Title: Record Retention / Destruction Policy
Effective Date: 05-05-2009
Issuing Authority: Vice President and Chief Financial Officer
Contact: Nate Engle at engle1@stolaf.edu or 507-786-3502
Last Updated: 09-14-2021
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For items of historical reference that are not included in the retention schedule, please see “College Archives” section below and contact the College Archivist to determine if the records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
college_archives@stolaf.edu
507-786-3229
The College Archives, under the direction of the Lead Archivist, is the depository for non-current institutional records that contain enduring and significant historical or research value. 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 transfers of professional and personal papers of faculty and staff, records of academic and administrative departments, materials and records from 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 academic work (including distinction and honors papers)
- Student Organization reports and policies
- Survey summaries
It is the responsibility of the Lead Archivist to preserve, describe, and provide access to the College’s records of historical value. In the cases where historical records may be confidential in nature, access will be restricted 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, then 3 years |
| Nursing Loans | Business Office | Until loan is cancelled or repaid, then 3 years |
| Perkins Loans | Business Office | Until loan is cancelled or repaid, then 3 years |
| Purchase Orders | Business Office | 7 years |
| Student Account/Aid Files | Business Office | Until account 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 | Office of VP & CFO | PERMANENT |
| Gift Agreements/Planned Gifts | Office of VP & CFO | PERMANENT |
| Insurance Policies | Office of VP & CFO | PERMANENT |
| Insurance Records (other than policy) | Office of VP & CFO | 7 years after termination of policy |
| Investments | Office of VP & CFO | 7 years after the sale of the investment |
| Contracts & Agreements | Office of VP & CFO or Office of Origin | 7 years after end |
| Parent Permission and Registration Forms when Hosting Minors | Conferences Office or Office of Origin | 7 years unless a claim is made, then until resolved |
| Benefits (Enrollment/Change Forms, Annual Election of Benefits Forms, SPD Receipts, Tuition Correspondence) | Human Resources | 7 years after separation date |
| COBRA Paperwork | Human Resources | 10 years after separation date |
| Compensation (Total Compensation Statements, Annual Wage Letters, Step-in-Grade Letters, Status Changes) | Human Resources | 7 years after separation date |
| Employment Screenings (Background Check Consent Forms and Results) | Human Resources | 7 years after separation date |
| Form I-9’s | Human Resources | 3 years after hire date or 1 year after separation date, whichever is greater |
| Leaves – Non-Medical (Military, Personal, Jury Duty, etc.) | Human Resources | 7 years after separation date |
| Medical Leaves (FMLA Initial Notices, Provider Certificates, Fitness for Duty Forms, Designation Notices, Medical Documentation, Pay During Leave Forms, Disability Documentation) | Human Resources | 7 years after separation date |
| Medical – Other (Pre-employment Physicals, DOT Physical Renewals, Hepatitis B Vaccination Forms, Reasonable Accommodations, Return to Work Notices) | Human Resources | 7 years after separation date |
| New Hire/Rehire (Confidentiality Agreements, Applications, Cover Letters, Resumes, Requisitions, Handbook Receipt Forms, Emergency Contacts, Voluntary Demographic Data, Hire Information Forms, Moving Expenses, Offer Letters, Summer Employment Agreement Forms) | Human Resources | 7 years after separation date |
| Performance Management (Reviews, Job Descriptions, Employee Relations Documentation, Improvement Plans, Personal Acknowledgements, Years of Service Tracking) | Human Resources | 7 years after separation date |
| Retirement Plans (Match Eligibility Notices, Wage Reduction Agreements, Service Affidavits, 457(b) Agreements) | Human Resources | 7 years after separation date |
| Separation Documents (Exit Reports, Resignation/Retirement Letters, Resignation/Retirement Checklists, Death Notices) | Human Resources | 7 years after separation date |
| Severance Agreements and Letters | Human Resources | 10 years after separation date |
| Staff Handbooks | Human Resources | PERMANENT |
| Staff Recruiting Files (Requisitions, Interview Notes, Advertising Expenses, Applicant Information) | Human Resources | 2 years after position filled |
| Training Records (Title IX, Sexual Abuse Awareness, Sexual Misconduct, Diversity, Bloodborne Pathogens, Employee Right to Know) | Human Resources | 10 years after completion date |
| Volunteers (Registration Forms and Correspondence) | Human Resources | 7 years after separation date |
| Workers’ Compensation Documents (First Report of Injury Forms, Accident Investigation Notes, Correspondence with Insurer, Medical Documentation, Closing Notices) | Human Resources | 30 years after date of incident |
| Payroll Records (ledgers, taxes) | Payroll | PERMANENT |
| Payroll – W4s & Direct Deposits | 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. | ||