Policy 2708: Managing University Records

Subject Area: Miscellaneous
Responsible Office: The Office of Legal Counsel
Sponsor: Vice President and General Counsel
Originally Issued: June 2009
Revised: N/A
Refer Questions To: The Office of Legal Counsel

Purpose: This policy sets forth a general framework for meeting the University’s obligations to review, retain, and destroy University records consistent with laws, regulations, and internal University recordkeeping objectives that may change from time to time. This policy is intended to supplement rather than supersede the current document retention and destruction policies of any academic or administrative department of the University. Please contact the Office of Legal Counsel if any such existing policies conflict with the guidance in this policy.

Applicability: This policy applies to all academic and administrative departments of the University and all University employees having a responsibility to maintain or destroy University records.

Scope: This policy applies to all University records, which means any documents generated, received, or maintained in connection with any operations of the University. Typically, personal documents (including e-mails) of non-employees subject to the University’s Eligibility and Acceptable Use Policy are not considered to be University records. For guidance on electronic discovery, see Policy 2709, Electronic University Records Relevant to Pending or Anticipated Litigation.


This policy sets forth general categories of University records and provides general retention guidelines for each category. Notwithstanding these general guidelines, each academic and administrative department is responsible for: (i) identifying all laws and regulations that apply to its own recordkeeping; (ii) notifying the Office of Legal Counsel of all such laws and regulations and recommending revisions or additions to these requirements as appropriate; (iii) monitoring its own compliance; (iv) destroying documents in an appropriately secure and effective manner; and (v) documenting compliance with this policy, particularly with respect to the storage and destruction of University records.

Revisions or additions to the following requirements will be made by the Office of Legal Counsel in consultation with the Chief Financial Officer and the Assistant Vice President of the Office of Risk Management and Safety.

Except in unusual situations approved by the Office of Legal Counsel in consultation with the Chief Financial Officer and the Assistant Vice President of the Office of Risk Management and Safety, the costs of reviewing, retaining, and destroying University records pursuant to this Policy will be borne by the academic or administrative department that maintains the records at issue.

Employees who knowingly fail to comply with this Policy or any other departmental document retention and destruction policy may be subject to discipline.

Academic Program Records
       Accreditation and licensing Permanent
  Catalogs and course descriptions Permanent
  Dissertations and terminal Master’s theses (undergraduate theses included only if prize-winning) Permanent
  Degrees awarded Permanent
Accounting, Banking, Budget, Finance, and Tax Records
  Annual audits, financial statements, related workpapers Permanent
  Banking: accounts payable, accounts receivable, fund transfers, 1099 forms, deposit slips, check registers, electronic fund transfer records 7 years
  Bank statements and reconciliations 3 years
  Bond financing 7 years after payment in full
  Budget reports Permanent
  Expenses 7 years
  Cash and credit card receipts, petty cash vouchers 3 years
  Depreciation schedules Permanent
  General Ledgers Permanent
  Invoices 7 years
  Investment and endowment records Permanent
  Journal entries 7 years
  Purchasing and procurement 10 years after completion
  Quarterly financial management reports 3 years
  Student accounts receivable Permanent
  University tax returns, information returns, applications for tax-exempt status, IRS correspondence, audits Permanent
Corporate Records  
  Annual Reports Permanent
  Articles of Incorporation, Bylaws Permanent
  Board of Trustees and Board Committee policies, resolutions, minutes Permanent
  Construction drawings and plans Permanent
  Contracts, after performance or termination 10 years
  Fixed assets Permanent
Development and Alumni Records  
  Alumni records Permanent
  Fundraising Permanent
  Gift and trust agreements and related correspondence Permanent
Employment and Benefits Records  
  Accident and Worker’s Compensation 5 years
  Affirmative Action plan documents and reports Permanent
  Employment applications 3 years
  Employment and separation agreements Permanent
  Grievances and complaints 7 years if finding of no cause; all others, permanent
  Immigration records (e.g., I-9 forms) 3 years after separation
  Insurance and benefit plans 7 years
  Occupational injury or illness 5 years after separation
  Payroll registers, payroll tax returns Permanent
  Personnel files 10 years after separation
  Evaluation, promotion, discipline, and discharge 10 years after separation
  Retirement and pension plan documentation Permanent
  Search committee records 5 years
  Earnings, withholding, and deductions 7 years; year-end records (e.g., W-2, 1099), permanent
  Tenure and promotion of faculty Permanent
  Time cards 7 years
  Union contracts Permanent
  Unemployment taxes Permanent
Legal, Intellectual Property, Risk Management, and Safety Records
  Conflict of interest (trustees, officers, senior administrators) Permanent
  Contracts, after performance, termination, or expiration 10 years
  Accidents, crimes, and emergencies 7 years
  Environmental and hazardous materials reports, studies, and remediation Permanent
  Insurance policies Permanent
  Litigation judgments, settlement agreements, and consent decrees Permanent
  Leases, after expiration or termination 6 years
  OSHA documents 5 years
  Patent, copyright, and trademark applications, maintenance costs, and royalty records Permanent
  Permits, approvals, and licenses 7 years after expiration
  Real estate and fixed asset records Permanent
Publications, Libraries, and Archives
  Awards and published book editing files Permanent
  Editing files for rejected books, marketing files, production documents, and advisory board records 7 years
  Journal editorial records, advertising records, circulation files 5 years
  Publication agreements and permissions to reproduce Permanent
Museums and Galleries  
  Accession, acquisition, appraisal records, inventories, exhibit records, insurance records, and administrative reports Permanent
  Loan records 10 years after return
Research Records  
  Grant and contract applications for sponsored research 7 years after completion of research
  Human subject and animal research Permanent
  Research logs and data 7 years after completion of research
Student Records  
  Admissions applications 5 years from graduation or date of last attendance, 2 years if not enrolled
  Academic records (transcripts are permanent) 5 years
  Career advising 3 years
  Discipline records 5 years from last incident, permanent if involves suspension or expulsion
  Student affairs, extracurricular activities and athletics 6 years
  Housing records 5 years after graduation or last attendance
  Financial aid, student loan, and scholarship records 4 years after later of graduation or payoff
  Disability accommodation records 7 years
  Tuition and expense payment records 8 years