Document Retention

Effective Date: February 6, 2018

Policy Statement

In accordance with federal, state, local applicable laws, rules and regulations, Iona University requires that College records be retained for specific periods of time, and be maintained in specific repositories. The records will be properly and diligently upheld by following the rules and regulations of this document. This policy relates to original, tangible, hard-copy documentation and does not apply to an electronic record which will be addressed in a separate policy for all electronic formats.

Reason for Policy

Iona University is enthusiastic to achieve accurately and legally responsible record retention to allow us to be historically accountable. The policy’s purpose is to include any hard copy record made, produced or received by any department, employee, or office of the University. The policy will apply to all record documents in paper and other traditional media formats. Individual departments are capable of intensifying procedures if they are consistent with the given policy.

The intention of the policy is to provide the University with an organized procedure and schedule that will comprise of:

• Meeting legal standards
• Optimizing the use of electronic and physical storage space
• Minimizing costs related to record retention
• Maintaining the history of the University
• Properly destroying outdated and useless records

Who Should Know the Policy?

All College Faculty and Staff, Independent Contractors, and Board of Trustee members that is responsible for the accurate creation, placement or usage of any record for Iona University.

• v Recycle non-confidential paper records
• v Shred or otherwise render unreadable confidential paper records

Definitions

• Active Record: An original College Record currently used by the office, department or other area of the University that generated it. Active Records remain active for varying numbers of years, depending on the purpose for which they were created and regulatory requirements. Active Records may be retained in the originating office or at an offsite storage company.
• Data Owners: Each department that maintains records, financial information, employee information either in electronic or paper form, is required to designate an individual who will ensure that records in his or her area are preserved, maintained and retained in compliance with policies and retention schedules.
• Destruction of Iona University information and records: At the end of the designated retention period for each type of information or record, destruction will take place in accordance with the procedures in this policy unless a legal hold/preservation order exists or is anticipated. Destruction will be finalized through shredding and incineration. Each Department Manager will be responsible for signing off on what is to be destroyed in their area.
• Historical Record: Materials made or acquired and preserved solely for reference or exhibition purposes.
• Inactive College Records: An original College Record that is not an Active Record but still must be maintained pursuant to the Record Retention Table set forth below
• Personal Information: Records that include an individual’s name together with that individual’s demographic information, date of birth, Social Security Number; drivers’ license number or New York state identification card number; financial account number, or credit or debit card number, with or without any required security code, access code, personal identification number or password that would permit access to an individual’s financial account; or biometric indicator. Personal Information is highly sensitive, and must be safeguarded and secured at all times.
• Permanent Record: Document which is retained permanently because of its administrative, historical, or legal value. For example a student transcript is a student's permanent academic record of all courses taken, all grades received, all honors received and degrees conferred.
• Property Rights: All records generated and received are the property of Iona University. No employee, by virtue of his or her position, has any personal or property right to such records even though he or she may have developed or compiled them.
• College Record: The original or official copy of any record/document. The Official Repositories for these records are identified in the table at the end of this document. There is no need for offices and departments that are not the Official Repository for a College Record to retain copies of those records.
• Record Retention Schedule: The document identifying types of records that, for business and/or legal reasons, are subject to mandatory retention for a specific period of time.
• Unauthorized Destruction: The unauthorized destruction, removal, alteration, or use of information and records is prohibited.
• Workforce Responsibility: All employees and agents are responsible for ensuring that Iona University information and records are created, used, maintained, preserved, and destroyed in accordance with this policy.

Record Disposal

After accurately reviewing the retention schedule and the University's policy, you can determine whether or not it is suitable to dispose of a record(s). In the event they are applicable for destruction these are the following ways to dispose:

• Recycle non-confidential paper records
• Shred or otherwise render unreadable confidential paper records
• Erase or destroy electronically stored data (ask IT department for assistance).

For questions regarding responsibilities or confusion relating to retention please contact the Data Owners or General Counsel.

General

Any record that is part of a current audit, investigation or litigation may not be destroyed even if the time period for retention per College policy has elapsed. Ultimately, if there is any such doubt regarding the ability to destroy a document you should follow the retention schedule. If unsure, check with the Data Owners or General Counsel.

Record Retention Schedule