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St. Olaf College Record Retention / Destruction Policy

Title: Record Retention / Destruction Policy
Effective Date: 05-05-2009
Issuing Authority: Vice President and Treasurer
Contact: Angie Mathews at mathews@stolaf.edu or 507-786-3502
Last Updated: 05-05-2009

Purpose of Policy

St. Olaf College is implementing this policy to maintain College history, comply with various regulatory requirements, and to ensure the most efficient and effective operation of the College.  Our records include virtually all of the records you produce as an employee.  Such records can be in electronic or paper form.  Thus, items that you may not consider important, such as interoffice emails, desktop calendars and printed memoranda, are records that are affected by this policy. 

The goals of this policy are to:

• Make records management a part of your office routine;
• Retain important records for reference and future use;
• Delete documents that are no longer necessary for the proper functioning of the College;
• Organize important documents for efficient retrieval; and
• Ensure that you know what documents should be retained, the length of their retention, means of storage, and when and how they should be destroyed.

Policy

Records produced or received by any office or employee of the College in the transaction of College business are the property of the College and subject to the College’s policy for retention, disposal, access, and publication, including records produced or received by individuals in administrative and committee service capacities.  College records should be maintained according to the Records Retention Schedule (“RRS”), which will serve as the formal institutional policy for the retention and disposition of all types of records.  However, records subject to audit or those legally required for ongoing official proceedings must be retained until released from such audits or official proceedings, notwithstanding the instructions of the RRS.

No College records shall be discarded, destroyed or transferred from the custody of the College or otherwise disposed of prior to the time period specified in the RRS.  As it is not possible for the RRS to be exhaustive, please follow all regulatory guidelines when determining if a record not included on this schedule needs to be maintained or destroyed, or consult the Controller. 

For items of historical reference that are not included in the retention schedule, please see "College Archives" section below and contact the College Archivist to determine if the records should be retained in the College Archives. 

Management

To ensure compliance with this policy, the Controller is responsible for the following oversight functions:

• Implementing the policy;
• Ensuring that employees are properly educated, understand, and follow the policy;
• Providing oversight on actual retention and destruction of documents;
• Ensuring proper storage of documents;
• Periodically following-up with counsel to ensure proper retention periods are in place;
• Suspending the destruction of documents upon foreseeable litigation; and
• Keeping employees apprised of changes in relation to the policy.

The Controller shall review the policy from time to time, modify it accordingly, and inform and educate all employees on any such changes.  All questions relating to document retention and/or destruction should be directly addressed to the Controller.

Definition of Records

For the purpose of this policy, records shall be defined as all material on which information is recorded or preserved, regardless of form or characteristics, which is created or maintained by any agency, officer, or employee of the College in the transaction of its business. This definition refers to all forms of recorded information or other material bearing upon the activities and functions of the College, any of its officers, and employees. This definition also includes but is not limited to handwritten, typed, or printed material; publications; photographs; moving images; sound recordings; drawings; and computer or other electronic data. Not included in the definition of records as used in this policy are: faculty research or lecture notes; library materials; and materials not published by the institution.

Types of Records

The RRS attached at the end of this policy lists several categories of records, as well as specific records that contain specific retention periods.  All records not provided for in the RRS or described herein, shall be classified into three types, (1) Temporary Records, (2) Final Records, and (3) Permanent Records.

Temporary Records

Temporary records include all College documents that have not been completed.  Such records include, but are not limited to, dictation to be typed in the future, reminders, etc.

Temporary records can be destroyed, or permanently deleted if in electronic form. 

Final Records

Final records include all College documents that are not superseded by modification or addition. Such records include, but are not limited to, documents given (or sent via electronic form) to any third party not employed by the College, or government agency; final memoranda and reports; correspondence; handwritten telephone memoranda not further transcribed; etc.  All accounting records shall be deemed final.

Except as provided for in the RRS, all final documents are to be discarded ten (10) years after the close of a project.

Permanent Records

Permanent records include all business documents that define the scope of the College’s activities and functions, publications, and expressions of professional opinions.  Such include, but are not limited to contracts, proposals, materials referencing expert opinions, annual financial statements, federal tax returns, payroll registers, copyright registrations, patents, etc.

Except as provided for in the RRS, all permanent documents are to be retained indefinitely.

Storage 

Tangible Records

Tangible records are those you must physically move to store, such as paper records (including records printed versions of electronically saved documents), photographs, audio recordings, advertisements and promotional items.  Active records, records that need to be easily accessible and inactive records may be stored in the College’s office space or equipment. 

Electronic Records

Electronic records should be either printed and stored as hard copies or saved to the network if they contain information that is required to be retained according to the RRS. 

Destruction/Deletion

Tangible Records

Tangible records should be destroyed by shredding or some other means that will render them unreadable.  If you have a record that you do not know how to destroy, such as a photograph, compact disk, or tape recording, ask the advice of the Controller.

Electronic Records

E-mail records must be deleted according to the RRS.  Where duplicate records are involved, both copies must be destroyed/deleted where proper.

Cessation of Record Destruction/Deletion

If a lawsuit is filed or imminent, or a legal document request has been made upon the College, ALL RECORD DESTRUCTION MUST CEASE IMMEDIATELY.  The Controller may suspend this policy to require that documents relating to the lawsuit or potential legal issue(s) be retained and organized.  A critical understanding of this section is imperative.  Should you fail to follow this protocol, the College may be subject to fines and penalties, among other sanctions.

College Archives

St. Olaf College Archives
507-786-3229
The College Archives, under the direction of the College Archivist, is the depository for non-current institutional records that contain enduring and significant historical or research value. A minimum of two copies of every publication issued by the College or by any of its agencies should be forwarded to the archives. The Archives also solicits and accepts donations of professional and personal papers of faculty and staff, records of student organizations, and other relevant material.

Examples of items that should be forwarded to the College Archives include, but are not limited to:

• Administrative Correspondence
• Alumni Biographical Information
• Annual Reports, such as:
• Financial Reports – final
• Grant final reports
• Institutional and Research reports
• Artifacts
• Constitutions/By-Laws
• Event summaries (Conferences, workshops, etc.)
• Faculty files, such as:
• Professional files
• Course syllabi
• Publications
• Awards and other forms of recognition
• Biographical information
• Resumes/curriculum vitae
• Faculty/Staff Manuals
• Histories of the College/Program Reviews
• Honor Society Records
• Minutes and related documents (subcommittee reports, drafts of memoranda, etc.)
• Faculty minutes
• Departmental minutes
• Committee minutes
• Interdisciplinary program minutes and related documents
• Non-Academic Department minutes
• Policies (e.g. Residence Life, Student Policies)
• Publications, such as:
• Announcements
• Circulars
• Flyers
• Mass Mailings
• News Releases
• Newsletters
• Posters
• Programs – St. Olaf Performances
• Recordings of:
• Lectures
• Academic events
• Chapel talks
• Concerts and/or programs
• Athletic Events
• Student distinction and honors papers
• Student Organization reports and policies
• Survey summaries

The decision to select and preserve records of historical value is the responsibility of the Archivist.  In the cases where historical records may be confidential in nature, access will be limited to only individuals authorized by the Vice President governing those records.  

Record Retention Schedule (RRS)

Record Type	Official Copyholder	Retention Period*
Accounts Payable	Business Office	7 years
Accounts Receivable (reports/ledgers/backup)	Business Office	7 years
Annual Financial Statements	Business Office	PERMANENT
Audit Reports	Business Office	PERMANENT
Audit Work papers	Business Office	7 years
Bank Reconciliations	Business Office	7 years
Bank Statements	Business Office	7 years
Budget Reports – Annual	Business Office	PERMANENT
Capitalization Files (costs, depreciation, plans, etc.)	Business Office	PERMANENT
Cash Receipts	Business Office	7 years
Check - Cancelled (see below)	Business Office	7 years
Checks Cancelled for important payments i.e. taxes, property, etc.	Business Office	PERMANENT
Credit Card Statements/Backup	Business Office	7 years
Depreciation Schedules	Business Office	PERMANENT
General Ledgers	Business Office	PERMANENT
Journal Entries	Business Office	7 years
Notes Receivable Ledgers, Schedules, College Loans	Business Office	Until loan is cancelled or repaid
Nursing Loans	Business Office	Until loan is cancelled or repaid
Perkins Loans	Business Office	Until loan is cancelled or repaid
Purchase Orders	Business Office	7 years
Student Account/Aid Files	Business Office	Until loan is cancelled or repaid
Tax Returns	Business Office	PERMANENT
Tax Return Supporting Documents	Business Office	7 years
Travel Expense Reports	Business Office	7 years
Donor Gift Agreements/Planned Gifts	Treasurer’s Office	PERMANENT
Gift Agreements/Planned Gifts	Treasurer’s Office	PERMANENT
Insurance Policies	Treasurer’s Office	PERMANENT
Insurance Records (other than policy)	Treasurer’s Office	7 years after termination of policy
Investments	Treasurer’s Office	7 years after the sale of the investment
Contracts & Agreements	Treasurer’s Office or Office of Origin	7 years after end
Applicant Files (applications, cover letters, resumes, or other employment inquiries, and other records regarding decision not to hire)	Human Resources	2 years from the date of rejection or making of the record.  If hired, records go to personnel file
Advertisements or notices regarding position openings or other opportunities	Human Resources	2 years after position is filled or announcement is superseded or updated
Personnel Policies & Procedures	Human Resources	Until no longer needed for reference
Personnel Files (job applications, contracts, salary letters, performance reviews, disciplinary warnings)	Human Resources	7 years after separation
Retirement & Pension Records	Human Resources	PERMANENT
Medical Files (accident reports, workman's comp claims, exposure to hazardous substances)	Human Resources	PERMANENT
Medical Files (including medical or physical exams, FMLA paperwork, ADA documentation, benefit enrollment)	Human Resources	7 years after separation
I-9's	Human Resources	3 years from hire or 1 year after separation, whichever is later
Payroll Records (ledgers, taxes)	Payroll	PERMANENT
Payroll – W4s & Dir Dep	Payroll	7 years
Payroll Time Cards (EE/Students)	Payroll	7 years
Student Discipline Files	Dean of Students	2 years after graduation (legal issues kept longer)
Personal Student Files	Dean of Students	1 years after graduation, inactive files – 5 years after graduation year (legal issues kept longer)
Medical Patient Records	Health Center	6 years
Student Academic records - St. Olaf Transcript	Registrar	PERMANENT
Student Academic records - St. Olaf application	Registrar	5 years after graduation or last enrolled
Student Academic records - Pre-college test scores	Registrar	5 years after graduation or last enrolled
Student Academic records - Non-St. Olaf College transcripts	Registrar	5 years after graduation or last enrolled
Student Academic records - Transcript request forms	Registrar	5 years after graduation or last enrolled
Student Academic records - Off-campus program grades	Registrar	PERMANENT
Student Academic records - Petition forms	Registrar	5 years after graduation or last enrolled
Student Academic records - Permission forms	Registrar	5 years after graduation or last enrolled
Student Academic records - Data information sheets	Registrar	5 years after graduation or last enrolled
Student Academic records - Correspondence with Students	Registrar	5 years after graduation or last enrolled
Grades	Registrar	PERMANENT
Registration forms	Registrar	5 years after graduation or last enrolled.
Drop/Add slips	Registrar	5 years
Advising Files	Registrar	5 years after graduation or last enrolled
Admission and Enrollment Files	Admissions	1 years after graduation or date of last attendance
Admissions Applications – Rejected Students	Admissions	1 year after term for which app was processed
Financial Aid (reports and transactions)	Financial Aid	Until loan is cancelled or repaid (for active files), 7 years (for inactive files)
Fiscal Operations Report (FISAP)	Financial Aid	4 years
Student Earning Records	Financial Aid	7 years
Blueprints	Facilities Mgmt	PERMANENT
Construction Documentation	Facilities Mgmt	PERMANENT
Floor Plans	Facilities Mgmt	PERMANENT
Remodeling Documentation	Facilities Mgmt	PERMANENT
Equipment Files	Facilities	6 years after disposal
Donor Files (correspondence, emails, reports, profiles, etc.)	Development Office	PERMANENT
Donor Gift Records (Millennium, receipts, pledges)	Development Office	7 years after gift received
Gift Records (Millennium, receipts, pledges)	Development Office	7 years after gift received
Grants Received by St. Olaf + sub-awards	Grants Office	3 years after end of grant or 7 years, whichever is longer
Grant Proposals	Grants Office	Awarded: PERMANENT not awarded:  1 year
All documents pertaining to a specific grant are kept in a file folder filed by the name of the Foundation or Federal Agency that awarded the grant.
All files include the original proposal, budgets, signed proposal clearance forms, award letters, and financial and narrative annual and final reports.
Accreditation Records	President’s Office	Until no longer needed for reference
Minutes	Dept of Origin + College Archives	PERMANENT
Instructional Materials	Any dept/faculty	Until obsolete
* THIS IS NOT A COMPREHENSIVE LIST OF ALL RECORDS.  FOR SPECIFIC RECORDS NOT LISTED, CONSULT THE CONTROLLER.