs for exceptions]
Network audit logs	30 days.
Server Data Retention – Network Access Control System		ITS
Registration of Student – Owned computer’s MAC addresses	Minimum 90 Days after device last active on the campus network; old entries purged as needed.
IP/MAC address audit information	Indefinite
Server Data Retention – E-Mail Server (applies only to e-mail retained on the server)		ITS
E-Mail Inbox	Opened and unopened e-mail is retained on the server until deleted by the user or the account is closed (see “Account Closing”, below).
Sent Items	Until deleted by the user or account is closed.
Junk Items	30 Days or until deleted by users.
Trash Items	90 Days or until deleted by user.
Back-Ups of E-Mail Server	14 Days
Account Closing	Folders kept online for 1 year after account closing, with the exception of graduating seniors (30 days after graduation).  Above backups apply after that time.
Server Data Retention		ITS
Individual’s files in selected directories on the individual’s allocated desktop or notebook computer, initially set to back-up all personally created documents.	Periodic (not necessarily regular) review of client systems and removal of inactive or decommissioned systems.
Individual’s home directory on network share.	Data may be transferred to supervisor for saving or disposal.  Otherwise, folders kept online for 1 year after termination.  Backups below then apply.
Back-Ups of Other Servers (except as noted above)	Core institutional information systems: 1 year (fulls and incrementals).  Colleague and course folders: bi-yearly archives kept 7 years.  All other servers: 90 days (fulls and incrementals).
College – Owned Computers – Migration by individual to a Replacement Computer		ITS
Data files on old computer.	All files in predetermined locations on the hard drive are copied onto new computer (deleted files not restored unless requested by Client).
Old Computer Hard Drive	Faculty: removed drives kept by ITS for a period of a year or more.  Staff: drives kept 1-2 months then securely erased.
College – Owned Computers  – Employee Exit from the College (employment termination)		ITS
Computer and Hard Drive	If computer returned to stock, hard drive is re-imaged prior to re-deployment.  If computer is deployed to employee’s replacement, the hard drive contents may or may not be erased.

Last Revised: July 24, 2018

For: Faculty, Staff

Last Reviewed: March 1, 2021

Maintained by: Business Office

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