College-Wide Record Retention Policy and Schedule

Purpose

This policy defines the standards and procedures for retention, handling, and disposition of college records.

Scope

This policy applies to all departments at Keuka College.

Policy Statement

Keuka College requires retention of college records, regardless of format, for specific periods of time in accordance with federal, state, and other legal and institutional requirements. The College is committed to effective and consistent record management that:

Maintains the privacy and security of institutional and constituent information.
Ensures records are retained for the required duration.
Preserves records of historical value.
Requires disposal of outdated and unnecessary records in a manner appropriate for the format.
Optimizes the use of space.
Minimizes the costs associated with record retention.
Managing college records.

The designated official(s) must maintain the official copy of a college record for the required duration outlined in records retention schedule and must dispose records in a manner appropriate for the record format.

Departments that are not designated as the official repository must dispose of duplicate copies of college records in an appropriate manner when there is no longer an administrative need for them. Retaining records when there is no legal requirement to do so places an additional burden on the College. Offices in need of specific information should request the information from the official holder of the records.

Records containing personal identifying information must be protected against theft. If such records are accessed inappropriately or lost, the College could be subject to fines, penalties, costs to notify individuals whose records were breached, and loss of reputation. Mishandling of college records or data could lead to disciplinary action. Please see the Data Classification Policy in support of this policy.

Electronic Storage

Electronic record storage polices and applications are governed by the IT Department. Electronic documents stored within the College’s various storage applications will be archived on a set schedule. Special storage will be provided for documents that are required to be retained for longer than 7 years. The retention policy within these platforms will be determined based on current best practices and following regulatory compliance.

Document Disposal

Departments are required to perform record disposition regularly, at least once each year. When disposing of records, departments must destroy them in an appropriate manner:

Recycle non-confidential paper records.
Shred or render unreadable records with confidential information.
Utilize a confidential disposal bin that will be emptied and disposed of by Keuka College Facilities utilizing black plastic trash bags; these papers are not recycled.
Erase electronically stored non-confidential records.
Overwrite or physically destroy the media on which confidential electronic records are stored.

Records that have been entered into the College’s database or system of record (SIS) do not need to be purged.

Record Retention Schedule

Student Record
Type of Record	Official Repository	Duration
Academic action documentation (withdrawal, leave of absence)	Records and Registration Office	6 years from graduation or last date of attendance
Academic integrity code violations (findings of violation and related case files)	Appropriate college	Permanent
Academic records (petitions, degree audits, change of registration/program forms, etc.)	Records and Registration Office	6 years from graduation or date of last attendance
Attendance Records	Records and Registration Office	6 years
Conferred Degrees	Records and Registration Office	Permanent
Consent for record disclosure and request for non-disclosure	Records and Registration Office	1 year after the request has been terminated
Degree requirement exceptions/changes	Records and Registration Office	6 years from graduation or date of last attendance
Enrollment verification and transcript requests	Records and Registration Office	1 year from submission date
FERPA documents: requests for nondisclosure of directory information and request for termination of nondisclosure of directory information	Records and Registration Office	Permanent
Final Official Grades	Records and Registration Office	Permanent
Grade Changes	Records and Registration Office	Permanent
Holds (registration, financial, etc.)	Originating office	Until released
International partnership/overseas program records and correspondence	Office of Records and Registration	6 years
Name Change	Records and Registration Office	6 years from graduation or last date of attendance
Student Class Schedule (including location, modality, time)	Records and Registration Office	6 years
Transcripts	Records and Registration Office	Permanent
Transfer credit evaluations	Records and Registration Office	6 years from graduation or date of last attendance
Advising Records	Appropriate department	1 year from graduation or last date of attendance
Veterans Administration certification of eligibility	Office of Financial Aid	5 years from graduation or last date of attendance
Scholarship/Award Records	Office of Financial Aid	6 years
On-Campus Residency Records	Office of Student Life	7 years
Residence Hall Damage Records	Office of Student Life	7 years
Student Complaint/Grievances	Office of Student Life	7 years
Student Activity and Organization Records	Office of Student Life	7 years
Disciplinary records (findings of violation and related case files), where penalty imposed is suspension or expulsion	Office of Student Life	Permanent
Disciplinary records (findings of violation and related case files), where penalty imposed is probation	Office of Student Life	7 years
Disciplinary records (findings of violation and related case files), where penalty imposed is NOT probation, suspension, or expulsion, but includes a reprimand	Office of Student Life	Until the student’s graduation
Disciplinary records (findings of violation and related case files), where penalty imposed is NOT probation, suspension, or expulsion, but includes a warning	Office of Student Life	Until the student’s graduation
Disciplinary records (entire case files, including records of any hearing, regardless of whether there are findings of violation) for any formal complaint for the following prohibited conduct: Dating Violence; Domestic Violence; Sexual Assault; Sexual Exploitation; Sexual and Gender-Based Harassment; Stalking; Aiding Prohibited Conduct; Attempting to Commit Prohibited Conduct; Retaliation; and Violating an Interim Measure.	Office of Student Life	7 years from the date of a final, binding decision

Student Finances
Type of Record	Official Repository	Duration
General Correspondence and Records	Office of Student Accounts	6 years
Cashier reports	Office of Student Accounts	6 years
Transaction reports and listings	Office of Student Accounts	1 year
Disclosure statements	Office of Student Accounts	3 years after account has been paid in full
Student loan records	Office of Financial Aid	3 years after the loan has been repaid in full
Tuition and fee charges	Office of Student Accounts	6 years
State financial aid documents	Office of Financial Aid	5 years
Financial aid reports	Office of Financial Aid	5 years
Federal financial aid documents	Office of Financial Aid	Permanent
Student bankruptcy records	Office of Financial Aid	6 years after the case closes

Admissions, Applicants Who Do Not Enroll
Type of Record	Official Repository	Duration
Applications for admission or readmission, relevant correspondence, entrance exam reports (ACT, CEEB, et.al.), letters of recommendation, transcripts (high school and other colleges), and other application materials	Office of Admissions	2 years from start of application term
Application materials for international students	Office of Admissions	3 years
Financial aid records	Office of Financial Aid	1 year from start of application term

Admissions, Applicants Who Enroll
Type of Record	Official Repository	Duration
Applications for admission or readmission, relevant correspondence, entrance exam reports (ACT, CEEB, et.al.), letters of recommendation, transcripts (high school and other colleges), and other application materials	Records and Registration Office	6 years from graduation or date of last attendance
Application materials for international students	Office of Admissions	3 years
Financial aid records	Office of Financial Aid	5 years from graduation or date of last attendance
International student forms (visa documentation, financial certification, etc.)	Office of the PDSO	5 years from expiration date of immigration document
Letters of recommendation (including waiver for right of access)	Office of Admissions	Until date of matriculation
Recruitment materials	Office of Admissions	Until date of matriculation
Transcripts (high schools and other colleges)	Records and Registration Office	65 years from graduation or date of last attendance

Academic Course Information
Type of Record	Official Repository	Duration
Class Rosters	Records and Registration Office	Permanent
Course offerings and schedule of classes	Records and Registration Office	Permanent
Grade books	Appropriate academic department	5 years after completion of course
Graded course materials (homework, exams, etc.)	Appropriate academic department	1 year after completion of course
Curriculum development records and proposals	Office of the Provost	7 years
Course Syllabi	Office of the Provost	Sufficient to meet operational needs

Library
Type of Record	Official Repository	Duration
Circulation records, excluding special collections	Library Department	Retained until items are returned and discharged
Circulation records for special collections	Library Department	Permanent
Library Annex location records	Library Department	Permanent
Library catalog	Library Department	Permanent
Licensing agreements	Library Department	7 years from expiration or termination of agreement

Publications, Research, Reports, Grants
Type of Record	Official Repository	Duration
Recruitment Materials	Office of Marketing and Communications	3 years
Commencement programs	Records and Registration Office	Permanent
Course catalogs	Records and Registration Office	Permanent
Student degree, enrollment, and racial/ethnic reports and publications	Office of Institutional Effectiveness	Permanent
Required Compliance Reports (IPEDS, DOE, NYSED, etc.)	Office of Institutional Effectiveness	12 years
Grant and contract proposals, awards, agreements and supporting documentation	Office of Institutional Effectiveness	6 years after close of grant for New York State 3 years after close of grant (including filing of final financial report) for federal and all other grants and contracts
Animal welfare records	Office of Institutional Effectiveness	3 years or contract period
Disclosures of external financial interests and commitments	Office of Institutional Effectiveness	5 years post-disclosure or 5 years after the grant period has ended (whichever is later)
Export control records	Office of Institutional Effectiveness	5 years after the grant period has ended
Institutional biosafety committee records, including biohazardous agents, recombinant DNA molecules, gene therapy	Office of Institutional Effectiveness	5 years after the grant period has ended
Institutional review board for human participants records	Office of Institutional Effectiveness	5 years after grant period has ended for the full record Permanent for selected records
Scientific misconduct records	Office of Institutional Effectiveness	10 years after the grant period has ended

Faculty And Academic Personnel
Type of Record	Official Repository	Duration
Academic Contracts	Office of the Provost
Academic search records	Office of the Provost	1 year after hire date
Student Evaluations (SEIs)	Office of the Provost	3 years after termination
Grievances	Office of the Provost	No cause findings: 3 years from determination Cause findings, Permanent
Evaluation appointment letters, and forms	Office of the Provost	6 years after termination
Tenure or promotion dossiers	Office of the Provost	If action approved, 3 years; If tenure denied, 3 years from end of term appointment
Trustee decisions regarding academic personnel and designated executives	Office of the President	Permanent

Human Resources
Type of Record	Official Repository	Duration
Employee personnel files (including application, resume, payroll, appointment/salary forms, background check)	Office of Human Resources	6 years after termination
Federal reporting requirements: welfare benefits and other fringe benefit plans (i.e., 5500-s)	Office of Human Resources	Permanent
I–9 Forms (faculty and staff)	Office of Human Resources	3 years after termination
I–9 Forms (students)	Office of Human Resources	3 years, or 1 year after termination (whichever is greater)
Individual contracts of employment	Office of Human Resources	6 years after termination
Occupational injury or illness, records relating to	Office of Human Resources	5 years
Performance appraisals	Office of Human Resources	6 years after termination
Search committee records, including employment applications, resumes, and all applicant search materials	Office of Human Resources	1 year after hire date
Workers' compensation claims and insurance policies	Office of Human Resources	18 years
Documents supporting other academic and nonacademic employment decisions (e.g., promotion, termination, compensation)	Office of Human Resources	6 years after termination
Federal and state-required statistics and reports	Office of Human Resources	3 years
A record (list) of complaints of prohibited discrimination and protected status (including sexual) harassment	Office of Human Resources	Permanent
A record of reported bias activity	Office of Human Resources	Most recent 3 years
Records generated in the investigation of protected status (including sexual) harassment complaints or complaints of discrimination that are dismissed, or where parties do not pursue	Office of Human Resources	3 years
Records generated in the investigation of protected status (including sexual) harassment complaints or complaints of discrimination that result in a finding of merit	Office of Human Resources	Permanent

Payroll
Type of Record	Official Repository	Duration
Annual payment records (W-2, alpha lists, employee transaction lists)	Office of Human Resources	7 years
Income records	Office of Human Resources	7 years
Information returns filed with federal and state authorities (W-2, 941, 1042-S, etc.)	Office of Human Resources	7 years
Labor distribution adjustment records	Office of Human Resources	6 full fiscal years
Leave reporting records, exempt employees	Office of Human Resources	6 years after termination
Leave reporting records, nonexempt employees	Office of Human Resources	7 years
Payroll deduction authorization forms (W-4, IT-2104, garnishments, etc.)	Office of Human Resources	7 years
Payroll vouchers	Office of Human Resources	7 years
Record of payments and deductions (payroll registers, deductions lists, adjustments)	Office of Human Resources	7 years
Timecards	Office of Human Resources	7 years
Wage assignment orders	Office of Human Resources	7 years

Administration
Type of Record	Official Repository	Duration
Inaugural Records	Office of the President	Permanent
Executive correspondence/email regarding legal matters, fiscal matters, administrative matters, and/or other non-routine messages/letters of importance	Content will determine the appropriate retention period and location of correspondence/email	Permanent
Executive minutes and meeting proceedings	Content will determine the appropriate retention period and location of minutes and meeting proceedings	Content will determine the appropriate duration
Reports - annual, faculty, statistical, strategic, etc.	Appropriate department	Permanent
Accreditation records	Office of Institutional Effectiveness	Permanent
Board of Trustee minutes	Office of the President	Permanent
Bylaws	Office of the President	Permanent
Charter	Office of the President	Permanent
College policies	Office of Institutional Effectiveness, or designated Department	Permanent
Memoranda of understanding	Appropriate department	Permanent

Finance
Type of Record	Official Repository	Duration
Internal Audits	Department of Finance and Administration	5 years
Federal Audits	Department of Finance and Administration	5 years
State Audits	Department of Finance and Administration	5 years
External Non-Governmental Audits	Department of Finance and Administration	5 years
Account reconciliations (balance sheet)	Department of Finance and Administration	6 years
Accounting reports (monthly reports) schedules of department balances, transaction statements, account analysis statements, monthly and year-to-date salary and wage statements	Department of Finance and Administration	6 full fiscal years
Accounts payable vouchers and attachments	Department of Finance and Administration	6 full fiscal years
Accounts receivable statements, centrally generated	Department of Finance and Administration	6 full fiscal years
Accounts receivable statements, unit generated	Department of Finance and Administration, or designated department	6 full fiscal years
Annual financial reports	Department of Finance and Administration	Permanent
APPS invoices	Department of Finance and Administration	6 full fiscal years
Banking records, including deposit and withdrawal records, bank statements and reconciliations, voided and canceled checks	Department of Finance and Administration	6 full fiscal years
Billing records	Department of Finance and Administration	6 years
Board of Trustees audit committee minutes	Office of the President	Permanent
Capital equipment records	Department of Finance and Administration	Life of asset: records of equipment purchased on federal funds must be retained for 3 years after final disposition
Cash receipts	Department of Finance and Administration	6 full fiscal years
Depreciation records	Department of Finance and Administration	Life of asset
Effort certifications	Department of Finance and Administration	6 full fiscal years
Facilities and administrative cost and benefit rate calculations	Department of Finance and Administration	7 years
Inventories	Appropriate Department	Life of asset
Journal entries and back-up documentation	Department of Finance and Administration	6 full fiscal years
KFS e-docs, including supporting documentation such as invoices, vendor quotes, etc.	Department of Finance and Administration	6 full fiscal years (uploaded electronic copy or original documentation not uploaded [e.g., confidential material]) 60 days (original paper documents, included in uploaded electronic copy)
New account records and back-up documentation	Department of Finance and Administration	6 full fiscal years after account closing
Payment authority authorizations	Department of Finance and Administration	6 full fiscal years
Procurement card charge documentation	Department of Finance and Administration	60 days for all fund types
Subsidiary ledgers (accounts payable, accounts receivable, etc.)	Department of Finance and Administration	6 full fiscal years
Travel reimbursements and attachments	Department of Finance and Administration	6 full fiscal years
College Audit work papers and reports	Department of Finance and Administration	6 years
Work papers for annual financial reports	Department of Finance and Administration	6 full fiscal years
Budget plans and projections	Department of Finance and Administration	Permanent
Excise tax returns	Department of Finance and Administration	7 years
Income tax returns (990-T, CT-13, etc.)	Department of Finance and Administration	Permanent
Information return (990)	Department of Finance and Administration	Permanent
Purchase orders, contracts, agreements	Purchasing Office	7 full fiscal years
Information returns (1099, 8282, 90.22, etc.)	Department of Finance and Administration	7 years
Sales tax returns	Department of Finance and Administration	6 years

Real Estate
Type of Record	Official Repository	Duration
Abstracts of title	Department of Finance and Administration	Until disposal of property
Documents for leases, licenses, construction contracts and other contracts of a temporary nature, valued at less than $50,000	Department of Finance and Administration	6 years after expiration of lease or contract term
Property deeds, easements, licenses, rights of way, leases, rights of first refusal, remainder interests, mortgages, survey maps	Department of Finance and Administration	Permanent
Real property tax exemption applications and renewal forms filed with assessors	Department of Finance and Administration	6 years
Title insurance policies	Department of Finance and Administration	10 years after disposal of property

Insurance
Type of Record	Official Repository	Duration
Certificates of insurance	Department of Finance and Administration	Permanent
Incident reports, accident reports	Office of Human Resources	4 years after report date or until claim is settled or closed
Indemnification agreements, hold-harmless agreements, contracts	Department of Finance and Administration	3 years
Insurance policies (liability, property, and other policies)	Department of Finance and Administration	Permanent

Legal
Type of Record	Official Repository	Duration
General Legal Files	Department of Finance and Administration	20 years
Claims Files	Department of Finance and Administration	10 years
Legislation Files	Department of Finance and Administration	15 years
Court orders	Department of Finance and Administration	Permanent
Judgments	Department of Finance and Administration	Permanent
Releases	Department of Finance and Administration	Permanent
Settlements	Department of Finance and Administration	Permanent

Facilities
Type of Record	Official Repository	Duration
Construction documentation	Facilities	Permanent
Contracts, agreements, and certificates of insurance	Facilities	10 years

Health and Counseling
Type of Record	Official Repository	Duration
Medical Documentation	Health and Counseling	7 years
Counseling Services	Health and Counseling	6 years
Medical Staff Credentialing	Office of Human Resources	Permanent
Infection Control	Health and Counseling	10 years
HIPAA Disclosures	Health and Counseling	6 years
Health and Counseling Policies and Procedures	Health and Counseling	Permanent
Student Disability Records	Office of Student Accessibility	6 years after graduation or last date of attendance

Environmental Health and Safety
Type of Record	Official Repository	Duration
Confined space entry – completed permits	Facilities	1 year
Evacuation drill records	Office of Campus Safety	5 years
Exposure monitoring records	Facilities	30 years
Fire protection systems records	Facilities	5 years
Fume hood testing records	Facilities	3 years
Hazardous waste disposal manifests and reports	Facilities	3 years
Homeland security chemical lists	Office of Campus Safety	3 years
Injury and illness reports	Office of Campus Safety	5 years
OSHA training records	Office of Human Resources	Until end of employment
Radiation dose reports	Facilities	Permanent
Radiation safety training records	Facilities	3 years
Radioactive materials license and safety committee records	Facilities	Permanent
Radioactive material receiving and inventory records	Facilities	3 years
Select agent records and correspondence	Responsible Department	3 years

Public Safety
Type of Record	Official Repository	Duration
Accident reports	Office of Campus Safety	Permanent
Crime reports	Office of Campus Safety	Permanent
Property damage reports	Office of Campus Safety	Permanent
Annual security report	Office of Student Life	Permanent
Crime Statistics	Office of Campus Safety	7 years
Crime Logs	Office of Campus Safety	7 years
Law Enforcement Reports	Office of Campus Safety	Permanent
Parking Permit Records	Office of Campus Safety	2 years
Parking Violation Records	Office of Campus Safety	2 years

Alumni and Advancement
Type of Record	Official Repository	Duration
Alumni records	Department of Advancement and Alumni Relations	Permanent
Donor Records	Department of Advancement and Alumni Relations	Sufficient to meet operational needs
Gift records	Department of Advancement and Alumni Relations	7 years
Original gift letter agreements, signed by the President and the donor	Department of Advancement and Alumni Relations	Permanent
Original gift letter agreements, all others	Department of Advancement and Alumni Relations	Permanent
Planned gifts (trusts, life income, agreements, annuities), real estate gifts	Department of Advancement and Alumni Relations	Permanent
Alumni Association Records	Department of Advancement and Alumni Relations	Sufficient to meet operational needs

Athletics
Type of Record	Official Repository	Duration
Scouting files for athletes who enroll	Athletics	7 years
Athlete rosters and game schedules	Athletics	7 years
Videos and reports used for scouting and training	Athletics	Sufficient to meet operational needs
Records of gender equity in athletics	Athletics	7 years
Athletic Training Records	Athletics	7 years
Athletic health information	Athletics	7 years
NCAA eligibility certifications	Athletics	7 years

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