Records Retention (Policy OG-2)

The purpose of this policy is to ensure the integrity and security of all documents and records created, received, or maintained during institutional business. To protect the interests of faculty, employees, students and of the College. To facilitate appropriate access to such documents and records, preserve the confidentiality of such records, as applicable, and reduce the cost of records maintenance. To inform all faculty, employees, and administrators of Clarkson College of the standards, requirements and responsibilities for the management, retention, and disposition of all records of the College. This policy applies to all faculty and staff of Clarkson College, hereinafter called the “College.” 

Definitions

The term “record” under this policy means all documents and records, whether written, electronic, or recorded matter, regardless of its physical form or characteristics, that are created, produced, received or maintained by faculty, employees or component of the College during their activities for and/or on behalf of the College or in the transaction of College business. Examples include, but are not limited to; academic files, administrative files, student files, financial and accounting records, correspondence, books, papers, letters, memoranda, forms, charts, reports, maps, drawings, plans, photographs, films, spreadsheets, computer records, microfilm, microfiche, electronic files, electronic mail, data processing output in media, video recordings, audio recordings, and micrographics or any digitization magnetic tape or other electronic storage of any of these items.  

It is the policy of the College that all records subject to this policy are the property of the College and neither the personal property, nor the property of a specific department. That such records are maintained in accordance with all applicable laws and regulations, the requirements of accrediting and other external agencies, and the standards and procedure prescribed herein. That records that are no longer needed or of no value are discarded or disposed of, as specified in this policy. 
 
The College makes no claim to the original, intellectual property of faculty that was not created as part of their primary duties in teaching assigned courses, serving on committees, and other tasks assigned by College administration; unless extraordinary resources were provided and the College and faculty member negotiated and agreed to College ownership before work began. Examples include, but are not limited to; extensive lecture notes, books and articles, conference presentations and proceedings, works of fiction and nonfiction, poems and dramatic works, and pictorial and graphic works. This policy also does not apply to non-records which include preliminary drafts not circulated for comment, duplicate copies of correspondence, duplicate magazines, publications from professional organizations, newspapers, public telephone directories, electronic mail (e-mail) created during incidental use and transitory messages such as voice mail, telephone messages, self-sticking notes and other messages which are used primarily for the informal communication of information.  
 
Procedure: 

  1. General Principles and Responsibilities 
    1. All faculty and staff of the College are responsible for ensuring that all records are created, used, maintained, preserved, and disposed of in accordance with this policy. Electronic and computer records are to be managed consistent with the requirements for traditional records in compliance with this policy. 
    2. All records that are essential to the continued functioning or operations of the College during and after an emergency shall be retained and protected to ensure the College’s continued operations in the event of a natural or man-made disaster. 
    3. Records containing confidential and proprietary information shall be securely maintained, controlled, and protected to prevent unauthorized access. 
    4. The unauthorized use, removal, or destruction of records of the College is prohibited. 
    5. No record or document may be falsified or inappropriately altered in any manner. 
    6. Information pertaining to the unauthorized use, removal, or destruction of the College’s records or regarding falsifying or inappropriately altering information in a record or document should be reported to the Controller. 
  2. Maintenance of College Records
    1. All records shall be maintained and retained in accordance with federal and state laws and regulations, the requirements of accrediting and other external agencies, and the Records Retention Schedule herein (Attachment 1), and any subsequent amendments to such schedule. 
    2. All records shall be retained in a readable format regardless of changes in technology or equipment obsolescence. Printing out the documents and saving to a file system, maintaining the old equipment and software applications, or converting the records to new technology may meet this requirement. 
    3. Electronic mail (e-mail) communications, messages and documents transmitted by e-mail are subject to this policy, if otherwise in a paper format, and due to its contents they relate to duties and responsibilities for or on behalf of the College or in the transaction of College business. Such e-mail communications thereby must be retained consistent with the Record Retention Schedule in Attachment 1. Each e-mail user is responsible for sorting out messages subject to this policy and for the retention of such College records in compliance with the Records Retention Schedule in Attachment 1. The originator/sender of the e-mail message (or the recipient of a message if the sender is outside the College) is the person responsible for retaining the message. E-mail messages may be retained in electronic form in the mailbox for a period not to exceed ninety (90) days from its receipt or be printed and filed along with other documents related to the same topic or project. Users may delete e-mail messages that they are not required by this policy to retain (such as non-record  
      messages and transitory messages) and messages that are being retained in printed form.  
    4. Each department director shall serve as the Records Coordinator for their respective area. Each Records Coordinator shall be responsible for implementing and maintaining the records management program within their area consistent with this policy. Each Records Coordinator shall serve as a resource to answer questions regarding the retention and disposal of College records and provide training and guidance for all staff responsible for the execution of record retention and disposal procedures. 
    5. Each Records Coordinator shall prepare a listing of major records used and maintained by the department and shall compare it to the records listed in the Record Retention Schedule in Attachment 1. Any records not covered by the Record Retention Schedule under this policy shall be identified and submitted by the Records Coordinator in writing, together with the recommended retention for the prior approval, of the Records Retention Committee as provided below. 
    6. Each department head shall periodically, but not less than annually, review with the designated Records Coordinator currently used records to determine whether these records are adequate and appropriate for each department’s requirements.
    7. Each department director shall periodically, but not less than annually, review with the designated Records Coordinator the Record Retention Schedule in Attachment 1, to determine any special circumstances that necessitate changes in the retention periods. Requests for changes in retention periods or deviations from specified retention periods are to be submitted in writing to the Record Retention Committee and may be implemented only after its approval.
    8. All proposed changes, additions, or revisions to the Record Retention Schedule in Attachment 1 shall be submitted in writing to the Record Retention Committee for its initial review and approval. The Record Retention Committee, in consultation with the College’s Executive Leadership Team, shall research the legal, fiscal, administrative, and historical value of the records to determine the appropriate length of time the records will be retained. All approved changes will be incorporated into the Records Retention Schedule in Attachment 1 and distributed to the designated Records Coordinators. 
  3. Disposal of Records 
    1. Records that have satisfied their legal, fiscal, administrative, and archival requirements are to be disposed of or destroyed in accordance with the Records Retention Schedule in Attachment 1. 
    2. Records that cannot be destroyed include records with a permanent retention and records relating to or containing information regarding current, pending, threatened litigation or governmental investigation involving the College. In the event of a governmental audit, investigation, or current, pending, or threatened litigation or lawsuit, the College is under a legal obligation to preserve all relevant records pertaining to the issues. 
    3. Records must be destroyed in a manner that ensures the confidentiality of the records and renders the information no longer readable and recognizable as the College’s records prior to disposal.  
  4. The Records Retention Committee
    1. The Records Retention Committee is established to review and approve any proposed revisions, additions, and changes to the Record Retention Schedule in Attachment 1.  
    2. The Committee shall consist of the Vice President of Academic Affairs, the Vice President of Operations, the Controller, the College Registrar, the Human Resources Director, and other representatives as appropriate.  
    3. The Committee will meet annually, at a minimum.