Title: #VII-6. Records Retention Guidelines

Date: October 14, 2011

I. Purpose and Scope

These guidelines provide for the systematic review, retention and destruction of documents received or created in the transaction of West Virginia University at Parkersburg business, and are designed to ensure compliance with federal and state laws and regulations, to eliminate accidental or innocent destruction of records and to facilitate college operations by promoting efficiency and reducing unnecessary storage of documents. These guidelines apply to all records of the college and to all college faculty and staff.

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WVU at Parkersburg retains and preserves vital records of its business and operations to preserve an historical record of the college, to ensure current and future operations, and to comply with its legal obligations.

II. Definitions

A. Active Records - Records that are generally referred to once a month or that are needed to support the current business activity of an office or division.

B. Disposition of Records - The terminal treatment of records, either through destruction or permanent storage.

C. Inactive Records - Records that have not been needed for at least one year or for which the active period has passed.

Unless these records (both active and inactive) have been defined as permanent or archival records they should be destroyed according to the time period shown on the retention schedule. Inactive records should be securely stored until the end of the retention period.

D. Litigation Hold - A communication issued as the result of current or anticipated litigation, audit, government investigation or other similar matter that suspends the normal process regarding the retention and disposition of college records.

E. Permanent Records - Also known as archival records, permanent records have historical, administrative, or research value to the college, which the college keeps indefinitely. Area administrators are responsible for ensuring that the college identifies these records and that they are stored appropriately once they become inactive.

F. Record - Anything containing information reflecting college educational and business transactions regardless of format (paper, digital, photographic, recordings, etc.). Typical records include official publications, fiscal data, incoming/outgoing correspondence including email, meeting minutes, reports, and student files.

Not all records must be retained. The list below describes items in a typical office that are not classified as records and therefore do not need to be categorized or maintained. These materials may be destroyed at any time if they are no longer needed by the office holding them. These items will not appear on a retention schedule:

· large quantities of duplicate materials and all duplicates of “official copies”

· magazines and newspapers not published by the college

· published reports produced by other entities

· purchased data from other sources

· catalogues, journals or other printed matter created by other entities used for informational purposes

· notes or working papers once a project is complete, unless they provide more complete information than the final report

G. Records Custodians – Individuals designated by unit administrators who have supervisory authority over a particular business practice, and, in that capacity, who have responsibility for ensuring effective implementation of these guidelines in their area of authority. See information on the responsibilities of Records Custodians in Section IV, part A.

H. Records Destruction - The physical or electronic destruction of a record after it has become obsolete or otherwise in accordance with these guidelines.

I. Retention Period - Minimum required length of time for which a college office or department is responsible for maintaining records. Custodians may hold records longer than the retention period if feasible and space allows.

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J. Retention Schedules - An internal document describing categories of records, providing a length of time they should be kept and includes instructions for disposition. State or federal law may determine the period that certain records must be kept. The General Retention Schedule at the end of this document lists the most common records at the college and provides a retention period along with any special instructions related to disposal. Almost every office or department will have records requiring retention that are not on the General Retention Schedule. Records that are not on this schedule should be added on a case by case basis.

III. Policy

A. Overview

It is the policy of WVU at Parkersburg to ensure that its records are preserved to provide documentation of the college’s history and to be retained for the periods of time necessary to satisfy the college’s business and legal obligations. The records will be disposed in accordance with an established records retention and disposition schedule. Certain records are permanent records and may never be destroyed.

A Records Custodian will oversee the day-to-day transactions related to the office’s records related functions and manage the disposition of records at the conclusion of the designated

retention period.

B. Email

Email sent or received over the college’s computer system may constitute a form of college record. While not all emails are business records, all college emails are property of the college and are subject to discovery in the event of litigation against the college or any of its faculty, staff, or students. Consequently, the administration has the ability and the right to view the email of all members of the college community.

Faculty and staff are not obligated to retain all emails indefinitely; such a policy would clearly impose an impossible burden both on the college community and on the college’s computer network. Rather, individual employees and faculty members are expected to exercise judgment regarding the content and purpose of the email in determining whether it needs to be retained as a college record, and, if so, the length of the retention period.

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Retention periods applicable to email messages are as follows:

1. Ordinary emails, including routine communications, internal meeting notices, and cover letters or transmittal memoranda, need be retained only so long as is necessary to complete the action or resolve the issue that is the subject of the email.

2. Administrative documents – To the extent that email is being used to document, either internally or outside the college community, the formulation, planning, implementation, interpretation or modification of a college program, policy or service, any such email constitutes a college record and shall be retained in accordance with the retention periods set forth in the

General Retention Schedule.

Emails can be retained in the following ways:

1. Emails can be printed out and filed and saved as paper documents;

2. Emails can be saved into electronic archive folders;

3. Emails can be saved on removable storage devices.

Regardless of the format in which the emails are saved, the Records Custodian for each office or division has an obligation to preserve and safeguard the information in the email as if it were a paper document. Once the email is saved in another format, however, there is no obligation additionally to retain the email in an active email folder.

C. Litigation Holds

Where the college has actual notice of litigation or of a government investigation or audit, or has reason to believe that such events are likely to occur, it has the obligation to take steps to preserve documents that might be implicated in such litigation or investigation. In such event, the college will take steps to identify all paper and digitally maintained files that may contain documents relevant to the case, including emails, and will notify members of the college community to preserve such documents indefinitely. If a faculty or staff member receives such a preservation notice, it does not necessarily mean that they are involved in the litigation or investigation. Rather, it means that the evidence that the college is required to preserve may be in the faculty or staff member’s possession or control, and that the employee or faculty member has an obligation to preserve such information effective immediately.

In the event of a litigation hold, all policies for the disposition of documents must be suspended with respect to those matters that are the subject of the hold. Electronic information should be preserved in its original electronic form on the media on which it is stored. Electronic information should not be transferred from the media on which it is stored to a different media for the duration of the litigation hold unless such transfer is necessary to preserve the integrity of the information for the duration of the hold, and such transfers should be made only after consultation with the IT department to preserve the integrity of the electronic data. In addition, the faculty and/or staff member that receives the notice shall similarly preserve any new information that is generated that may be relevant to the litigation or investigation by saving it in a segregated file. A faculty or staff member’s failure to preserve documents after having received a preservation notice can have extremely serious consequences for the college. Accordingly, a failure to comply with a litigation hold may subject employees to discipline, up to and including termination, and will be deemed misconduct that will subject faculty members to discipline in accordance with Board of Governors Policy B-02.

IV. Procedures

A. Essential Functions

1. Records Custodians

Each supervisor in a particular office or department has the responsibility for designating in writing a Records Custodian in their office or department and ensuring that the Custodian understands and is following the records retention requirements applicable to that particular unit. The supervisor is also required to sign off on either destruction of documents at the conclusion of their retention period or any transfer of records to storage.

The Records Custodian is expected to: understand the records created within the department or

office; follow these guidelines to make decisions on retention and disposition of records and provide guidance to others who are involved in preparing records for storage; be responsible for ensuring that everyone in the office is aware of these guidelines and follows them; establish the level of confidentiality and security appropriate to specific types of records and help the department or office maintain and monitor confidentiality and security.

2. Litigation Holds

The Special Assistant to the President is responsible for notifying all relevant members of the college community where a litigation hold is being implemented. He or she will, in consultation with the relevant members of the college community, determine the scope of the hold, will determine when the hold is no longer required, and will communicate the lifting of the hold on an as needed basis to members of the college community.

B. Accessibility and Safekeeping of Records

1. Records, especially financial records, must be easily retrievable for examination by authorized individuals, including auditors. Access to electronic records is subject to college rules regarding information security. Records Custodians should work with the IT department to ensure that electronic documents are maintained in a format that preserves accessibility.

2. The Records Custodian is responsible for ensuring that active and inactive records are secured in a way to provide appropriate confidentiality and protection from unauthorized inspection, theft, and/or physical damage.

C. Disposition of Records

1. The Records Custodian is responsible for periodically determining which college records in their particular office or department have reached the end of their retention period and should therefore be destroyed or transferred to storage.

2. The Records Custodian’s supervisor is required to sign off on the destruction of documents or transfer to storage.

3. Non-confidential paper records may be placed in containers for recycling. Confidential paper records must be shredded or other arrangements must be made for the documents to be destroyed.

4. The Records Custodian should consult with the IT department regarding the destruction of electronic documents.

D. Records Destruction

Following the established retention schedule records should be securely maintained for the period of retention either in the office or department where they were created or used. Records that have been identified as archival records must be permanently retained in a designated storage area.

Records that will not be listed on a retention schedule and therefore may be destroyed at any

time include:

· material that is not considered a “record” (see definition of record);

· duplicates of an official copy which is stored and retained by another office, such as personnel records, financial and budget information, copies of information used in an employee search;

· records that have served their purpose and are no longer needed, such as drafts of reports;

· and notes that have been turned into meeting minutes.

When there is doubt about whether a record may be destroyed, the custodian shall review the retention schedule or consult with the custodian of the official copy of the record if one exists.

Destruction includes:

Recycling – generally appropriate for all non-confidential paper documents, including public documents of other organizations, magazines, annual reports, newsletters, announcements, and drafts of policies or other memoranda which are not confidential.

Shredding – using a shredder for all documents that should not be read by others after they are no longer needed or that contain personnel or confidential information. This is essential for any document containing personal information, information that is student protected information under FERPA, health related information, or financial information.

V. General Retention Schedule

This schedule will NOT include all records that should be on a schedule. The Records Custodian’s supervisor should provide guidance regarding any federal or state rules when developing a retention schedule for records not mentioned here.

This schedule applies to all types of records, regardless of media or format, including documents, email, photographs, audiotapes, videotapes, CDs, and DVDs. Retention periods reflect minimum time periods. Records may be retained for longer periods of time at the discretion of the custodian or as required by legal counsel. Do not destroy any records while they are subject to audit, investigation, or where investigation is probable. Records that are in storage areas such as basements or attics are often at risk of water damage or destruction and should be evaluated in light of this schedule.

Internal Operations

General Type	Description	Retention Period	Comments
Board of Governors Records	Meeting minutes, agenda, reports, proposals, and supporting documentation	Permanent (President’s Office)	Archive on a regular schedule.
IRS Determination Letter	IRS Determination Letter	Permanent (Chief Financial Officer)
General Type	Description	Retention Period	Comments
Grievance Files	Documentation of grievances initiated by faculty and staff	Permanent (Human Resources).	Destruction of records in this category shall only be by shredder or other means that will make them unreadable.
Environmental Reports/OSHA Investigations	Investigation documentation or reports	Permanent (Safety Officer)
Insurance Policies	All policies in effect on behalf of the college, students, faculty and staff	Maintain as long as Active plus 7 years (CFO’s Office)
External and Internal Audit Records	Created by internal or external auditors to document their reviews, findings and recommendations	Permanent: Final report. Other records: Retain 3 years after creation of the audit records.	Destruction of records in this category shall only be by shredder or other means that will make them unreadable.
Real Property Leasing/Rental Records	Documentation of the lease and rental of property	Retain 7 years after expiration of the lease.	Destruction of records in this category shall only be by shredder or other means that will make them unreadable.
Social Security Reports and Deposits	Periodic reports of wages and social security contributions paid by the college to each employee	Permanent (CFO’s Office)	Destruction of records in this category shall only be by shredder or other means that will make them unreadable.
Unemployment Compensation Benefit Files and Reports	Documentation on eligibility of former employees for unemployment benefits and when these employees receive compensation charged against the college’s account	Retain for 5 years after termination of employee. (Human Resources)	Destruction of records in this category shall only be by shredder or other means that will make them unreadable.
W-2 Listings	Documentation of salaries paid and taxes withheld for employees	Permanent. (CFO’s Office)	Destruction of records in this category shall only be by shredder or other means that will make them unreadable.
Financial Aid Authorization/Allocation Letters	Awards of federal financial aid to the college	Permanent (Financial Aid and CFO’s Offices)
General Type	Description	Retention Period	Comments
Time Sheets	Documentation of hours worked by employees	Student workers: Retain for 7 years. Staff: Retain for 7 years.	Destruction of records in this category shall only be by shredder or other means that will make them unreadable.
Bank Records	Transactions recorded in the college bank accounts and their reconciliation to the general ledger.	Retain 7 years after end of fiscal year. (CFO’s Office)	Destruction of records in this category shall only be by shredder or other means that will make them unreadable.
Employee Benefit Plan Files	Documentation on employee enrollment in benefit plans	Permanent (Human Resources)	Destruction of records in this category shall only be by shredder or other means that will make them unreadable.
Staff Appraisals, Promotion, Demotion and Discharge Documentation	Records documenting periodic evaluation, work performance and employment record of college staff	Permanent (Human Resources)	Destruction of records in this category shall only be by shredder or other means that will make them unreadable.
Enforcement - Campus Parking Tickets	Citations issued and the administrative enforcement of parking rules and regulations. Issued by college Security.	Retain 3 years after final disposition.	Destruction of records in this category shall only be by shredder or other means that will make them unreadable.
Enforcement - Campus Incident Reports	Documentation of incidents that occur on campus that violate college and/or local laws and regulations. They contain case number, arrest report, incident report, date, time, complainant, address and details of the report (IAW Clery Act)	Permanent (Safety Officer)

Financial Records

General Type	Description	Retention Period	Comments
Financial Records - General	Budget worksheets, printouts, account books, ledger, purchase records, purchase orders, travel expense reports	7 years following the activity, or after legislative audit final report, whichever is later.	The CFO’s Office is the official custodian of these records. If the CFO’s Office has a copy of the record, the department may destroy its duplicate at the close of the budget reconciliation period. Destruction of records in this category shall only be by shredder or other means that will make them unreadable.
Financial Records – Warranty and Purchase Orders	Warranty information, purchase orders with contractual terms	7 years following the date of purchase or 7 years following the end of the warranty period, whichever is later.	Destruction of records in this category shall only be by shredder or other means that will make them unreadable
Financial Records – Debt Financing	All documents related to debt financing	20 years following the period of debt repayment (CFO’s Office)	Destruction of records in this category shall only be by shredder or other means that will make them unreadable
Financial Documentation	Tuition and fee schedules, annual endowment fund reports, annual financial statements, etc.	Permanent

Personnel Records

General Type	Description	Retention Period	Comments
Personnel Records	Documents related to employment, salary, benefits and performance evaluation.	Permanent (Human Resources)
Faculty Professional Papers	Records related to faculty teaching, curriculum, committee work, or biographical materials	Permanent	Store in archive
General Type	Description	Retention Period	Comments
Faculty and Staff Search Records	Vacancy announcement, advertisements, applications, evaluations, references, correspondence, email and all documents or materials related to the search.	3 years following the successful hire or close of the search without a hire. (Human Resources)	Destruction of records in this category shall only be by shredder or other means that will make them unreadable.

General College Records

General Type	Description	Retention Period	Comments
College Policies and Procedures	Forms, procedure manuals, guides, handbooks, etc.	Destroy when they are no longer in effect. President’s Office will retain policy documents permanently.
Projects, Programs, Proposals	Notes from meetings, reports, conceptual documents, financial support, all records related to projects or programs developed by non-academic offices.	Retain until a project has been completed and evaluate for permanent retention in the college archives.
College-wide Committee Records	Minutes, reports and other materials generated by college wide committees including charges, substantive correspondence and work product, and reports and documents about or related to the operation of college wide committees.	10 years	The chair of each committee is responsible for keeping and organizing a record of the committee’s work (minutes) and final recommendations and for transferring the records to the appointing administrator for college archives.

General Type	Description	Retention Period	Comments
President’s and Senior Administrative Officers’ Records	Records related to the functioning of senior administrative offices including calendars, memoranda, correspondence, speeches, memorabilia, photographs, web site information, etc.	Permanent	Archive on a regular basis.

Student Records

General Type	Description	Retention Period	Comments
Student Records – Admission Files	Application records for admission to the college created for undergraduate, and transfer student applicants. The files may include acceptance letters, letters of recommendation, placement records, transcripts, etc.	Permanent: Registered students. Retain 1 year: Unregistered applicants. (Registrar)	Upon matriculation, admission files become registrar files. However, some material such as letters of recommendation are removed. Destruction of records in this category shall only be by shredder or other means that will make them unreadable.
Student Records – Registrar	Student grades, transcripts, evaluations, and personal information (addresses, phone numbers, etc.)	Permanent (Registrar)	The official custodian of student records is the Registrar. .
Student Records – Graduation Lists	Lists of individuals who have successfully completed the degree requirements and have been graduated from the college	Permanent (Registrar)
Student Records – Registration	Documentation of a student’s course registration and changes to registration.	Retain 1 year after the student submits the change.

General Type	Description	Retention Period	Comments
Student Records – Financial Aid	Records showing evidence of providing financial aid including financial aid applications, federal student aid forms, federal tax forms, award letters and confirmations, verification records, interview records, students scholarships, and awards.	7 years after graduation or separation. (Federal regulation)	Before destroying records related to special awards or scholarships, evaluate for permanent retention. Destruction of records in this category shall only be by shredder or other means that will make them unreadable.
Student Records – Student Discipline	Records relating to proceedings and decisions resulting from violations of the Code of Student Conduct or other college policies.	Suspensions and expulsions retained with the student’s permanent record. All other, retained 7years.	Destruction of records in this category shall only be by shredder or other means that will make them unreadable.
Student Records – Activities and Government	Records related to student participation in special activities, student clubs, associations, and the Student Senate. Records related to any student organization or club.	Permanent: final publications, photographs, artwork, memorabilia, policies and administrative records. All other records: 3 years after their administrative use ceases.	Archive permanent records on a regular schedule. Destruction of records in this category shall only be by shredder or other means that will make them unreadable.
Student Records – Career Counseling Office	Records related to an individual student such as counseling notes and letters of recommendation.	3 years after administrative use ceases: Counseling notes. 10 years after inactivity: Letters of recommendation.

Faculty Group Records

General Type	Description	Retention Period	Comments
Faculty Group Records – General Office Records	Records related to the routine daily administration of the department including memoranda, meeting minutes, correspon- dence, and administra-tion of programs	Until no longer administratively useful.	Before destruction these records shall be evaluated for historical value.
General Type	Description	Retention Period	Comments
Course and Curriculum Records	Includes college catalogs/bulletins, course schedules, syllabi and course outlines	Permanent

Contract Records

General Type	Description	Retention Period	Comments
Contracts – Construction and Renovation	Records related to construction and renovation of real property	Permanent	Archive on a regular schedule.
Contracts – Negotiation Records, Executed Contracts	Records related to the process to enter into a contract or agreement, or understanding including background support materials, drafts, memos, letters, and related correspondence. The contract itself and all attachments and amendments to it.	Where contracts and agreements were finalized: 7 years after contract expiration. All other records: retain until administrative use ceases.
Capital Improvement Contract Records	Contractual agreements for capital improvements	Permanent (Director of Facilities and Grounds)
Grant and Contract Administration	Records related to the administration of federal and other grants, contracts, and agreements from negotiation to final performance such as grants-in-aid, state contracted services, and vendor contracts. Includes negotiation documentation, memoranda of understanding, agreements, contracts, amendments, terms, budget proposals, and related correspondence	7 years after final payment or completion of all obligations under the grant or contract and all subsequent renewals, whichever is later. Summary records such as proposal, award letter and selected deliverables and reports: Permanent	Records related to proposals that were not funded may be kept as long as administratively useful and then destroyed.

Addendum to General Retention Schedule

I. Personnel Records

The “official copy” of all records related to an employee are retained and maintained by the

Human Resources Office, with one exception: The official copy of all records pertaining to faculty promotion, tenure and evaluation are retained and maintained by the respective academic division offices.

Students who work in jobs that are NOT part of their educational experience are treated as all other employees for the purposes of record keeping. However, most students are paid to do jobs as a result of a financial aid award or as an integral part of their WVU at Parkersburg education. In that case, their employment information is maintained as a student record with the unique obligations associated with student records.

II. Employment Screening Committee Records

At the end of a search, the chair of a search committee should collect from each member of the committee all files, notes, applications, recommendations, and other material related to that search. This material should be reduced to one “official copy” of each record with the rest destroyed. All email and other electronic records should be printed and kept with other print documents and the e-copy deleted from the email system. All search committee members should delete all electronic files related to the search from their computers, email programs, and hard drives.

III. Records Related to Web Sites

Because web sites have replaced many publications they are a significant archival record of the college and its operation. Web masters and others creating web page content should capture copies of their web site’s content as electronic files and archive them for permanent retention.

IV. Electronic File Storage and Back-Ups

WVU Parkersburg shall strive to maintain systems and data operations to allow for access to the maximum extent possible.

In order to protect the systems and data owned and created by WVU Parkersburg; the WVU Parkersburg Office of Information Technology shall strive to create and maintain a regular and scheduled series of copies or backups of all WVU Parkersburg data that is stored on the network servers owned and operated by WVU Parkersburg.

WVU Parkersburg data backup procedure consists of, but is not limited to the following processes.

1. All servers shall be backed up using a “full-backup” process.

2. All WVU Parkersburg backups will be created using the departmentally established standard format.

3. All WVU Parkersburg backups will be written to a hard copy tape. Soft backups or any data stored on another server or in a non-static device will be considered a “working copy,” and not an official WVU Parkersburg backup.

4. All WVU Parkersburg backups shall be stored in a locked, fire-proof cabinet. Said cabinet shall be located in a reasonably secure locked room located in a campus building that is physically separate from the building housing the servers being backed up.

5. All server and network systems will be processed with a full-backup Monday through Friday. The backups will begin at approximately 9:00 p.m. and continue until complete-- usually until 6:00 a.m.

6. All backups will be kept and archived as per the following schedule:

· Tape sets will be created and maintained for each weekday, Monday through Friday.

· All tape sets used for Monday through Thursday will be kept for the current week and shall be overwritten the following week.

· Friday tape sets shall be created and kept for the entire calendar month in which they are created.

· The last Friday tape set for each calendar month shall be maintained and kept for the rest of the fiscal year.

· The last Friday tape set for the fiscal year shall be stored, labeled and archived for long term storage.

7. Data restoration operations shall only be performed when senior college management deems such operations necessary. A senior college administrator and the Chief Information Officer must concur that a data restoration from backup is the best option before such operations may commence.

Approved by the WV Department of Administration October 14, 2011.