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.
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 | Integrated Postsecondary Education Data System (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 |