Records Retention Schedule, Proposed Policy

Proposed Example for GCU

(The “Repository” or name of the administrative unit responsible for the record at GCU is unknown. Therefore, the common university name has been used in the table below.)

Purpose

Knowing what records to keep and for how long is challenging. A records retention schedule defines the period of time that records should be retained and when they should be destroyed. Various requirements based in law and university policy govern the retention of administrative records. A retention schedule is critical for promoting responsible records management, mitigating risk, and ensuring consistent compliance across GCU.

Category	Record Type	Record Description	Repository	Duration
Academic/Student Records	Academic Integrity Code Violations		School / College of Enrollment	Record of final disposition for offenses that result in suspension or expulsion: permanent.
Academic/Student Records	Academic Personnel		Academic Search Records	See Affirmative Action/Equal Opportunity
Academic/Student Records	Admissions Data for Applicants Who Enroll		Admissions Office, Individual Graduate Admissions Offices	5 years from graduation or date of last attendance
Academic/Student Records	Admissions Data for Applicants Who Do Not Enroll, Whether Accepted or Rejected		Admissions Office, Individual Graduate Admissions Offices	2 weeks after the beginning of the semester for which the applicant sought admission
Academic/Student Records	Advanced Placement Records and other Placement Test Records / Scores		Registrar, Office of the University	5 years from graduation or date of last attendance
Academic/Student Records	Annual Conflict of Interest Disclosure Statements		Office of Research Compliance	3 years
Academic/Student Records	Applications for Graduation		School / College of Enrollment	1 year after graduation or date of last attendance
Academic/Student Records	Audit Authorizations and Records		Registrar, Office of the University	1 year after date submitted
Academic/Student Records	Catalogs		Registrar, Office of the University (exceptions: MED, SDM, LAW keep theirs)	Permanent
Academic/Student Records	Change of Course Forms-Continuing Education, Summer Sessions, and Extramural Studies		Office of Continuing Education and Summer Sessions	1 year after submission
Academic/Student Records	Change to Student University ID number (UID)		Registrar, Office of the University	Permanent
Academic/Student Records	Class Lists (original)		Registrar, Office of the University	Permanent
Academic/Student Records	Consent to Release Personally Identifiable Information (Requests for Non-Disclosure)		Registrar, Office of the University	Kept until next academic year, signatures kept 5 years
Academic/Student Records	Correspondence, relevant		Admissions Office, Individual Graduate Admissions Offices	5 years from graduation or date of last attendance
Academic/Student Records	Course Offerings		Registrar, Office of the University	Permanent
Academic/Student Records	Credit/No Credit Approvals (Audit, Pass/Fail, etc.)		Registrar, Office of the University	1 year after date submitted
Academic/Student Records	Credit by Examination Records		Registrar, Office of the University	5 years from graduation or date of last attendance
Academic/Student Records	Curriculum Change Authorizations		School / College of Enrollment	5 years from graduation or date of last attendance
Academic/Student Records	Degree, Grade, and Enrollment Statistics		Registrar, Office of the University	Permanent
Academic/Student Records	Disciplinary Records – Students (findings of violation and related case files)		Office of the Dean of Students for Student Records	Record of final disposition for offenses that result in suspension or expulsion: Permanent
Academic/Student Records	Enrollment Verifications		Registrar, Office of the University	1 year from enrollment date
Academic/Student Records	Entrance Exam Reports		Admissions Office, Individual Graduate Admissions Offices	5 years from graduation or date of last attendance
Academic/Student Records	Financial Aid Records (applicants who enroll)	Including Federal Perkins Loan Records	Financial Assistance, Office of	5 years after the end of the award period
Academic/Student Records	Grade Change Forms		Registrar, Office of the University	Permanent
Academic/Student Records	Grade Sheets		Registrar, Office of the University	Permanent
Academic/Student Records	Grade Books (Professors)		School/College of Enrollment	5 years
Academic/Student Records	Graduation Lists		Registrar, Office of the University	Permanent
Academic/Student Records	International Student Forms	Visa documentation, etc.	International Students and Scholars Office	5 years
Academic/Student Records	Letters of Recommendation (enrolled students)		School/College of Enrollment	5 years after graduation or date of last attendance
Academic/Student Records	Name Changes		Registrar, Office of the University	5 years after graduation or date of last attendance
Academic/Student Records	Original Grade Sheets		Registrar, Office of the University	Permanent
Academic/Student Records	Patient Medical Records		Student Health Services	20 years after final treatment
Academic/Student Records	Personnel Files, Appointment Letters, and Forms		See Human Resources Section	See Human Resources Section
Academic/Student Records	Racial/Ethnic Statistics		Office of Institutional Research	Permanent
Academic/Student Records	Recruitment Materials (enrolled students)		School/College of Enrollment	5 years after graduation or date of last attendance
Academic/Student Records	Residency Certificates (enrolled students)		School/College of Enrollment	Until date of enrollment
Academic/Student Records	Residency Change Documents (Non-resident to Resident)		TBD	5 years after graduation or date of last attendance
Academic/Student Records	Schedule of Classes (institutional)		Registrar, Office of the University	Permanent
Academic/Student Records	Student Class Schedules		Registrar, Office of the University	1 year from graduation date or date of last attendance
Academic/Student Records	Student Waivers for Right of Access (enrolled
Admissions Offices	Until graduation or date of last attendance
Academic/Student Records	Suspensions and Dismissals		School/College of Enrollment	5 years after graduation or date of last attendance
Academic/Student Records	Tenure or Promotion Dossiers		Office of the Provost	If action approved, 3 years; if tenure denied, 7 years from end of term appointment
Academic/Student Records	Transcripts		Registrar, Office of the University (exceptions: MED, SDM, LAW keep theirs)	Permanent
Academic/Student Records	Transcripts – High School and Other College (applicants who enroll)		School/College of Enrollment	5 years after graduation or date of last attendance
Academic/Student Records	Transfer Credit Evaluations		Registrar, Office of the University	5 years from graduation
Academic/Student Records	Trustee Decisions Regarding Academic Personnel and Designated Executives		Office of the Trustees	Permanent
Academic/Student Records	Veteran Administration Certifications		Registrar, Office of the University	5 years after graduation or date of last attendance
Academic/Student Records	Withdrawal Authorizations/Leaves of Absence – Graduate and Professional School Students		Graduate School Professional School Registrar	After graduation or date of last attendance
Academic/Student Records	Withdrawal Authorizations/Leaves of Absence – Undergraduate Students		University Service Center for Undergraduate Students	2 years
Academic / Student Records	Admissions Data: Official Mid-Semester census snapshots	Record level data for applicants and admitted undergraduate and graduate students imported into the Academic Data Warehouse	Academic Data Warehouse (ADW)	Permanent
Academic / Student Records	Admissions Data: Daily Admissions Snapshots	Record level data for applicants and admitted undergraduate and graduate students imported into the Academic Data Warehouse	Academic Data Warehouse (ADW)	All snapshots within the latest admissions cycle academic year plus previous three academic years
Academic / Student Records	Student Enrollment: Official Mid-Semester and Official Final census snapshots	Record level data for enrolled students imported into the Academic Data Warehouse	Academic Data Warehouse (ADW)	Permanent
Academic / Student Records	Student Enrollment: Weekly Enrollment Snapshots	Record level data for enrolled students imported into the Academic Data Warehouse	Academic Data Warehouse (ADW)	All snapshots for the latest enrollment semester for which registration is open or the previous three academic years
Academic / Student Records	Faculty Data: Official census snapshots for key reporting periods	Record level data for faculty or instructional staff imported into the Academic Data Warehouse	Academic Data Warehouse (ADW)	Permanent
Academic / Student Records	Faculty Data: Bi-Monthly Snapshots
Academic / Student Records	Student created data/work	All student information in an email inbox and OneDrive	Office 365	Becomes unavailable 60 days after separation from the university.
Academic / Student Records	Student created data/work	All student generated information in a Halo course	Halo, LMS	Becomes unavailable 60 days after the last day of the semester.
Academic / Student Records	Student created data/work	Exams/ graded course work / comments / participations	Course Platform	One (1) year after course completion (if the work is not returned to the student)
Academic / Student Records	Record level data for faculty or instructional staff imported into the Academic Data Warehouse	Academic Data Warehouse (ADW)	All snapshots for the current fiscal year plus prior three fiscal years.	All snapshots for the current fiscal year plus prior three fiscal years.
Accounting and Finance	Account Reconciliations (Balance Sheet)		Appropriate Department	7 years
Accounting and Finance	Accounts Payable Vouchers and Attachments		Accounts Payable Department	7 years
Accounting and Finance	Accounts Receivable Statements, Centrally Generated		Miscellaneous Receivable	7 years
Accounting and Finance	Accounts Receivable Statements, Unit Generated		Appropriate Department	7 years
Accounting and Finance	Annual Conflict of Interest Disclosure Statements		Office of the Trustees	7 years
Accounting and Finance	Annual Financial Reports and Work Papers		General Accounting	Permanent
Accounting and Finance	Banking Records	Including Deposit and Withdrawal Records, Bank Statements and Reconciliation, Voided and Canceled checks	General Accounting	7 years
Accounting and Finance	Billing Records		Appropriate Department	7 years
Accounting and Finance	Bond and Debt External Reporting – Final Executed Copies	Final Statements and reports issued for debt issuance and maintenance of the financial instrument and/or captured in the Bond Transcript (including final POS and OS). Includes regulatory and ongoing disclosures for life of the financial instrument and Bond Pricing Information. Bank documents include final executed documents.	Treasury Office	Life of the bond/swap/debt instrument plus 7 years
Accounting and Finance	Bond Issuance or Financial Analysis – Not Approved	Projects which do not move forward and are not revived	Treasury Office	No more than 2 years from last substantive revisions
Accounting and Finance	Capital Equipment Records and Equipment Inventories		Post Award Financial Operations	Records of equipment purchased on federal funds must be retained for 3 years after final disposition UG 200.333(c). If any records are under claim, audit, or litigation, they must be retained until the matter is settled.
Accounting and Finance	Cash Receipts		University Cashier	7 years
Accounting and Finance	Depreciation Records		General Accounting	Life of Asset
Accounting and Finance	Effort Certifications		Post Award Financial Operations	3 Years from the date of submission of the final expenditure report or longer if required by granting agency. UG 200.333 If any records are under claim, audit, or litigation, they must be retained until the matter is settled.
Accounting and Finance	Final Supporting Documentation for Bond or Debt Issuance (includes bond issuance, bank agreements, and swaps)	Allocation of bond proceeds, earnings of bond proceeds, rebate calculations and payments	Treasury Office	Life of the bond plus 7 years
Accounting and Finance	Financial Reports produced for the purposes of Management Oversight (e.g. Daily Indicator Report, etc.)		Treasury Office	3 years. Based on the nature of the materials the retention period may be extended
Accounting and Finance	Indirect Cost Rate Calculations		Post Award Financial Operations	3 Years after the date of submission. UG 200.333 (f)(1). If any records are under claim, audit, or litigation, they must be retained until the matter is settled.
Accounting and Finance	Internal Financial Agreements	Reports created to analyze projections needed for internal decision making	Treasury Office	2 years from the end of the agreement or repayment of the loan, whichever is sooner
Accounting and Finance	Inventories		Property Management	Life of Asset
Accounting and Finance	Journal Entries		General Accounting	7 years
Accounting and Finance	Material Information Supporting Journal Entries		Treasury Office	7 years from the date of journal entry
Accounting and Finance	New Account Records and Backup Documentation		General Accounting	7 years after account closing
Accounting and Finance	Non-final Bond or Debt Issuance Working Documents (includes bond issuance, bank agreements, and swaps)		Treasury Office	Life of the bond plus 7 years
Accounting and Finance	Procurement Card Charge Documentation		Departmental P-Card Administrator	7 years
Accounting and Finance	Service Center Rate Calculations		Post Award Financial Operations	3 Years after the end of the Fiscal Year covered by the rate calculation; UG 200.333 (f) (2). If any records are under claim, audit, or litigation, they must be retained until matter is settled.
Accounting and Finance	Swap External Reporting – Final Executed Copies		Treasury Office	Life of the swap plus 7 years
Accounting and Finance	Travel Reimbursements and Attachments		Accounts Payable Department	7 years
Accounting and Finance	University Audit Work Papers		Internal Audit	7 years
Alumni Affairs and Development	Alumni Records		Development Gifts & Records	Permanent
Alumni Affairs and Development	Gift Records		Development Gifts & Records	7 years
Alumni Affairs and Development	Original Gift Letter Agreements, All Others		General Accounting/ Development	Permanent
Alumni Affairs and Development	Planned Gifts (trusts, life income, agreements, annuities), Real Estate Gifts		Development Gift & Records	Permanent
Construction and Facilities Management	As-built Drawings		Facilities Management and Planning	Permanent
Construction and Facilities Management	Contracts and Agreements		Facilities Management and Planning	14 years
Construction and Facilities Management	Electronic facilities card access records	Including building card swipe access records	IS&T	4 years
Construction and Facilities Management	Records of Repairs		Facilities Management and Planning	7 years
Corporate Records	Accreditation Records		Office of the President	Permanent
Corporate Records	Articles of Incorporation		Office of the Trustees	Permanent
Corporate Records	Board of Trustees Minutes		Office of the Trustees	Permanent
Corporate Records	Bylaws		Office of the Trustees	Permanent
Corporate Records	Charter		Office of the Trustees	Permanent
Equal Opportunity/ Affirmative Action	Affirmative Action Plans		Equal Opportunity Office	7 years
Equal Opportunity/ Affirmative Action	Federal and State Required Statistics and Reports		Equal Opportunity Office	7 years
Equal Opportunity/ Affirmative Action	Non-Academic Search Materials and Documents Supporting Hiring Selection Decisions		Appropriate Department	3 years from date of appointment
Equal Opportunity/ Affirmative Action	Academic Search Materials and Documents Supporting Hiring Selection Decisions		Appropriate Department	3 years from date of appointment
Equal Opportunity/ Affirmative Action	Complaints of Unlawful Discrimination and Harassment		Equal Opportunity Office	Permanent
Human Resources	Certificates of Insurance, Indemnification agreements, Contracts and Insurance Policies for Benefits		Human Resources	Permanent
Human Resources	Deceased Employee Claims		Human Resources	7 years after date of death
Human Resources	Employee (Staff) Personnel File, Non-faculty	Including hire paperwork (application, cover letter, resume, offer letter), job descriptions, legacy document, onboarding records, appointment/salary forms, salary and compensation records, status changes (promotion, transfer, temporary assignment, layoff, Resignation / Termination), performance appraisals (performance evaluations, performance correspondence, corrective action, accolades), and position-related correspondence (relating to job, discrimination claims, unfair pay, etc.) Official Employee File does not include: Reference check records, background check records, Release forms, Unemployment claims, and Confidentiality Agreements. These records are retained by HR or appropriate department as part of employment.	Human Resources	7 years after separation
Human Resources	Employee (Faculty and staff) Benefits Files	Including Long-Term Disability Forms	Human Resources	7 years after separation
Human Resources	Faculty Personnel Files	Including hire paperwork, salary records, status changes, tenure/promotion, retirement/termination, and appointment recommendations	School/College of Employment	7 years after separation
Human Resources	Faculty and Staff Benefits Files	Including enrollment forms, application forms, beneficiary designations, worker’s compensation claims, MLOA/FMLA paperwork, Long-Term Disability Forms	Human Resources	Permanent
Human Resources	Federal Reporting Requirements: Welfare Benefits and other Fringe Benefit Plans	i.e., 5500-s	Human Resources	Permanent
Human Resources	Files for Disabled Employees		Human Resources	Permanent
Human Resources	I-9 Forms (Faculty and Staff)		Human Resources	3 years or 1 year after separation (whichever is greater)
Human Resources	I-9 Forms (Students)		Human Resources	3 years after employment date, or 1 year after termination (whichever is greater)
Human Resources	Individual Contracts of Employment		Human Resources or appropriate department	7 years after separation
Human Resources	Occupational Injury or Illness, Records Relating to employment		Human Resources	5 years
Human Resources	Patient Medical Records		Occupational Health Center	20 years after final treatment
Human Resources	Personnel Files for Retirees		Human Resources	7 years after separation
Human Resources	Protection of Minors Records		Human Resources	35 years from the date the victim discovered or reasonably should have discovered that an emotional or psychological injury or condition was caused by the act
Human Resources	Records Covered Under HIPAA		Human Resources	7 years after employee’s termination
Human Resources	Search Committee Records	Including employment applications, resumes, and all applicant search materials	Human Resources	7 years
Human Resources	Severance Agreements		Human Resources	7 years after expiration
Human Resources	Union Agreements		Human Resources	Permanent
Human Resources	Workers’ Compensation Claims and Insurance Policies		Human Resources	18 years
Information Security & Technology	Call Center logs	Logs of employees logging into and out of the call manager application that enables them to handle call center-routed calls	Information Security & Technology	1 year– these records are temporary and should only need to be retained to meet operational needs, then destroyed.
Information Security & Technology	Call Center Analytics	Analytics regarding the Call Center Logs	Information Security & Technology	10 years – these records will help the university understand and assess its evolving technology support needs over time
Insurance	Certificates of Insurance, Indemnification Agreements, Hold Harmless Agreements, Contracts		Office of Risk Management	7 years after expiration
Insurance	Insurance Policies (Liability, Property, and Other Policies)		Office of Risk Management	Permanent
Insurance	Incident Reports, Accident Reports		Office of Risk Management	7 years after expiration
Legal	Consent Orders		Office of the General Counsel	Permanent
Legal	Court Orders		Office of the General Counsel	Permanent
Legal	Judgments		Office of the General Counsel	Permanent
Legal	Releases		Office of the General Counsel	Permanent
Legal	Settlements		Office of the General Counsel	Permanent
Medical Records	Patient Medical Records		All units, centers or other entities that provide medical care	20 years after final treatment
Patent, Trademark, and Copyright Records	Copyright and Trademark Registrations		Office of the General Counsel or Office of Technology Development	Permanent
Patent, Trademark, and Copyright Records	Invention Assignment Forms		Office of Technology Development	Permanent
Patent, Trademark, and Copyright Records	Licensing Agreements		Office of Technology Development	7 years after termination
Patent, Trademark, and Copyright Records	Original Patents and Related Work Papers		Office of Technology Development	Permanent
Patent, Trademark, and Copyright Records	Royalty Records		Office of Technology Development	Life of Patent or TM plus 7 years
Payroll	Annual Payment Records		University Payroll Office	Permanent
Payroll	Information Returns filed with Federal and State authorities	W-2, 941, 1042S, etc.	University Payroll Office	7 years
Payroll	Payroll Deduction Authorization Forms (W4, ACH, Bonds)		University Payroll Office	5 years after employment ends
Payroll	Payroll Vouchers		University Payroll Office	3 years
Payroll	Record of Payments and Deductions	Payroll registers, deductions lists, adjustments	University Payroll Office	5 years
Payroll	Time Cards, student		Appropriate Department/ Electronic, Student Employment	3 years after pay date
Payroll	Time Cards, non-student		Appropriate Department	3 years
Public Safety Environmental Health and Safety	Accident Reports		University Police	7 years after report date
Public Safety Environmental Health and Safety	Crime Reports		University Police	7 years after report date
Public Safety Environmental Health and Safety	Daily Log		University Police	Permanent
Public Safety Environmental Health and Safety	Property Damage Reports		University Police	7 years after report date
Public Safety Environmental Health and Safety	Fume Hood Testing Records		Environmental Health and Safety	3 years
Public Safety Environmental Health and Safety	Hazardous Waste Disposal Manifests and Reports		Environmental Health and Safety	3 years
Public Safety Environmental Health and Safety	Incident Records		Environmental Health and Safety	5 years
Public Safety Environmental Health and Safety	Radiation Safety Training Records		Environmental Health and Safety	3 years
Purchasing	Purchase Orders, Contracts, Agreements		Purchasing Department	7 years
Real Property	Property Deeds, Easements, Licenses, Rights of Way, Leases, Rights of First Refusal, Remainder Interests, Mortgages		Office of the General Counsel	Permanent
Real Property	Property Tax Returns filed with taxing jurisdiction		General Accounting	7 years
Sponsored Projects, Contracts, and Grants	Grant and Contract Applications, Proposals, and Supporting Documentation		Sponsored Programs	3 Years from the date of submission of the final expenditure report or longer if required by granting agency. UG 200.333
Sponsored Projects, Contracts, and Grants	Records Concerning Human Subject Records		Office of Research Compliance	7 years from completion of study or longer if required by study sponsor
Taxes	Excise Tax Returns		General Accounting	7 years
Taxes	Information Returns	990, 1099, Form PC, etc.	Financial Affairs	20 years
Taxes	Sales Tax Returns		General Accounting	7 years

Descriptive Retention Schedule Examples from Univ of Washington

Select Retention Schedule Recommendations from State of Arizona

Pursuant to ARS §41-151.12(3), only the Arizona State Library, Archives and Public Records has the authority to set retention periods, including the sole authority to modify, extend or decrease records retention periods. The retention periods listed herein are the required time records must be retained. Records should be promptly and orderly disposed of at the end of their retention period. Keeping records longer than the retention period poses financial, legal, audit and investigative risks to the Agency. These risks need to be considered by State and Local Agencies when there is a compelling need to retain records for a longer period of time than the approved retention period. Records required for ongoing or foreseeable official proceedings such as audits, investigations or lawsuits, must be retained until released from such official proceedings, notwithstanding the instructions of this schedule.

Laura Palma-Blandford, State Archivist – Arizona State Archives and Records Management

Full document available here.

Common University Stakeholder Groups Involved in a Retention Schedule

Academic/Student Records
Admissions Offices
Accounting and Finance
Alumni Affairs and Development
Construction and Facilities Management
Corporate Records
Equal Opportunity/ Affirmative Action
Human Resources
Information Security & Technology
Insurance
Legal
Medical Records
Patent, Trademark, and Copyright Records
Payroll
Public Safety
Environmental Health and Safety
Purchasing
Real Property
Sponsored Projects, Contracts, and Grants
Taxes