Information Technology, Documents, & Records
The College Archives is the official depository for non-current college records having lasting administrative or historical value. All documents, correspondence, accounts, files, manuscripts, publications, photographs, tapes, drawings, or other material regardless of physical form and characteristics, which are created or maintained by college officers, staff, or faculty members in the performance of assigned administrative duties are considered “college records” and are the property of the College. Pursuant to a 1974 action of the Board of Trustees, no such records are to be discarded, destroyed, or otherwise disposed of except after consultation between the College Archivist and the administrative officers, department heads, or committee chairs responsible for the custody of these records during their active life. Approval either to transfer inactive college records to Archives or to destroy them after an agreed-upon period may take the form of written records disposition schedules or other agreements between the Archivist and the custodian of the records. A number of general “blanket” authorizations for disposal of certain classes of routine records have already been issued – please contact the Archives if you have any questions. One copy of every publication issued by the College or any college agency should always be forwarded to the Archives. Restrictions on access to records transferred to Archives may be negotiated by the agency or office of transmittal. Reference service provided by the Archives to the College may include searching records to provide specific pieces of information, making copies of particular documents, or making records available for consultation in the Archives. Offices and departments which transfer records to Archives may request the return of records to the transmitting office, if transfer to Archives is found to have been premature. In addition to official college records as defined above, the Archives may also accept donations of professional and personal papers belonging to individual members of the College community, records of student organizations, or other material documenting aspects of the life or business of Carleton College that may be given to the Archives for preservation and use.
The need for this Record Retention Policy arose in light of new Federal Rules of Civil Procedure relating directly to document and data retention, including electronic documents and e-data. The new Rules establish procedures for discovery by litigation opponents of electronic information. The Rules also provide protections against sanctions being imposed on a litigant in the event that information which could be relevant to the case has been destroyed pursuant to a document or information retention policy. Although the Rules technically apply only in cases in federal court, the principles are likely to be applied by any court.
There are two basic concepts raised by the new Rules – general and specific. The specific is that if Carleton has notice that a claim which could end up in court has been or is reasonably likely to be asserted against it, then Carleton must place a “litigation hold” on the destruction of documents (electronic or hard copy) which are relevant to the case or may lead to the discovery of relevant evidence. Simply put, if Carleton has notice that it might get sued, it must take affirmative steps to preserve information, including sending notice to everyone at Carleton who might have information and instructing them not to destroy any documents or data, and putting a hold on, or stop to, any automatic destruction processes.
The general concept is that it is in Carleton’s interest to implement retention procedures that result in the destruction of documents and data which do not need to be retained either for legal or institutional reasons. There are a number of reasons why retention procedures make sense, four of which are:
- the Rules state that “absent exceptional circumstances, a court may not impose sanctions under these rules on a party for failing to provide electronically stored information lost as a result of routine, good-faith operation of an electronic information system”;
- the cost to the College of producing discoverable information will be lower if there is less information to produce;
- variations in destruction practices by individuals in the absence of a retention policy could cause a court to infer that information was destroyed when it should not have been; and
- relief from a significant burden on the College in the storing of data and documents for a period longer than required by law or in the College’s interest.
Data & Record Retention Team
Janet Scannell, Chief Technology Officer (firstname.lastname@example.org, X4077)
Shannon Schulz, Director of Development Operations (email@example.com, X5979)
Emy Farley, Registrar (firstname.lastname@example.org, X4290)
Rod Oto, Associate Dean of Admissions and Director of Student Financial Services (email@example.com, X4138)
Linda Thornton, Comptroller (firstname.lastname@example.org, X4171)
Kerstin Cardenas, Director of Human Resources (email@example.com, X4068)
Tom Lamb, College Archivist (firstname.lastname@example.org, X7015)
RECORDS RETENTION POLICY
Proper retention of records is essential to conducting the business of the College; to protecting the legal interests of the College, students, and employees; to preserving the College’s history; and to complying with applicable state and federal laws and regulations. In addition, the College is obligated to preserve records when litigation is threatened or pending. For the purposes of efficiency and management of physical and digital storage resources, it is also important that unneeded records be disposed of in a timely manner.
This policy applies to all departments, divisions, offices, and employees of the College. Personnel are required to be familiar with and to adhere to this policy, as it pertains to the types of records/documents in the Document and Data Retention Schedule below.
B. Records Defined
For the purposes of this policy, “records” include documentary material, regardless of media, produced in the course of College business. The most common types of records generated and their retention periods are addressed in the Document and Data Retention Schedule. Any questions concerning records not specified in the schedule should be directed to the Data and Record Retention Team before a record is destroyed. “Records” also include copies of original materials that are themselves different from the original (e.g., a copy of a document with marginal handwritten notes).
“Records” do not include extra copies of materials of which an official copy has been retained, nor do they include personal or transitory correspondence/materials (see Section D below). “Records” also do not include “transitory documents” (including e-mails) that are not included in any of the categories in the records retention schedule. “Transitory documents” can be destroyed when no longer needed. “Transitory documents” include items such as letters of transmittal or acknowledgements; requests for routine information; notices of staff/department meetings or events; communications to students concerning class schedules or assignments; records that are kept in the sole possession of the maker, are used only as a personal memory aid, and are not accessible or revealed to any other person except a temporary substitute for the maker of the record; personal correspondence or other documents not related to the business of the College; and the like.
C. Data and Record Retention Team
The Data and Record Retention Team is responsible for implementing the College’s records retention policy and procedures. The Data and Record Retention Team is authorized to perform the following functions:
- Identify records generated by and received by the College that should be retained.
- Publish a record retention procedure schedule that complies with any applicable state and federal laws and regulations.
- Monitor state and federal laws and regulations affecting record retention.
- Answer questions from college personnel concerning record retention.
- Periodically review the record retention procedure and schedule and update as necessary.
- Develop a training and awareness program on record retention for the College personnel.
- Develop guidelines for appropriate destruction of College records.
- Develop guidelines to maintain confidentiality of records as necessary.
- Monitor departments for compliance with the record retention policy and procedure.
- Authorize deviation from the retention procedures or schedule, usually for a research or other academic purpose, on a case-by-case basis.
D. General Record Retention Rules
The following are general rules pertaining to record retention. There may be additional rules and procedures governing particular types of records.
- College personnel are required to check the record retention schedule before disposing of materials generated in the course of College business.
- If a particular type of document does not appear to be covered by the schedule, consult with the Data and Record Retention Team.
- Only one copy of a document should be retained, by the party or department responsible for it (see Document Custodian). Where possible, the retained document should be the original. Permanent records may be transfer to College Archives by the Document Custodian on a scheduled basis.
- Drafts and notes concerning a document should be destroyed unless they are important to documenting official business or action of the College, in which case they will be stored with the document.
- Except as noted in the retention schedule, the retention period runs from the date the record was created or received.
- In the case of pending or reasonably anticipated litigation, the college will impose a “litigation hold,” which will be communicated to all persons whom the college has reason to believe may be in possession of documents that are either relevant or may lead to the discovery of admissible evidence pertaining to the case. The imposition of a “litigation hold” means that all retention periods are suspended for applicable documents and no such documents shall be destroyed or altered until notification that the litigation matter has been concluded.
- E-mails are computerized documents that should be treated like any other record and are subject to the same retention schedule.
- Documents stored in OnBase should be treated like any other record and are subject to the same document retention schedule.
- Any questions as to whether a particular type of document is “transitory” and can be destroyed should be directed to the Data and Record Retention Team.
E. Records Retention Schedule
The Document and Data Retention schedule includes records by office and category; the retention period in days, months, and years and the document custodian.
F. Record Destruction
Documents may be disposed of in a manner convenient to the person undertaking the destruction. Documents with confidential, private, or sensitive information should be shredded.
G. Policy Management
This policy will be reviewed on an annual basis by the Data & Record Retention Team. The policy will be posted on the Carleton web site in the Campus Handbook; updates will be communicated on an annual basis.
Document and Data Retention Periods
Core institutional database records (i.e. Ellucian Colleague; Ellucian Advance) are retained indefinitely; the retention period indicated below applies to paper records and ancillary files. Ancillary files including documents on personal computers and other servers (i.e. Collab; OnBase).
|Type of Record||Time Period for Retention||Document Custodian|
|Academic Department Records Concerning Students||6 Years from Graduation or date of last attendance||Registrar|
|Accounts Payable Ledgers and Supporting Documentation||5 Fiscal years|
|Accounts Receivable Ledgers and Supporting Documentation||5 Fiscal years|
|All Accounting Subsidiary Records||5 years|
|Annual Financial Reports||Permanent|
|Bank Reconciliations and Bank Statements||5 Fiscal Years|
|Capital Equipment Records (if purchased with federal funds)||3 Years after disposition of equipment|
|Capital Equipment Records (unless purchased with federal funds||Life of Asset|
|Cash Receipts/ Deposits||5 Fiscal Years|
|Depreciation Records||Life of Asset|
|Sales Tax Returns||6 Years|
|Other Student Loan Records (Perkins FSA HB Feb 2012)||3 Years after loan is paid in full, cancelled, or assigned elsewhere|
|Perkins Loan Files||10 Years after loan is paid in full, cancelled, or assigned elsewhere|
|Tax returns and worksheets||Permanent|
|Vendor Contracts||3 Years from completion of contract|
|W-9 on file for Vendor||3 Years after last use|
|Admissions Materials for Students Who Do Not Enroll|
|Financial Aid Records (Students who do not Enroll)||3 Years from end of academic year in which student applied||Student Financial Services|
|All other Admissions Materials||3 Years from end of academic year in which student applied||Admissions|
|Documents Supporting other Selection Decisions||3 Academic years from date of decision||Admissions|
|Federal/State Required Statistics and Reports||Permanent||Admissions|
|Admissions Materials for Students Who Enroll (see Student Records)||Permanent||Dean of Students|
|Alumni Directories||Permanent||Alumni Relations Office|
|Alumni Newsletters/ News E-Mails||Permanent||Alumni Relations Office|
|Annual Fund Solicitations||Permanent||Alumni Annual Fund|
|Annual Fund Phonathon Materials||Permanent||Alumni Annual Fund|
|Alumni Database (Alumni, Parents; Friends)||Permanent||Development|
|Letters of Intent and Gift Agreements||Permanent||Business Office|
|Deed of Gifts||Permanent|
|Purchases and Sale Documentation||Permanent|
|Career Center and Career Placement Records||Permanent||Career Center College Archives|
|Corporate and Foundation Relations (CFR)|
|Closed Grant File||Permanent||CFR|
|IDC Proposal and Supporting Documentation||Permanent||Business Office|
|Corporate Records||Office of the President Archives|
|Articles of Incorporation||Permanent|
|Board of Trustees Minutes||Permanent|
|Board of Trustees Board Packets||Permanent|
|Records of College – Affiliated Enterprises||7 years after enterprise dissolution or after College ceases affiliation|
|Dean of the College|
|Academic Search Committee Materials (advertising materials, applicant files, Search Committee records)||3 Full academic years from year search completed||Dean of the College|
|Course Offerings/Course Catalogue||Permanent||Registrar|
|Faculty Handbook||7 Years from end of academic year||Dean of College|
|Faculty Tenure Records||Permanent||Dean of the College Archives with Restricted Access (evaluation pending)|
|Faculty Contract Renewal Materials, if denied||Permanent||Dean of College|
|Grievances||Permanent||Dean of College|
|Minutes of Faculty Meetings and other Governance Meetings||Permanent||Dean of College|
|Bonds, Tax Exempt||Business Office|
|Bond Closing Transcripts and Supporting Documentation||Term of Bond, plus 3 years||Business Office|
|Documents Relating to Capital Expenditures Financed or Refinanced with Bond Proceeds||Term of Bond, plus 3 years||Business Office|
|Record of Investments, Investment Agreements, Arbitrage Reports and Trustee Statements Related to the Bond Issuance and Expenditures||Term of Bond, plus 3 years||Business Office|
|Environmental Health and Safety Faculty Records||8 years||Facilities|
|Commencement Programs||Permanent||External Relations|
|Press Releases||Permanent||Medial Relations|
|Sports Information Releases||Permanent||Sports Information|
|Human Resources||Human Resources|
|Affirmative Action/Equal Opportunity Officer Investigations, if denied||6 Years from academic year of last employment|
|Affirmative Action/Equal Opportunity Officer Investigations, if granted||Permanent|
|COBRA Notices and Enrollment Forms||6 Years after termination|
|Disability Benefits Records||Life of employee|
|Employee Personnel Files||6 Years after termination|
|ERISA Documents including Benefit Plan Descriptions & Summary Plan Documents||6 Years|
|Faculty CV’s and Personal Information Card||Permanent|
|FMLA Records||3 Years from end of leave|
|Medical Records & Records of Exposure to Toxic Substances||Length of Employment plus 30 years|
|Non – Academic Search Committee Materials (advertising materials, applicant files, interview records)||1 Year following search completed|
|Retirement Benefits Accrued||Life of employee or beneficiary|
|Sick Leave Benefits||Life of employee|
|Staff Handbook||7 Years from end of academic year|
|Workers’ Compensation Files||Life of employee|
|I9||3 Years after date of hire or 1 Year after employment ends whichever is LATER|
|Direct Deposit Authorization/Student Account Authorization||1 year after|
|W4||4 Years after the end of the calendar year|
|Certificate of Insurance||7 Years after expiration|
|Insurance Policies||7 Years after expiration|
|Accident Reports and Claims||7 Years after case is settled|
|Litigation Records – Consent Orders, Judgments, Court Orders Disposing of Litigation, Releases and Settlement Agreements||Permanent|
|Litigation Records – Documents of Historical Significance (e.g. Trial Transcripts, Deposition Transcripts, and Trial and Litigation Records – Documents of Historical Significance (e.g. Trial Transcripts, Deposition Transcripts, and Trial and Deposition Exhibits in cases of significance to the history of the College)||Permanent|
|Subscription Agreements for Hedge Fund or Private Equity Investments||7 Years after termination|
|NACUBO Endowment Study||Permanent|
|Quarterly Valuation Reports||Permanent|
|Time Cards||5 Years after the end of the calendar year|
|Payroll Registers and Reports||5 Years after the end of the calendar year|
|International Students – Copies of Passport, VISA, I94, FNIS Backup||5 Years after the end of the calendar year|
|Wage Garnishments||5 Years after the end of the calendar year|
|W2||5 Years after the end of the calendar year|
|1042S||5 Years after the end of the calendar year|
|941||5 years after the end of the calendar year|
|Property and Facilities Records||Facilities|
|As Built Drawings||Permanent|
|Building Permits||1 Year after final Completion|
|Leases||5 Years from expiration of lease|
|Plans and Specifications||Permanent|
|Routine Incidental Maintenance||3 Years from completion|
|Title Insurance Policies||7 Years after sale of property|
|Carleton’s Magazine – The Voice||Permanent||Archives|
|Other Printed Publications||Permanent||Archives|
|Accident/Incident Reports||7 Years|
|Clery Act Logs||3 Years|
|Clery Act Statistics||3 Years|
|Clery Act Warning Notices||3 Years|
|Property Loss or Damage Reports||7 Years|
|Student Records – reference AACRAO’s Retention of Records: Guide for Retention and Disposal of Student Records|
|Academic Standing Committee Actions (Dismissal, Suspension, etc.)||Until graduation or 2 Years after withdrawal 5 Years after suspension ; 10 Years after expulsion||Dean of Students|
|Academic Advising Files||1 Year after Carleton graduation or date of last attendance; policy currently varies department||Academic Advisor|
|Academic Records||Permanent||Dean of Students|
|Advanced Placement and other Placement Test Records/Scores||5 Years from Carleton graduation or date of last attendance||Registrar|
|Change of Grade Forms||Permanent||Registrar|
|Commencement Program||Permanent||Dean of Student Archives|
|Curriculum Change Authorizations||1 Year from Carleton graduation or date of last attendance||Dean of Students|
|Enrollment Verifications and Good Student Discount Insurance Authorizations||1 Year||Registrar|
|Requests for Non – Disclosure of Directory Information||1 Year from Carleton graduation or date of last attendance||Dean of Students|
|Dean’s Recommendations/Consent to Release Personally Identifiable Information||Later of 5 years from Carleton graduation or 2 years from date of request||Dean of Students|
|Financial Aid Records (students who enroll)||5 Years from Carleton graduation or date of last attendance||Student Financial Services Office|
|International Student Forms||10 Years from Carleton graduation or date of last attendance||International Student Programs|
|Medical Leave Agreements||1 Year from Carleton graduation or date of last attendance||Dean of Students|
|Name Change Authorization||Permanent||Registrar|
|SAT/UNSAT Requests||4 Years from Carleton graduation||Registrar|
|Student Education File - except for Admission Application, including Entrance Exam Reports, Advanced Placement Records; High School or other College Transcripts; Directory Information; Campus Job Evaluations; Notices of Awards or Honors; Evidence of Extracurricular Activities and other information provided by the student which is indicative of post-college activities, all of which is transferred to the Alumni Record maintained by Central Records permanently.||6 Years from Carleton graduation or date of last attendance||Dean of Students|
|Student Handbook||Electronic||Dean of Students|
|Student Health Records||7 Years from Carleton graduation or date of last attendance||The Wellness Center|
|Teaching Licensure Applications||Permanent||Registrar|
|Transcript Requests ( Registration Forms, Drop/Add, Pass/Fail or Registration Change Petitions)||Permanent||Registrar|
|Transcripts from Other Colleges and Consortia||Permanent||Registrar|
|Transfer Credit Evaluations||6 Years from Carleton graduation or date of last attendance||Registrar|
|Veterans Administration Certifications||3 Years after Carleton graduation or date of last attendance|
|Withdrawal Authorizations/Leave of Absence||Carleton graduation or two years after withdrawal from the College||Dean of Students|
|Information Technology - General Server Operation and Individuals’ Files Managed by ITS (Retention of other information Limited by Specifications listed elsewhere.)||Information Technology Services (ITS)|
|Server Data Retention – System Logs||ITS|
|Web server logs (which may include account names)||Log entries are kept for up to 1 year, after which general server backup retentions apply (see below).|
|Any log that associates a User ID (account name) or other Personal Identification with an IP address and/or access to any web page or other Network Service on or off campus, except where required to record financial transactions, etc.||Logs are recoverable between 90 days and 365, depending on system. [Check with web server logs for exceptions]|
|Network audit logs||30 days.|
|Server Data Retention – Network Access Control System||ITS|
|Registration of Student – Owned computer’s MAC addresses||Minimum 90 Days after device last active on the campus network; old entries purged as needed.|
|IP/MAC address audit information||Indefinite|
|Server Data Retention – E-Mail Server (applies only to e-mail retained on the server)||ITS|
|E-Mail Inbox||Opened and unopened e-mail is retained on the server until deleted by the user or the account is closed (see “Account Closing”, below).|
|Sent Items||Until deleted by the user or account is closed.|
|Junk Items||30 Days or until deleted by users.|
|Trash Items||90 Days or until deleted by user.|
|Back-Ups of E-Mail Server||14 Days|
|Account Closing||Folders kept online for 1 year after account closing, with the exception of graduating seniors (30 days after graduation). Above backups apply after that time.|
|Server Data Retention||ITS|
|Individual’s files in selected directories on the individual’s allocated desktop or notebook computer, initially set to back-up all personally created documents.||Periodic (not necessarily regular) review of client systems and removal of inactive or decommissioned systems.|
|Individual’s home directory on network share.||Data may be transferred to supervisor for saving or disposal. Otherwise, folders kept online for 1 year after termination. Backups below then apply.|
|Back-Ups of Other Servers (except as noted above)||Core institutional information systems: 1 year (fulls and incrementals). Colleague and course folders: bi-yearly archives kept 7 years. All other servers: 90 days (fulls and incrementals).|
|College – Owned Computers – Migration by individual to a Replacement Computer||ITS|
|Data files on old computer.||All files in predetermined locations on the hard drive are copied onto new computer (deleted files not restored unless requested by Client).|
|Old Computer Hard Drive||Faculty: removed drives kept by ITS for a period of a year or more. Staff: drives kept 1-2 months then securely erased.|
|College – Owned Computers - Employee Exit from the College (employment termination)||ITS|
|Computer and Hard Drive||If computer returned to stock, hard drive is re-imaged prior to re-deployment. If computer is deployed to employee’s replacement, the hard drive contents may or may not be erased.|
Adopted May 14, 2009 (effective for the fiscal year beginning July 1, 2008).