65.02 - Records Inventory, Retention and Disposition
May 13, 2015
A-1. Records Defined. Records are defined as recorded information, in any form, including data in computer systems, created or received and maintained by an organization or person at or near the time of the transaction of business or the conduct of affairs and kept as evidence of such activity.
a. Confidential Records. Information whose release is restricted because of statute, regulation or other legal requirements. Examples include medical information, credit information, or student information. Confidential records are clearly defined by the Family Educational Rights and Privacy Act (FERPA) and the Idaho Public Records laws. [add. 5-15]
b. Non-Record Documents. Duplicate copies of final reports, printouts or copies of permanent files made for reference, distribution copies of a publication, or routing copies of a memo or letter are all considered non-records. Material acquired solely for the purpose of reference, that is, copies of other institutions' course catalog, programs from meetings, etc., are also non-records and should be appropriately disposed of once they are no longer useful and/or past the record copy destruction date.
c. Record Copies. Because many records have multiple formats or are maintained in duplicate elsewhere, retention periods [see E-1] should be construed to apply only to the "record copy", which is that copy designated by the unit of origin (originating office) as the "record copy". All other copies are merely working documents and should be appropriately disposed of once they are no longer useful and/or past the record copy destruction date.
d. Sensitive Records. Information whose release is restricted because of organizational policy or procedures or industry practice. No statute, regulation or other legal provision necessarily prohibits the release of sensitive information. However, unauthorized release of sensitive information may cause damage to reputation or status of an individual or organization and may result in loss of income or opportunity. Examples include personally identifiable information, intellectual property, and proprietary materials such as class test materials, marketing plans, budget data, routine correspondence, or unprotected personal information. [add. 5-15]
A-2. Scope. Records management policies and procedures pertain to university records, regardless of media. These records may be electronically stored information, paper or microfilm records, magnetic tapes, or other media (see also FSH 1470).
A-3. Responsibility. Records generated by a unit during the course of business are the responsibility of the unit of origin. In managing records, units shall:
- Retain records according to the UI records retention schedule (see C-1).
- Maintain active and inactive records in appropriate locations.
- Identify and protect vital records (those records essential for carrying out our mission).
- Ensure confidentiality of protected records
- Dispose of records that are no longer being used and are not required to be retained by retention policy, legal holds, or other business reasons. [ed. 5-15]
- Retain an inventory of records they have generated or are in their custody, and shall be able to provide a complete inventory of those records to General Counsel within 10 working days, upon receipt of an inventory request.
B-1. Records are retained pursuant to their official retention schedules [see C-1].
B-2. Active records are maintained in the unit of origin.
B-3. Once records are no longer actively used in the offices where they originated, records coordinators are responsible for transferring records to the Finance and Administration records center, where they are retained for the balance of their retention period. Records needed only for short duration should be destroyed or recycled by the office according to the approved schedules. Records which have been transferred to the Records Center may be accessed by the unit of origin, or others authorized by that unit. Records whose retention period has passed, and which have no legal holds on them, shall be disposed of pursuant to University of Idaho policy [see C-6]. [ed. 5-15]
C-1. Records Retention Schedule. The University of Idaho retention schedule is based on the Higher Education Retention Schedule adopted by the State Board of Education of the State of Idaho (SBOE retention schedule) and the Board of Regents of the University of Idaho. The University of Idaho retention schedule is maintained by the University of Idaho Records Management. The University of Idaho retention schedule is available at the Records Management website.
C-2. Records Retention Guidance. This section provides guidance for records retention by general record type, for records series that have not yet been incorporated into the University of Idaho Records Retention Schedule (see C-1). This is intended to be a general guide to be used pending specific record series identification and retention establishment. For guidance related to retention of specific records series refer to the University of Idaho retention schedule, available at the Records Management website.
If you believe that records you maintain should be kept longer than the retention periods specified below for various reasons (example: external audit requirements, federal regulations, etc.) please contact Records Management in order to document your record types and retentions in the UI Records Retention Schedule (see C-3). Note: these guidelines apply only to the record copies (see A-1 a) of various record types. Working copies and non-record copies (see A-1 b) should be disposed of as soon as they cease to be useful, and no later than the retention period for the record copy.
a. Financial Records:
- Routine Transactions:
- Travel authorizations, reimbursement requests, and purchasing and cash handling records all share the same retention period: Temporary. Hold until end of fiscal year of creation + 3 years.
- Budget files:
- Calculations, drafts, and final version copies. Temporary. Hold until fiscal year end (June 30th) + 3 years, then destroy.
- Records for contractual services and programs (ex: guest speakers). Temporary. Hold until end of contract + 3 years, then destroy.
- Grants documentation:
- Financial and personnel records. Temporary. Hold until end of Grant period or last contact related to the grant + 3 years, then destroy. [rev. 5-15]
- Final project and periodic reports, as well as initial proposals (if available). Permanent. Retain in office of origin until infrequent use warrants long term storage, then transfer to University Archives.
b. Unit/Administrative Records:
- Correspondence, including email:
- Informal/routine - meeting notices, availability of a resource, when co-worker will be back, general announcements - Temporary. Destroy 3 years after close of fiscal year of creation.
- Formal - typically signed by the unit administrator, includes letters, memos and emails related to accreditation, curriculum, programmatic changes, re-evaluation of course credits, petitions, etc. Also includes letters describing the work of the unit and its deadlines and deliverables. Permanent. Transfer a copy to University Archives.
- Meeting Minutes:
- Those that originate within the unit – applies to all original minutes (see FSH 1470 C-7). Permanent. Organize in year, date order. Transfer to University Archives when infrequent use warrants long term storage.
- Brochures, flyers, etc., promoting the services of the unit. Newsletters. Some presentations, depending on the event or use. Reports, statistical analyses, syllabus, etc. Permanent. Transfer two copies to University Archives.
- Time sheets:
- Faculty/staff/temps and regular students - Temporary. Keep for 3 years after the close of the fiscal year of creation, then destroy confidentially. Note: payroll information entered into Banner is regarded as the record copy of evidence of hours worked, and is subject to a 50 year retention. The documentation of the information entered into Banner (i.e. time sheets) are supporting documents and need only be kept for the period designated above. Note that time sheets documenting time worked prior to the implementation of Banner (July 1994) must be retained the full 50 years.Exception: When a position is entirely or partially paid out of grant funds - then maintain these time sheets for the same period as grant files.
- Performance Evaluations:
- Staff, temps and regular students - [Permanent]. File the originals with HR, who will keep it permanently. Any copies kept at the unit are working copies, and should be confidentially destroyed of when no longer needed.
- Emergency contact, copy of certification, committee appointments, schedule information. Temporary. Confidentially destroy 5 years after last date of employment.
d. Student Records:
- Student Files include but are not limited to - emergency contact list, unit policy signoff w/computer use form, student handbook furnished form, prerequisite forms (each semester), unofficial transcripts. Temporary. Maintain all of the above student records for 5 years after date of graduation or date last enrolled, and then destroy confidentially.
- Consent for release of information - Permanent. Transfer to Registrar for collation into student's permanent file. Remove from file prior to shredding of other documents in Student file.
- Interview file - students seeing corporate recruiters- May include resume, appointment times, etc. Temporary. Keep no more than one year from date of interview. Destroy confidentially.
- Credentialing Materials - records used to certify that a student has fulfilled their program-specific requirements to the satisfaction of the related accrediting organization or licensing agency. While temporary, these records must be maintained until the end of the students' average working life. The University of Idaho currently considers this to be 50-years. Units that create credentialing records may set these materials aside when purging student files. UI Records Management and the Records Center can help with storage. Estimated based on the US Census average retirement age of 68 years, or until such time as the relevant oversight agencies establish a different status. NOTE: These records are protected from release per FERPA and must have student approval. 50 years
C-3. Establishing a specific records series in the University of Idaho retention schedule.
a. Determining Retention Periods on New Records Series. If there is no defined retention period for a particular record series:
1) Records Management investigates the current UI retention schedule, applicable state and federal statutes, internal and external audit requirements, and Regents' and university policy manuals (also see FSH 1470) , to identify the retention period required by law, rule, regulation or policy. [ren. 5-15]
2) Records Management consults with the unit administrator and/or unit records coordinator to determine the administrative rationale for keeping records beyond any external legal or audit requirements. [ren. & rev. 5-15]
3) Records Management consults with the University Archivist to determine if a record has a long-term evidential or informational value to decision-makers or researchers. [ren. 5-15]
4) Records Management updates the University of Idaho retention schedule, to include the new series, its retention, and vital and archival characteristics and submits it for validation and recognition by the State Records Manager. [ren. & rev. 5-15]
b. Altering Retention Periods for Series. Units may request that their record series be retained for a longer period than specified by the SBOE retention schedule, but not a shorter period. Such requests will be reviewed by Records Management, and if approved, the change to the retention period for that series will be made to the University of Idaho retention schedule.
C-4. Legal Holds. General Counsel may at their discretion place a legal hold on any University records. In that case the retention schedule for those records is suspended, and disposal shall not take place until the legal hold is removed by General Counsel.
C-5. Destruction of Records of Unknown Series. The University of Idaho retention schedule contains categories (series groups) that apply to most University of Idaho records, including those series that have not been identified to Records Management and therefore not included specifically in the University of Idaho Retention Schedule. Before destroying records whose retention periods you are not certain about, consult with Records Management, Pitman Center (Bruce M. Pitman Center) Room 53, (208) 885-2580, records email.
C-6. Disposition of Records upon Expiration of Retention Period.
a. Methods of Disposal. There are two broad mechanisms for disposing of records after their retention and all relevant holds have expired: disposing of them (in the case of sensitive or confidential records, irretrievably destroying them), or transferring ownership of them to University Archives.
1) Disposal of Records. Records of a non-sensitive, non-confidential nature may be disposed of by any means deemed appropriate. Where possible, recycling is preferred, although disposing, deleting or recycling are all acceptable.
2) Destruction of Confidential or Sensitive Records. Physical, paper records, and electronically stored records of a confidential or sensitive nature on individual hard drives or other media capable of being shredded and/or incinerated shall be destroyed by shredding or incineration by a vendor approved for this task. Records Management shall be responsible for maintaining a contract with and coordinating the service of this vendor to the University community. Records Management seeks vendors that are capable of shredding paper documents in a manner consistent with prevailing industry standards for confidential materials, and of destroying electronic media to an extent that precludes their intended use and the extraction of data from the media remnants. Electronically stored records of a confidential or sensitive nature stored in other manners shall be destroyed/deleted in such a manner that they cannot be retrieved or recreated using reasonable means. [rev. 5-15]
3) Transfer of Ownership to University Archives. Ownership of records shall be transferred to University Archives and Special Collections if the record series has been identified as containing records of historical or special interest by University Archives and the record retention period for the records has passed. The unit of origin transfers ownership of the records to University Archives using a Record Transfer Form. Once ownership has been transferred to University Archives those records will be processed according to the policies and procedures of University Archives and Special Collections and UI (see FSH 1470).
4) Method of Disposal. At the point in time when records are ready to be disposed, the method to be used is determined by the characteristics of the record series and the assessment of historical, archival, and potential research value of the series by the University Archivist. Records series that have been determined to have archival, historical, or research interest shall be transferred to University Archives. All others shall be disposed of or destroyed.
D. Information. For additional information or consultation, or to obtain records management forms, contact Records Management, Pitman Center (Bruce M. Pitman Center) Room 53, Moscow, Idaho 83844-4247, (208) 885-2580 or (208) 885-9255 (fax). See also web site: Records Management website