Subject: Record Retention Practices

Issue 1

Effective 6/26/00

BACKGROUND

Records retention and disposition practices at the University are vital for the following reasons:

  • In the absence of practices for record retention, maintenance and destruction, a university may find itself storing records that are duplicates, obsolete or simply unnecessary. Indiscriminate records retention can result in significant unnecessary storage costs, misfiled records, inefficiency in wading through obsolete or irrelevant information, or increased exposure to litigation costs, lawsuits or damages;
  • Internal and external auditors require adequate records to fulfill audit requirements;
  • The universities require different types of information in order to develop institutional policies, to formulate strategic plans, and to manage day-to-day operations;
  • Various federal and state laws require that certain records be generated and kept for specific periods of time.

Attachment I presents the recommended minimum retention periods by major document category. Documents can be retained for longer periods, in accordance with operational or management needs. Note that it is likely that the universities will have record types that are not specifically stated in the list. Likewise, not all of the document types listed herein will be generated by each university. The category that most closely matches the record in question should be selected in the event that a specific category has not been defined.

SCOPE

This policy applies to all public and confidential records generated in the course of the universities’ operations, including both original documents and reproductions. It also applies to records stored on computer and microfiche as well as paper records.

Included is any written, printed, graphic, mechanical, or electronic data that has been received or prepared for use in connection with the transaction of university business.

LEGAL CONSIDERATIONS

For some record categories, the minimum length of time information is to be retained is defined by federal and state law. For example, federal student aid regulations dictate the type of information that must be obtained for each student and the length of time these records must be stored. Records of wages and salaries are required by the Internal Revenue Service, Department of Labor, Equal Employment Opportunity Commission, and by state revenue departments and employment commissions. Frequently, the same data is required by more than one governmental agency, each with different retention periods. In these cases, the records should be retained for the longest period to ensure that all laws have been complied with.

A systematic record retention and destruction program will reduce litigation costs and reduce exposure to liability. Since all records kept by an institution can be scrutinized when a lawsuit is threatened or has begun, a university that has not routinely destroyed obsolete records may be required to produce these as well, which may significantly increase legal costs. If old documents contain damaging information or are taken out of context, a university may be needlessly exposed to liability. When documents are destroyed according to an established policy, the courts will not assume that the records contained incriminating information as long as there is no anticipated or pending lawsuit.

EMPLOYMENT RECORDS

Employment records, including official personnel files, must be maintained and retained in accordance with collective bargaining contracts, University policies, and legal requirements. Supervisors should be cautious in creating unofficial records, such as notes in a supervisor’s file, because such records may be used to the detriment of the University. Supervisors should consult with the Human Resources office for guidance about employee performance and discipline issues.

STUDENT RECORDS

The Family Educational Rights and Privacy Act of 1974 (FERPA), known as the Buckley Amendment, governs the access to, disclosure and retention of some student records for institutions that receive Federal funding. The Act guarantees student access by requiring that current and formerly enrolled students be given the right to inspect and challenge certain records kept by an education institution. The Act also places restrictions on the disclosure of student records to third parties. The Act specifies the retention periods for recommendation letters, pass/fail requests, and student waivers of the right to see recommendation letters, and other documents.

E-MAIL

The candidness of e-mail messages has hurt more than one institution faced with a lawsuit, because the conduct of public business thru e-mail is a public record. To minimize the potential risk and cost associated with e-mail, e-mail should be used in a professional manner. Users should not use derogatory comments or obscenity and should keep in mind that the personal privacy of e-mail is not guaranteed.

If the content of an e-mail file falls within a document retention category, then the email record should be retained in either paper or electronic form for the period defined for that category.

ADMINISTRATION

The Office of Finance & Administration will periodically revisit the record retention practices and solicit input from the universities regarding the modification of this APL.

APPROVED: Vice Chancellor for Finance & Administration

ATTACHMENT I – UNIVERSITY OF MAINE SYSTEM RECORD RETENTION GUIDELINES

CATEGORY: HUMAN RESOURCES

RECORD GROUP DOCUMENT TYPE RETENTION PERIOD (IN YEARS)
Job Announcements & Ads Job Announcements & Ads 3
Applicants not Hired Employment Applications 3
Applicants not Hired Background Investigation 3
Applicants not Hired Resumes 3
Applicants not Hired Recommendation Letters 3
Applicants Hired Employment Applications Employment + 6
Applicants Hired Background Investigation Employment + 6
Applicants Hired Resumes Employment + 6
Applicants Hired Medical Examinations Employment + 6
Applicants Hired Recommendation Letters Employment + 6
Applicants Hired Immigration Records (I-9 Forms) Longer of : (Hire Date + 3) or (Termination Date + 1)
Faculty Files Correspondence Employment + 6
Faculty Files Student Course Evaluation Forms Employment + 6
Faculty Files Peer Review Documents (Evaluations) Employment + 6
Faculty Files Reviews of Publications Employment + 6
Faculty Files Tenure Records Employment + 6
Faculty Files Faculty Committee Evaluation Reports Employment + 6
HRS Master Tapes 10
Official Personnel Files Employment History Employment + 6
Official Personnel Files Educational Background Employment + 6
Official Personnel Files Emergency Contacts Employment + 6
Official Personnel Files Promotions Employment + 6
Official Personnel Files Attendance Records Employment + 6
Official Personnel Files Employee Evaluations Employment + 6
Official Personnel Files Transfers Employment + 6
Official Personnel Files Personnel Actions Employment + 6
Official Personnel Files Grievance Records 6 years from date of settlement/decision
Official Personnel Files Equal Opportunity (including Discrimination, Sexual Harassment) Complaints 6 years from date of settlement/decision or Accused’s separation + 6, whichever is longer.
Official Personnel Files Disciplinary Warnings and Actions Employment + 6 (unless otherwise specified in bargaining agreements or employee handbooks)
Official Personnel Files Layoff or Termination Employment + 6
Official Personnel Files Training Records Employment + 6
General Files Superseded Employee Manuals Permanent
General Files Superseded Job Descriptions 10
General Files Expired Collective Bargaining Agreements Permanent
Pension & Benefit Records Individual employee files Life of Employee + 4
Pension & Benefit Records Education Assistance Life of Employee
Pension & Benefit Records Vesting Life of Employee + 4
Pension & Benefit Records Defined Benefits Retirement Benefits Life of Employee + 4
Pension & Benefit Records Defined Contributions Retirement Benefits Life of Employee + 4
Pension & Benefit Records Disability Records Life of Employee + 4
Pension & Benefit Records Actuarial Records 6
Pension & Benefit Records Health, Life and Disability Insurance Plan Designs & Provisions Permanent
Pension & Benefit Records Retirement Plan Designs & Provisions & Summary Descriptions Permanent
Pension & Benefit Records Beneficiary Designation Employment + 6

CATEGORY: EMPLOYEE MEDICAL RECORDS

RECORD GROUP DOCUMENT TYPE RETENTION PERIOD (IN YEARS)
Health & Environmental Safety Medical Records Employment + 6
Health & Environmental Safety Hazardous Material Biological Monitoring (lead, arsenic, etc). Employment + 30
Health & Environmental Safety Accident Reports Permanent
Health & Environmental Safety Blood-borne Pathogens Vaccination/Declination Form Employment + 30
Health & Environmental Safety Medical records for Exposed Employees Employment + 30
Health & Environmental Safety Employee Exposure Records 30 years from date of exposure
Health & Environmental Safety Records of Employees Exposed to Blood Borne Pathogens Employment + 30
Health & Environmental Safety Analyses using Medical or Exposure records Employment + 30
Health & Environmental Safety Employee Safety Training Records The longer of 30 years or employment
Health & Environmental Safety Respirator Fit Testing Records 3
Health & Environmental Safety Blood Borne Pathogen Training Records 3
Health & Environmental Safety Noise Exposure Records 2
Health & Environmental Safety Occupational injury or illness records 6
Health & Environmental Safety Employee Medical Complaints 6

CATEGORY: STUDENT RECORDS

RECORD GROUP DOCUMENT TYPE RETENTION PERIOD (IN YEARS)
Attending Applicants Applications 5 years after last attendance
Attending Applicants Transcripts (high school or previous institution) 5 years after last attendance
Attending Applicants Entrance Exams and Placement Scores 5 years after last attendance
Attending Applicants Recommendation Letters Until Admitted
Attending Applicants Acceptance letters 5 years after last attendance
Attending Applicants Correspondence 5 years after last attendance
Non-Attending Applicants Applications 1 year after application term
Non-Attending Applicants Transcripts (high school or previous institution)  1 year after application term
Non-Attending Applicants Acceptance letters  1 year after application term
Non-Attending Applicants Correspondence  1 year after application term
Individual Student Records Course Add/Drop Slips 1
Individual Student Records Audit Authorizations 1 Year After Date Submitted
Individual Student Records Pass/Fail Requests 1
Individual Student Records Registration Forms 1
Individual Student Records Transcript Requests 1
Individual Student Records Withdrawal Records 2 Years after Graduation or Date last Attended.
Individual Student Records VA Certifications 3 Years after Graduation or Date last Attended.
Individual Student Records Academic Action Letters 5 Years after Graduation or Date last Attended.
Individual Student Records Relevant Correspondence 5 Years after Graduation or Date last Attended.
Individual Student Records Curriculum Change Authorizations (waivers, substitutions, etc.) 5 Years after Graduation or Date last Attended.
Individual Student Records Graduation Authorizations 5 Years after Graduation or Date last Attended.
Individual Student Records Disciplinary Files Separation + 3
Individual Student Records Student Dismissal Files Permanent
Individual Student Records Class Schedules Enrollment + 1
Individual Student Records FERPA Requests Life of Requested record (no records are required if records requested by the student)
Individual Student Records Personal Data Forms Enrollment + 1
Individual Student Records Application for Graduation Enrollment + 1
Individual Student Records Advanced Placement (Credit by Exam) 5 Years after Graduation or Date last Attended.
Individual Student Records Degree Audit Records (VA students) Enrollment + 5
Individual Student Records Transfer Credit Evaluations Enrollment + 5
Individual Student Records Name Change Authorizations Enrollment + 5
Individual Student Records Tuition and Fee Charges Enrollment + 5
Individual Student Records Foreign Student (I-20) forms Enrollment + 5
Individual Student Records Continuing Ed. Attendance Records Enrollment + 7
Individual Student Records Medical Records 10 years from date of last campus health center visit
Individual Student Records Date of Graduation and Degree Permanent
Individual Student Records Academic Records (Including transcripts & Continuing Ed Award Certificates) Permanent
General Student Records Applicant/Admission Statistics Permanent
General Student Records Admission Tapes 5
General Student Records Enrollment Tapes 10 years
General Student Records Enrollment Statistics Permanent
General Student Records Racial/Ethnic Statistics 10
General Student Records Degree Statistics Permanent
Financial Aid Records Campus-based and Pell Grant records 3 years from end of award year for which aid was awarded.
Financial Aid Records FISAP Reports 3 years from end of the award year in which report submitted.
Financial Aid Records Perkins and Nursing Loan repayment records 3 years from date loan assigned to the Department, cancelled or repaid.
Financial Aid Records Perkins and Nursing promissory notes Until loan is satisfied or as needed to enforce the obligation.
Financial Aid Records FFEL and Direct Loans eligibility and participation records 3 years from end of award year in which student last attended.
Financial Aid Records FFEL and Direct Loans – all other records 3 years from end of award year in which report is submitted.

CATEGORY: FINANCE

RECORD GROUP DOCUMENT TYPE RETENTION PERIOD (IN YEARS)
Accounting Records Description of application systems (FAST, A/P, A/R, etc.) Life of system
Accounting Records Fiscal Year-End FAST Master File Tape Current Year + 10
Accounting Records Journal Voucher source documents and backup 5
Accounting Records Journal Voucher Reports (JVREPT) 5
Accounting Records Transaction Detail (Both on magnetic tape and on fiche) Current Year + 10
Accounting Records Grants & Contracts (contract copies, budget backup, misc. correspondence) 3 years after completion of project, unless grant or contract specifies otherwise
Accounting Records Workpapers 10
Accounting Records Auditor’s Reports 10
Accounting Records A133 Financial Aid Audit Reports 3 years after resolution of open items.
Accounting Records Year-End AD043 – G/L Summary 10
Accounting Records Year-End AM052 – Revenue/Expense Statement 10
Accounting Records Chart of Accounts Until superseded + 2.
Accounting Records Daily Updates to Accounting System (retained by SWS) 1 year.
Accounts Payable/Purchasing Purchase Requisitions 4 + current
Accounts Payable/Purchasing Purchase Orders 4 + current
Accounts Payable/Purchasing Interdepartmental Orders (IDTs/IDOs) 4 + current
Accounts Payable/Purchasing Receiving Records (packing slips, bills of lading, etc.) 4 + current
Accounts Payable/Purchasing Invoices 4 + current
Accounts Payable/Purchasing Payment Records (Check Registers, etc.) 4 + current
Accounts Payable/Purchasing Expense Reports 4 + current
Accounts Payable/Purchasing Petty Cash Records 4 + current
Accounts Payable/Purchasing Cash Advance Records 4 + current
Accounts Payable/Purchasing Travel Advances 4 + current
Accounts Payable/Purchasing Travel Vouchers 4 + current
Accounts Payable/Purchasing Check Requests and Backup 4 + current
Accounts Payable/Purchasing Credit card charge slips, statements, and reports 4 + current
Accounts Payable/Purchasing Royalty Payments 4 + current
Accounts Payable/Purchasing Unemployment Insurance Payments 4 + current
Accounts Payable/Purchasing Workers Comp Insurance Payments 4 + current
Accounts Payable/Purchasing Invoice, Accounts Payable and Purchasing reports 4 + current
Accounts Payable/Purchasing Cancelled Checks 4 + current
Accounts Payable/Purchasing 1099-MISC Forms 4 + current
Accounts Receivable Invoice Copies 4 years after collection
Accounts Receivable Accounts Receivable Ledgers 4 years after collection
Accounts Receivable Cash Journals and Receipts 4 years after collection
Accounts Receivable Legal Correspondence 4 years after collection
Accounts Receivable Collection Notices and Records 4 years after collection
Accounts Receivable Records of payments receipts 4 years after collection
Accounts Receivable Records of uncollected accounts 4 years after collection
Cash Management Records Bank Statements and Reconciliations 3
Cash Management Records Short-term Investments (FNMAs, Freddie Macs, etc). 3
Cash Management Records Analysis of Bank compensating balances 3
Cash Management Records ACH transactions, wires 5
Cash Management Records Transfer Agreements Life of Agreement
Cash Management Records ACH Transfers & Prenotification Requests 7
Cash Management Records Cash Receipts, Cash Books, Deposits 3
Cash Management Records Revenue and State Bonds + Backup Permanent
Cash Management Records Investment Manager Reports 1
Cash Management Records Non-contributory retirement Investment Manager performance reports 10
Cash Management Records Custodian Reports (Year-End) 10
Cash Management Records Endowment Records Permanent
Budgeting Records Annual Financial Reports Permanent
Budgeting Records AMO61 – Year-end (Microfiche, paper, or disk) 10
Budgeting Records AMO90, AMO91 (Microfiche or disk) 5
Budgeting Records BUDSUM (Paper) 5
Budgeting Records Status Reports (Paper) 10
Budgeting Records Budget Change Transactions (Paper) 5
Budgeting Records IPEDS Reports 10
Payroll Records – General Wage Rate Tables 3
Payroll Records – General Benefits/Deductions Registers 6
Payroll Records – General Payroll/Human Resource Master File Updates 6
Payroll Records – General Payroll Register & Payroll Register Summary (EBC340) 6
Payroll Records – General Gross Calculation Registers (EBC310) 6
Payroll Records – General Payroll Calculation Diagnostics & Analysis & Extract Reports 6
Payroll Records – General Check Registers 6
Payroll Records – General Time Input Reports 6
Payroll Records – General Accounting Detail from Payroll System (Microfiche) 6
Payroll Records – Employee Files Wage or Salary History 6
Payroll Records – Employee Files Salary or Current Rate of Pay 6
Payroll Records – Employee Files Disability & Sick Leave Benefits Life of Employee
Payroll Records – Employee Files Payroll Deductions 6
Payroll Records – Employee Files Time Cards or Sheets 5
Payroll Records – Employee Files W-2/1042-S Forms 6
Payroll Records – Employee Files W-4 Forms 6
Payroll Records – Employee Files Garnishments Employment
Buildings Capital Construction Project Contracts, Final Payment Records, Materials and Equipment information and correspondence Life of Building + 4 years
Buildings Building, and Site Plan Specifications Life of Building + 4 years
Buildings Acquisition date and cost data; mortgages, improvement and repair records; records of sales; depreciation schedules; grant number, if applicable Life of Building + 4 years
Buildings Building, Zoning Permits 1 year after completion of construction
Equipment (Capitalizable) Acquisition Date and Cost; description, location of the equipment; identification and/or serial numbers; grant number, if applicable; depreciation schedules, and records of disposals or sales. Life of equipment + 4 years
Other Equipment Noncapitalizable equipment The longer of life of equipment or 3 years.
Health and Safety Environmental Records Hazardous Material Spill Reports Permanent
Health and Safety Environmental Records Accident Reports Permanent
Health and Safety Environmental Records Fire Incident Reports Permanent
Health and Safety Environmental Records Hazardous Waste Records, including Manifests or Waste shipment records. Permanent
Health and Safety Environmental Records Air monitoring (hazardous gases) or area sampling (asbestos, lead, etc.) 30
Health and Safety Environmental Records Chemical inventories and lists 30
Health and Safety Environmental Records Process Safety Incident Investigation Reports 5
Health and Safety Environmental Records OSHA 200 Injury and Illness logs 5
Health and Safety Environmental Records Inspection Reports (spill prevention, fire alarms, fire extinguishers, etc) 3
Insurance Liability and Property Insurance Claims 10 years after settlement.

CATEGORY: FINANCE

RECORD GROUP DOCUMENT TYPE RETENTION PERIOD (IN YEARS)
Insurance Liability and Property Insurance incident reports 7 years unless resulting in a claim.
Other Operating Permits (eg, elevator) Current year plus 1
Other Maintenance Records Life of equipment or building
Other Motor Vehicle Records Life of vehicle
Other Air or Waste Water Emissions 3

CATEGORY: INSTITUTIONAL

RECORD GROUP DOCUMENT TYPE RETENTION PERIOD (IN YEARS)
Alumni Data Alumni Publications*

* Alumni publications are one of the document types subject to Internal Revenue Service inspection during an audit.

4 years from publication
Alumni Data Alumni Information**

**Information kept on former students typically includes: Name, Class, Year of Graduation and degree, home address and phone number, record of college activities, employment, position, address and phone number, and name of spouse and children.

Until former student’s death
Institutional Publications*

*Institutional publications are also subject to Internal Revenue Service inspection during an audit.

Bulletins and Course Catalogs 15
Institutional Publications* Student Newspapers 4
Institutional Publications* Student and Employee Directories 5
Gift Records Cash Gifts At least 4, no more than 7 years
Gift Records Non-Cash Gifts (stock, mutual fund shares, bonds real estate, etc.) Time gift possessed + 4 years
Gift Records Gift fund descriptions Permanent
Other Articles of Incorporation Permanent
Other By-Laws Permanent
Other Board of Trustees Minutes Permanent
Other Board of Trustees Committee Meetings Minutes Permanent
Other Licenses Current + 6
Other Deeds and Titles Permanent
Litigation Files Attorney Opinion Letters Applicable + 6
Litigation Files Leases Applicable + 6
Litigation Files Policy Statements 10
Litigation Files Campus Crime Reports – Annual (1990 Security Act) 4
Litigation Files Campus Crime Reports – Interim (when a major crime occurs) 3
Litigation Files Contracts Applicable + 6
Litigation Files Patent Records Permanent
Litigation Files Trademark Records Permanent
Litigation Files Claims Until suit fully resolved
Litigation Files Court Documents and Records (complaints, answers, motions, pleadings, etc.) Until suit fully resolved
Litigation Files Correspondence with Counsel Until suit fully resolved
Litigation Files Orders issued by the court Until suit fully resolved
Litigation Files Depositions, transcripts, interrogatories, answers to the interrogatories, requests for documents, the requested documents, and other discovery materials. Until suit fully resolved

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