University Record Retention Policy Policy # FA-002 Effective Date: June 1, 2009 Policy Statement Boston University requires that University records be retained for specific periods of time, and has designated official repositories for their maintenance. These records must be managed according to procedures that are outlined in this document. Reason for Policy Boston University is committed to effective records retention to preserve its history, ensure that critical records are available to meet business needs, comply with legal requirements, optimize the use of space, minimize the cost of record retention, and ensure that outdated and useless records are destroyed. Who Should Know This Policy? Any University staff responsible for the maintenance of records in any format, as well as all Boston University faculty and staff who create, store, or use University records in any format. Definitions Active Record: An original University Record currently used by the office, department or other area of the University that generated it. Active Records remain active for varying numbers of years, depending on the purpose for which they were created and regulatory requirements. Active Records may be retained in the originating office or at an offsite storage company. Active Records include records in all formats, including but not limited to: paper, fiche, digitized or scanned documents, electronic documents, and all other formats. Archival Record: An original University Record that has permanent or historic value, is inactive, and is not required to be retained in the office in which it originated or was received. Archival Records are retained and preserved indefinitely in the University Archives. The University s Records Administrator will make all final decisions concerning whether records will be preserved in the University Archives.
Definitions (continued) Electronic Record: A University Record kept in a non-tangible electronic format. Electronic Records include but are not limited to: word processor documents, spreadsheets, databases, HTML documents, scanned or imaged documents, and any other type of file warehoused online, on a mainframe, on a computer hard drive, or on any external storage medium (including disks and thumb drives). The same retention standards that apply to tangible University Records also apply to Electronic Records, and the retention periods outlined in the Record Retention Table apply equally to University Records in all formats. Fiche: A type of record format consisting of a flat sheet of microfilm, typically used for the purpose of maximizing space efficiency. University records kept on fiche are bound by the same standards and retention periods as records kept in paper or electronic formats. Inactive University Records: An original University Record that is not an Active Record but still must be maintained pursuant to the Record Retention Table set forth below. Inactive University Records are typically maintained at the University s preferred Offsite Storage vendor or at other locations on campus; however, Inactive University Records of historical significance are maintained by the University Archives as directed by the Records Administrator or its designee. Official Repository: The office or department designated as having responsibility for retention and timely destruction of particular types of official University Records. The University s Records Administrator, or designee, will make the final determination concerning the Official Repository for University Records. For example: The Payroll Office is the official repository for annual employee payroll records. There is no need for offices and departments that are not the Official Repository for a University Record to retain copies of those records. Offsite Storage: University Records that are in any format and are no longer needed may be stored with the University s preferred vendor for Offsite Storage. The Offsite Storage vendor provides a fee based service for picking up and maintaining inactive records, and also delivering those records if they are needed again on campus. See the Procedures section of this policy for instructions on how to store records at Offsite Storage. Personal Information: Records that include an individual s name together with that individual s Social Security Number; drivers license number or Massachusetts state identification card number; financial account number, or credit or debit card number, with or without any required security code, access code, personal identification number or password that would permit access to an individual s financial account; or biometric indicator. Personal Information is highly sensitive, and must be safeguarded and secured at all times. 2
Definitions (continued) Records Administrator: The University s Records Administrator shall be determined by the President, or the President s designated representative, and shall be initially the Vice President for Administrative Services. In consultation with the Executive Vice President and University Provost, the Records Administrator may designate certain policy implementation functions to other offices. Records Committee: The University s Records Administrator shall convene a Records Committee to develop procedures for the implementation of this Policy and to help ensure compliance. The Records Committee shall include representatives from the offices of the President, Information Systems and Technology, University Provost, Provost of the Medical Campus, Comptroller,, Internal Audit, University Registrar, Research Compliance, General Counsel, and any other office or department as the Records Administrator, in consultation with the Executive Vice President and the University Provost, deems appropriate, including representatives from the faculty. University Record: The original or official copy of any record/document, including Electronic Records, in any format. Formats include but are not limited to: paper, fiche, and electronic. The University s Records Administrator or its designee will make the final determination concerning the Official Repository for University Records and the Official Repositories for these records are identified in the table at the end of this document. There is no need for offices and departments that are not the Official Repository for a University Record to retain copies of those records. Responsibilities The University Records Administrator is responsible for the implementation of this Policy across all departments and units that maintain University Records in any format. The University Records Administrator shall oversee, with the assistance of the Records Committee, the implementation of this Policy, including by developing procedures concerning the review, oversight and governance of this Policy, and including any necessary training. Each unit manager or department head is responsible for implementing this Policy within his or her unit or department consistent with the procedures developed by the Records Administrator and the Records Committee. 3
General Statement of Procedures In consultation with and under the direction of the University Records Administrator or its designee, each unit manager or department head, or a designee, must: Determine the appropriate format for University Records under their area of responsibility. Implement the unit s and/or office s record management practices; Ensure that these management practices are consistent with this policy; Educate staff within the administrative unit in understanding sound record management practices; Preserve Inactive University Records (see the Definitions Section of this document) of historic value, and transfer those records to the University Archives; Ensure that access to confidential files and documents or electronic media that contain Personal Information is restricted in accordance with all University policies. Long term restrictions on access to selected Archival Records should be noted at the time of their transfer to the University Archives; and Destroy Inactive University Records that have no archival value upon passage of the applicable retention period. When the prescribed retention period (see the Record Retention Table) for University Records has passed, the unit s administrative manager should ensure that the records are properly disposed of unless the records are of historic value to the University. The administrative manager should consult the University Records Administrator to designate those records that are archival. Option A: Inactive University Records If you have determined that Active Records are no longer needed for business reasons but the applicable retention period has not yet expired, the Inactive University Records may be transferred to one of the University s preferred Offsite Storage vendors. Contact the University Records Administrator or its designee to: 1. Review records to be sent to Offsite Storage. 2. Request storage boxes (1 full file drawer = 2 boxes). 3. Request a transfer form from the University s preferred Offsite Storage vendor. 4. Schedule a time for boxes to be picked up. 4
General Statement of Procedures (Continued) Option B: Archival Records If you, in consultation with the University Records Administrator or its designee, have determined that you are in possession of Archival Records and the applicable retention period has expired, please forward those records to the University Archives. Option C: Non-Archival Records If you have determined that Active Records are not Archival Records and the applicable retention period has expired, you should destroy those records in one of the following ways: 1. Recycle non confidential paper records that do not contain Personal Information. 2. For records that contain Personal Information: a. Records must be redacted, burned, pulverized or shredded so that Personal Information cannot practicably be read or reconstructed; b. Electronic Records and other non-paper media containing Personal Information shall be destroyed or erased so that Personal Information cannot practicably be read or reconstructed. Contact the Office of Information Technology to ensure that electronic media are destroyed appropriately. Periodically review records generated and maintained in university information systems or equipment (including mainframe, mini, and micro computing/storage systems) to ensure that these requirements are met. The attached table (see Tools & References section) lists the official repositories for University Records as well as how long these records must be retained. Record retention periods may be increased by government regulation; judicial or administrative consent order, private or governmental contract, pending litigation or audit requirements. Such modifications supersede the requirements listed in this policy. The suspension of record destruction required by any of these reasons will be accomplished by a notice sent out to affected units by the General Counsel, the Office of Internal Audit, the Office of the Vice President for Financial Affairs, the Office of Research Administration or the Office of Sponsored Programs. No document list can be exhaustive. Questions regarding the retention period for any specific document or class of documents not included in these tables should be addressed to the University Records Administrator, its designee, or the Office 5
of the General Counsel. Departments and units that are not Official Repositories and that retain duplicate or multiple copies of these university records should dispose of them when the records are no longer useful (no later than the duration noted in this policy). Tools & References The Record Retention Table (located at the end of this document) Special Situations & Exclusions Amendments to the Record Retention Table: The Record Retention Table may be amended from time to time as approved by the Record Retention and Data Security Policy Committee, in consultation with the Executive Vice President or Provost, as appropriate. The Executive Vice President or Provost may refer any proposed amendment that raises a substantive issue to the appropriate committee. Contacts Electronic Media Storage Office of Information Technologies 595 Commonwealth Avenue, Room 658 Boston, Massachusetts 02215 (617) 353-2780 Offsite Storage of Inactive University Records RecordKeeper 57 Littlefield St. Avon, Massachusetts 02332 (508) 588-1919 Regulation Interpretations and Retention Period Inquiries Office of the General Counsel 125 Bay State Road Boston, Massachusetts 02215 (617) 353-2326 University Records Administrator Vice President for Administrative Services One Silber Way Boston, Massachusetts 02215 (617) 353-6500 6
I. Academic / Student Records Academic Integrity Code Violations School / College of Enrollment Record of final disposition for offenses that result in suspension or expulsion: permanent. All other records: 7 years. Academic Personnel Academic Search Records See Affirmative Action/Equal Opportunity Section Admissions Data for Applicants Who Enroll Admissions Data for Applicants Who Do Not Enroll, Whether Accepted or Rejected Advanced Placement Records and other Placement Test Records / Scores Admissions Office, Individual Graduate Admissions Offices Admissions Office, Individual Graduate Admissions Offices Registrar, Office of the University 5 years from graduation or date of last 1 year after acceptance/rejection date 5 years from graduation or date of last Annual Conflict of Interest Disclosure Statements Office of Research Compliance 5 years Applications for Graduation School / College of Enrollment 1 year after graduation or date of last Audit Authorizations and Records Registrar, Office of the University 1 year after date submitted Catalogs Change of Course Forms-Continuing Education, Summer Sessions, and Extramural Studies Registrar, Office of the University (exceptions: MED, SDM, LAW keep theirs) Office of Continuing Education and Summer Sessions 1 year after submission Change to Student University ID number (UID) Registrar, Office of the University Class Lists (original) Registrar, Office of the University Consent to Release Personally Identifiable Information (Requests for Non-Disclosure) Correspondence, relevant Registrar, Office of the University Admissions Office, Individual Graduate Admissions Offices Kept until next academic year; signatures kept 5 years 5 years from graduation or date of last Course Offerings Registrar, Office of the University Credit / no credit approvals (Audit, Pass/Fail, ect.) Registrar, Office of the University 1 year after date submitted Credit by Examination Records Registrar, Office of the University 5 years from graduation or date of last Curriculum Change Authorizations School / College of Enrollment 5 years from graduation or date of last Degree, Grade, and Enrollment Statistics Registrar, Office of the University Disciplinary Records - Students (findings of violation and related case files) Office of the Dean of Students for Student Records (See the Office of Human resources for employee records) Record of final disposition for offenses that result in suspension or expulsion: permanent. All other records: 7 years. Enrollment Verifications Registrar, Office of the University 1 year from enrollment date Entrance Exam Reports Financial Aid Records (applicants who enroll), including Federal Perkins Loan Records Admissions Office, Individual Graduate Admissions Offices Financial Assistance, Office of 5 years from graduation or date of last 5 years after the end of the award period Grade Change Forms Registrar, Office of the University
Grade Sheets Registrar, Office of the University Grade Books (Professors) School / College of Enrollment 5 years Graduation Lists Registrar, Office of the University International Student Forms (visa documentation, etc.) Letters of Recommendation (enrolled students) International Students and Scholars Office School / College of Enrollment 5 Years 5 years after graduation or date of last Name Changes Registrar, Office of the University 5 years after graduation or date of last Original Grade Sheets Registrar, Office of the University Patient Medical Records Student Health Services 30 years after final treatment Personnel Files, Appointment Letters and Forms See Section Racial / Ethnic Statistics Office of Institutional Research Recruitment Materials (enrolled students) School / College of Enrollment 5 years after graduation or date of last Residency Certificates (enrolled students) School / College of Enrollment Until date of enrollment Residency Change Documents (Non-resident to Resident) TBD 5 years from graduation or date of last Schedule of Classes (institutional) Registrar, Office of the University Student Class Schedules Registrar, Office of the University 1 year from graduation date or date of last Student Waivers for Right of Access (enrolled students) Admissions Office, Individual Graduate Admissions Offices Until graduation or date of last Suspensions and Dismissals School / College of Enrollment 5 years from graduation or date of last Tenure or Promotion Dossiers Office of the Provost If action approved, 3 years; If tenure denied, 7 years from end of term appointment Transcripts Transcripts High School and Other College (applicants who enroll) Registrar, Office of the University (exceptions: MED, SDM, LAW keep theirs) School / College of Enrollment 5 years from graduation or date of last Transfer Credit Evaluations Registrar, Office of the University 5 years from graduation Trustee Decisions Regarding Academic Personnel and Designated Executives Office of the Trustees Veteran Administration Certifications Registrar, Office of the University 5 years from graduation or date of last Withdrawal Authorizations/Leaves of Absence - Graduate and Professional School Students Graduate School/Professional School Registrar After graduation or date of last Withdrawal Authorizations/Leaves of Absence - Undergraduate Students University Service Center for Undergraduate Students 2 Years
II. Accounting & Finance Account Reconciliations (Balance Sheet) Appropriate Department Accounts Payable Vouchers and Attachments Accounts Payable Department 7Years Accounts Receivable Statements, Centrally Generated Accounts Receivable Statements, Unit Generated Miscellaneous Receivable Appropriate Department Annual Conflict of Interest Disclosure Statements Office of the Trustees 7 years Annual Financial Reports and Work Papers General Accounting Banking Records, Including Deposit and Withdrawal Records, Bank Statements and Reconciliation, Voided and Canceled checks General Accounting Billing Records Appropriate Department Capital Equipment Records Financial Affairs Life of Asset: records of equipment purchased on federal funds must be retained for three years after final disposition Cash Receipts University Cashier Depreciation Records General Accounting Life of Asset Effort Certifications Indirect Cost Rate Calculations Office of Sponsored Programs; Office of Research Administration Office of Sponsored Programs; Office of Research Administration Inventories Property Management Life of Asset Journal Entries General Accounting New Account Records and Back-up Documentation General Accounting 7 years after account closing Procurement Card Charge Documentation Departmental P-Card Administrator Travel Reimbursements and Attachments Accounts Payable Department University Audit Work Papers Internal Audit III. Alumni Affairs & Development Alumni Records Development; Gifts & Records Gift Records Development; Gifts & Records 7 years
Original Gift Letter Agreements, All others General Accounting/Development Planned Gifts (trusts, life income, agreements, annuities) Real Estate Gifts Development; Gifts & Records IV. Construction and Facilities Management As built Drawings Facilities Management and Planning Contracts and Agreements Facilities Management and Planning 14 years Records of repairs Facilities Management and Planning 7 years V. Corporate Records Accreditation Records Office of the President Articles of Incorporation Office of the Trustees Board of Trustee Minutes Office of the Trustees Bylaws Office of the Trustees Charter Office of the Trustees VI. Equal Opportunity / Affirmative Action Affirmative Action Plans /Office of Equal Opportunity Federal and State Required Statistics and Reports Non-Academic Search Materials and Documents Supporting Hiring Selection Decisions Appropriate Department 3 years from date of appointment Academic Search Materials and Documents Supporting Hiring Selection Decisions Complaints of Unlawful Discrimination and Harassment Appropriate Department / Office of Equal Opportunity 3 years from date of appointment
Certificates of Insurance, Indemnification agreements, Contracts and Insurance Policies for Benefits VII. Deceased Employee Claims 7 years after date of death Employee Personnel Files, Non-Faculty (including application, resume, appointment/salary forms, benefits enrollment and application forms, beneficiary designations) Faculty Benefits Applications and Paperwork, including Long-Term Disability Forms 7 years after separation 7 years after separation Faculty Personnel Files (including hire paperwork, salary records, status changes, tenure/promotion, retirement/termination, and appointment recommendations) School / College of Enrollment 7 years after separation Faculty and Staff Benefits Handbook Federal Reporting Requirements: Welfare Benefits and other Fringe Benefit Plans (i.e., 5500-s) Files for Disabled Employees 7 years after benefits end I 9 Forms (Faculty and Staff) 3 Years, or 1 year after separation (whichever is greater) I 9 Forms (Students) 3 Years after employment date, or 1 year after termination (whichever is greater) Individual Contracts of Employment 7 years after separation Occupational Injury or Illness, Records Relating to employment 5 Years Patient Medical Records Occupational Health Center 30 years after final treatment Performance Appraisals 7 years after separation Personnel Files for Retirees Records Covered Under HIPAA 7 years after employee's termination Search Committee Records, including employment applications, resumes, and all applicant search materials Severance Agreements 7 years after expiration Union Agreements Workers' Compensation Claims and Insurance Policies 18 Years
Certificates of Insurance, Indemnification Agreements, Hold Harmless Agreements, Contracts VIII. Insurance Office of Risk Management 7 years after expiration Insurance Policies (Liability, Property, and Other Policies) Office of Risk Management Incident Reports, Accident Reports Office of Risk Management 7 years after report date IX. Legal Consent Orders Office of the General Counsel Court Orders Office of the General Counsel Judgments Office of the General Counsel Releases Office of the General Counsel Settlements Office of the General Counsel Patient Medical Records X. Medical Records All units, centers or other entities that provide medical case 30 years after final treatment Copyright and Trademark Registrations XI. Patent, Trademark and Copyright Records Office of the General Counsel or Office of Technology Development Invention Assignment Forms Office of Technology Development Licensing Agreements Office of Technology Development after termination Original Patents and Related Work Papers Office of Technology Development Royalty Records Office of Technology Development Life of Patent or TM plus 7 years
XII. Payroll Annual Payment Records University Payroll Office Information Returns filed with Federal and State authorities (W-2, 941, 1042S, etc.) Payroll Deduction Authorization Forms (W4, ACH, Bonds) University Payroll Office University Payroll Office 7 years 5 years after employment ends Payroll Vouchers University Payroll Office 3 years Record of Payments and Deductions (payroll registers, deductions lists, adjustments) Time Cards, student University Payroll Office Appropriate Department/Electronic, Student Employment 5 years 3 years after pay date Time Cards, non-student Appropriate Department 3 years XIII. Public Safety; Environmental Health and Safety Accident Reports University Police 7 years after report date Crime Reports University Police 7years after report date Daily Log University Police Property Damage Reports University Police 7 years after report date Fume Hood Testing Records Environmental Health and Safety 3 Years Hazardous Waste Disposal Manifests and Reports Environmental Health and Safety 3 Years Incident Records Environmental Health and Safety 5 Years Radiation Safety Training Records Environmental Health and Safety 3 Years XIV. Purchasing Purchase Orders, Contracts, Agreements Purchasing Department 7 years
Property Deeds, Easements, Licenses, Rights of Way, Leases, Rights of First Refusal, Remainder Interests, Mortgages XV. Real Property Office of the General Counsel Property Tax Returns filed with taxing jurisdiction General Accounting Grant and Contract Applications, Proposals, and Supporting Documentation XVI. Sponsored Projects, Contracts & Grants Office of Sponsored Programs and Office of Research Administration 7 years after close of grant or longer if required by granting agency Records Concerning Human Subject Records Office of Research Compliance 7 years from completion of study or longer if required by study sponsor XVII. Taxes Excise Tax Returns General Accounting Information Returns (990, 1099, Form PC, etc.) Financial Affairs 20 Years Sales Tax Returns General Accounting