Records Retention and Destruction Policy

Date Established: May 2012
Approved by: Officers
Responsible Office: Finance & Administration
Responsible Senior Staff Member: VP of Finance & Administration
Drafted by: Head of Archives and Special Collections & Dir. of Compliance and Risk Mgmt
Date Last Revised: February 2020       

Statement 

Mount Holyoke College requires that college records, as defined herein, regardless of format, whether created on college owned equipment or otherwise, or whether the document is stored on campus or otherwise, be disposed of or retained for specific periods of time in accordance with legal or other institutional requirements, or for historical value. The college has designated offices of record to manage the retention and disposal of these records according to procedures outlined in this document.

Scope

The purpose of this policy is to:

  1. Define Mount Holyoke College records;
  2. Define the responsibilities of departments and employees for college records;
  3. Define Archives and Special Collections’ authority over college records;
  4. Provide best practices for managing college records.

This policy provides guidelines for retention and destruction of official college records. It applies to all college departments and offices, all college records and all college employees who create, receive or maintain such records in the course of college business.

Responsibilities

All members of the College community who create, receive, or maintain college records are responsible for ensuring that retention and destruction methods are compliant with this policy and the related standards.

Policy

Mount Holyoke College and various federal and state laws require that different types of records be retained for specific periods of time. The College has designated official repositories and a retention schedule for maintenance of these records. These records should be managed according to procedures that are outlined in this document.

Procedures

Managing College Records

Certain departments and units are designated as the “Office of Record” as listed in the retention schedule. Offices of Record are responsible for establishing and maintaining appropriate records retention management practices. Departments are expected to destroy records for which they are not the office of record, once they become inactive records. 

Each Office of Record administrator or a designee must do the following:  

  • Implement the office’s records management practices  
  • Ensure that these records management practices are consistent with this policy  
  • Educate staff within the administrative unit in understanding sound records management practices  
  • Preserve inactive records of legal, fiscal, administrative, or historical value. 
  • Transfer Archival Records with permanent legal, institutional, or historical value to Archives and Special Collections 
  • Ensure that access to confidential files is restricted
  • Destroy inactive records that have no archival value upon expiration of the applicable retention period 
  • Direct questions about these responsibilities to Archives and Special Collections who will work closely with offices to ensure understanding of this policy and implementation of these responsibilities.

Preservation of Archival Records

Material selected for preservation shall be sent to Archives and Special Collections. When selecting records for preservation the record holder must first consult with Archives and Special Collections. Archives and Special Collections provides all departments and offices at Mount Holyoke College with records management services for permanent records. All official records that are permanently preserved remain accessible to relevant parties as determined by the records retention schedule. Electronic records of permanent or enduring value will be preserved in a way that appears best to allow future accessibility of their content. 

Destruction of Records

Records should be deleted/destroyed in ways commensurate with their confidentiality and with methods which do not permit recovery, reconstruction or future use of confidential information. For example:

Paper records containing confidential information (such as personally identifiable information) should be shredded, not placed in recycle bins and not simply thrown out with other classes of records or with miscellaneous trash.

Electronic or machine readable records containing confidential information should be deleted/destroyed through thorough degaussing, multiple overwrites, or physical destruction of drives, disks, tapes or other magnetic or electronic storage media to ensure proper destruction. It is the responsibility of the office/department or individual in possession of a College owned computer(s) to ensure that data has been properly removed from the hard drives of computers before removal or redeployment. Consult the LITS helpdesk for any assistance.

Film, audio, recording and videotapes containing confidential information should be physically destroyed, not simply thrown away. 

Destruction performed by vendors shall be subject to the same procedures as those which are described in this policy. 

Litigation Hold

The Office of Record may not destroy a college record if that office has been notified of any audit, litigation, claim, negotiation, or other action involving the record. Records must be maintained until all required audits and requests are completed. If a litigation or legal hold is issued, records relevant to the issue must be preserved until the hold has been released.

If College Records are maintained with a vendor, the Office of Record, or their designated authority, will need to issue a litigation hold notice to the vendor managing that College Record.

E-mail

As stated above, e-mail messages that meet the criteria of a Record defined herein should be preserved in hard copy or stored electronically separately from e-mail systems for record retention and archival purposes.

Accessibility of Records

College Records must be easily retrievable for examination by authorized departmental and central administrators, auditors and other authorized individuals. The Office of Record must follow procedures for labeling and record-keeping to ensure that documents can be retrieved in a timely manner, and are responsible for retrieving records upon request. 

The Office of Record, in consultation with LITS, are responsible for ensuring that electronic records are not rendered unusable because of changing technology or deterioration. Records in formats endangered by technology changes must be migrated to other formats in order to maintain accessibility.

General Data Protection Regulation (GDPR) Requests

If a request is received in accordance with GDPR, destruction may take place before the time set forth in the schedule. Please consult the LITS helpdesk for assistance in complying with the request.

Definitions

College Record: Any form of recorded information, regardless of physical characteristics, that is created, received, recorded, or legally filed in the course of college business. College records serve as evidence of the college’s organization, functions, policies, decisions, procedures, operations, transactions, or other activities. 

[Note: An official record can be in hard-copy form (e.g., paper, magnetic tape, film, etc.) or electronic form. An electronic document (e.g., email, cloud-based documents, etc.) is considered a college record and is subject to the same retention period as the hard copy equivalent if the electronic document is created or received in the transaction of business; retained as evidence of official policies/decisions; and/or has historical significance or valuable informational content.]

Active Record: A record with current use for the unit, department, or division that generated it. Records remain active for varying numbers of years, depending on the purpose for which they were created.

Inactive Record: A record with no current use for the unit, department, or division that generated it and that has not yet reached the end of its retention period. 

Archival Record: A record that is no longer required by the unit, department, or division in which it originated or was received, and that has permanent legal, institutional, or historical value. 

Office of Record: The unit, department, or division designated as having responsibility for retention and timely destruction of particular types of college records. Such responsibility is assigned to the Unit’s administrator or a designee. Offices of Record are identified in the Retention Schedule below.

Policy Violations

Violations of college policies are adjudicated according to procedures outlined in the Student Handbook, the Handbook of Faculty Legislation, and the Staff Handbook, with disciplinary consequences imposed by the adjudicating authority up to and including dismissal. Some offenses are punishable under state and federal laws.

Retention Schedule

Record Type Record Sub-Type Office of Record Retention Period
Student Records Application materials: Old paper, current paper, electronic, decision letters Admission until graduation for matriculants; 2 years for non-matriculants
Financial Records Gift Accounting; Gift & Pledge Records Advancement 2 years
Financial Records Gift Accounting; Stock Gifts Advancement 2 years
Financial Records Gift Accounting; Adjustments Advancement 2 years
Administrative Records Committee Files Advancement Permanent
Financial Records Private Source Grant Records Advancement Permanent
Financial Records Grant and Contracts Accounting Records Advancement Permanent
Financial Records Event Contracts Advancement Permanent
Operations Records Funded Grant Proposals Advancement Permanent
Operations Records Unfunded Grant Proposal Records Advancement Permanent
Operations Records Stewardship; Documentation on Plaques, Benches, Trees Advancement Permanent
Operations Records Communications Advancement Permanent
Operations Records Events Advancement Permanent
Operations Records Database Reporting Advancement Permanent
Operations Records Database of Record Information (colleague data) Advancement Permanent
Financial Records Stewardship; Gift Agreements, Annual Reports, Financial Reports Advancement Permanent / Varies
Operations Records Research & Leadership Gifts Constituent Files Advancement Permanent / Varies
Operations Records Research Class / Parents & Friends Files Advancement Permanent / Varies
Financial Records Gift Planning Documentation Advancement Varies
Administrative Records Employee Administration Advancement / HR Permanent
Administrative Records Report Requests Alumnae Association 1 year
Financial Records Bank reconciliations Alumnae Association 2 years
Financial Records Contracts Alumnae Association 7 years
Financial Records Invoices to customers  Alumnae Association 7 years
Administrative Records Biographical alumnae files and class info files Alumnae Association Permanent
Administrative Records Events Alumnae Association Permanent
Operations Records Database Reporting Alumnae Association Permanent
Operations Records Database of Record Information (colleague data) Alumnae Association Permanent
Financial Records Bylaws of the Association and class and clubs Alumnae Association Permanent
Financial Records Tax  Alumnae Association Permanent
Financial Records Legal Alumnae Association Permanent
Operations Records Real Property leasing and Rental Records Amherst College Rental Housing  
Financial Records Form 990/990T & support Associate Treasurer 20 years
Financial Records wire transfer records Associate Treasurer 5 years
Financial Records Gift batches Associate Treasurer 5 years
Financial Records Government Grant Files Associate Treasurer active + 3 years
Financial Records Property records Associate Treasurer Active + 5 years
Financial Records Mortgage, bond & long-term debt records Associate Treasurer Active + 5 years
Financial Records Sales of Property Records Associate Treasurer Active + 5 years
Financial Records Budget Reports Associate Treasurer Active + 5 years
Financial Records Deeds & Titles Associate Treasurer Perm
Financial Records Deeds & Titles for donated real property later sold Associate Treasurer perm
Financial Records attorney opinion letters (real estate) Associate Treasurer perm
Financial Records Unitrust tax returns & support Associate Treasurer perm
Financial Records Life Inc Agreements Associate Treasurer perm
Financial Records Estate Files Associate Treasurer perm
Financial Records Closed out accounts Associate Treasurer perm
Financial Records Endowment Funds Reports Associate Treasurer perm
Financial Records Ref Sub-ledger Associate Treasurer perm
Financial Records Restricted Funds Ledger Associate Treasurer perm
Financial Records Statement of Changes Associate Treasurer perm
Financial Records Numeric Ref ledger Associate Treasurer perm
Financial Records Investment Cmte Minutes Associate Treasurer Permanent
Legal Records Outside group contracts  Athletics 3 years
Legal Records Certificates of insurance Athletics 3 years
Legal Records Participant waivers Athletics 3 years
Operations Records Sexual Assault Records Campus Police 11 years from report
Operations Records Armed Robbery Reports Campus Police 11 years or until suspect no longer incarcerated
Administrative Records Parking Tickets Paid Campus Police 2 years
Operations Records Stolen Motor Vehicle Reports Campus Police 3 years
Operations Records Protective Custody Reports Campus Police 3 years
Operations Records Missing Person Reports Campus Police 3 years after case solved
Operations Records Campus Police Complaint/Internal Affairs Records Campus Police 4-7 years following resolution
Employment Records Campus Police Background Invests, Unsuccessful Campus Police 5 years
Employment Records Campus Police Psychological Pre-Screening, Unsuccessful Campus Police 5 years
Operations Records General Incidents Campus Police 7 years
Operations Records Motor Vehicle Accidents Campus Police 7 years
Operations Records Clery Act Daily Crime and Fire Log Campus Police 7 Years after incidents reported & logs entered
Operations Records Clery Act Annual Security and Fire Safety Report Campus Police 7 Years after incidents reported & report filed
Employment Records Campus Police Background Invests, Hired Candidates Campus Police 7 years following term of employment
Employment Records Campus Police Psychological Pre-Screening, Hired Campus Police 7 years following term of employment
Operations Records Controlled Substance Seizure Reports Campus Police 7 years if no arrest/warrant
Operations Records Arrest Reports Campus Police 7 years unless past court completion
Operations Records Death Records Campus Police Permanent
Operations Records Murder Reports Campus Police Permanent
Operations Records Dispatch Logs Campus Police Permanent (after 1992)
Operations Records Special State Police Warrant Documentation Campus Police While sworn staff are employed
Operations Records Annual Report and Student Engagement (2014> Career Development Center guidance requested
Student Records Career Advising Records  Career Development Center guidance requested
Student Records Alumnae Engagement Career Development Center guidance requested
Student Records CDC Student Employee Records Career Development Center guidance requested
Student Records Recruiting Student Records Career Development Center guidance requested
Operations Records Department Financial Records Career Development Center permanent
Student Records Credentials File Career Development Center permanent
Student Records Student Employment Records Career Development Center permanent
Student Records Experiential Learning Records Career Development Center permanent
Student Records Student Off-campus Employment Records (<2013) Career Development Center permanent
Financial Records subsidiary ledgers Comptroller 10 years
Financial Records Mass form PC Comptroller 20 years
Financial Records Processed/Paid Purchase Orders Comptroller 5 years
Financial Records expense reports Comptroller 5 years
Financial Records AP Subsidiary rpts Comptroller 5 years
Financial Records AP check registers Comptroller 5 years
Financial Records Mass sales & meal taxes Comptroller 5 years
Financial Records Unclaimed property filings & records Comptroller 6 years
Financial Records Receipts for gifts & sales Comptroller 6 years
Financial Records Bank statements Comptroller 7 years
Financial Records Operating Acct & Stmts Comptroller 7 years
Financial Records General ledgers & operating ledgers Comptroller 7 years
Financial Records BNEW Operating accounts Comptroller 7 years
Financial Records Account Reconciliations Comptroller 7 years
Financial Records operating cash reports Comptroller 7 years
Financial Records Bank recons Comptroller 7 yrs from date files
Financial Records Original invoices Comptroller current + 4
Financial Records 1099's Comptroller current + 4
Financial Records JV's and backup Comptroller current + 5 years
Financial Records Uncollected accounts Comptroller Current + 6 years
Financial Records AR ledgers Comptroller perm
Financial Records property tax exemption records Comptroller perm
Financial Records audit reports & supporting workpapers Comptroller perm
Financial Records Management letters Comptroller perm
Financial Records audited financial statements Comptroller permanent-archived
Employment Records Faculty Employment Search Records Dean of Faculty For hired candidate: Permanent/ For interviewed/other candidates: three years
Employment Records Faculty Immigration (H1-B and PERM files) Dean of Faculty H1-B: one year past last date of employment. PERM: Five years from the date of filing the application
Administrative Records Faculty Legislation Dean of Faculty Permanent
Administrative Records Faculty Meeting Materials Dean of Faculty Permanent
Administrative Records Tenure and Promotion Records Dean of Faculty Permanent
Employment Records Faculty Personnel Records Dean of Faculty Permanent
Administrative Records Course Evaluations Dean of Faculty Permanent 
Administrative Records Academic Department & Program Annual Reports Dean of Faculty Permanent 
Student Records Student conduct records   Division of Student Life 7 years
Administrative Records Student Handbook Division of Student Life Permanent
Operations Records DOT Drug/Alcohol Testing EH&S 1 - 5 years
Operations Records DEP Hazardous Waste Manifests EH&S 5 years
Operations Records OSHA Training records EH&S duration of employment
Operations Records DOT training EH&S duration of employment plus 2 years
Operations Records DEP training  EH&S duration of employment plus 3 years
Operations Records DPH radiation licenses EH&S permanent
Operations Records DPH radiation dosimeter results EH&S permanent
Operations Records OSHA Respirator Fit test records EH&S until next fit test
Operations Records DPH radiation other compliance records EH&S until next regulatory inspection 
Operations Records OSHA Inspection Records EH&S until reviewed if required or until next regulatory inspections
Employment Records OSHA Medical -includes Safety Data Sheet EH&S/HR duration of employment plus 30 years
Operations Records Building, System & Land Plans Facilities Management Permanent
Operations Records Construction Project Records Facilities Management Permanent
Financial Records Accounts Payable (Alumnae Association) Finance 7 years
Financial Records General ledgers, year end trial balance (Alumnae Association) Finance Permanent
Financial Records Journal Entries (Alumnae Association) Finance Permanent
Financial Records Accounts Payable Records Financial Services 7 years
Financial Records Cash Receipts Financial Services Current + 4 years
Financial Records Deposit Tickets Financial Services Current + 4 years
Financial Records Journal Entry Detail Financial Services Current + 4 years
Financial Records Ledgers/Transaction Journals Financial Services Perm
Financial Records Damage Bills  Financial Services  
Financial Records PLP Transaction Journals Financial Services/Stdt Fin Svcs Permanent
Financial Records Student Loan Transaction Journals Financial Services/Stdt Fin Svcs Permanent
Financial Records Balancing Reports Financial Services/Stdt Fin Svcs Permanent
Financial Records Aging Reports Financial Services/Stdt Fin Svcs Permanent
Financial Records Delinquency Reports Financial Services/Stdt Fin Svcs Permanent
Financial Records FISL Financial Services/Stdt Fin Svcs Permanent
Research Records Faculty Research - Faculty Grant and Fellowship Files Funded Grants - Official: Financial Services. Unofficial: Dean of Faculty. Unfunded Grant Proposals: Principle Investigator Seven years from the end of the grant
Administrative Records OSHA 300 Log when required HR 5 years
Employment Records Employee Personnel Records HR 6 years from date of employee separation
Employment Records payroll records and timesheets (Alumnae Association) HR 7 years
Administrative Records Worker's Compensation HR 7 years
Employment Records Personnel Files (alumnae Association) HR Permanent
Administrative Records HR Programs (internal) HR Permanent
Administrative Records Benefits Summary Plan Description HR Permanent
Administrative Records Staff Handbooks HR Permanent
Operations Records Staff Training Records HR Title 9 permanent; others how long?
Administrative Records Benefits Vendors Records (agreements, etc) HR  
Employment Records Time sheet records HR  
Financial Records Form 5500 filings health & welfare benefits HR  
Financial Records ER Copy of EE W-2s HR  
Financial Records ER Copy of EE filed tax forms (w-4, etc.) HR  
Employment Records Student Staff Employment Files HR  
Administrative Records Regional Accreditation Forms and Documents IR 10 Years
Administrative Records IPEDS and U.S. Department of Education Compliance Surveys IR Permanent
Student Records IR Student Snapshots for Official Enrollment and Financial Aid Reporting IR Permanent
Administrative Records Indirect Assessment including COFHE Survey Data IR Permanent
Research Records Faculty Research - Institutional Research Board (IRB) Institutional Research Board Permanent 
Academic Records DESE Paperwork for Licensure Professional and Graduate Education 7 years
Financial Records Professional Development and other professional contracts for services provided Professional and Graduate Education 7 years
Financial Records Grant award and adminsitration materials Professional and Graduate Education 7 years
Financial Records Non-credit professional development course bills and payment Professional and Graduate Education 7 years
Legal Records Professional Development and other professional contracts for services provided Professional and Graduate Education 7 years
Legal Records Grant applications Professional and Graduate Education 7 years
Student Records Academic advising records for graduate students Professional and Graduate Education 7 years
Student Records Student conduct records for graduate students Professional and Graduate Education 7 years
Student Records Fellowship & scholarship applications for graduate students Professional and Graduate Education 7 years
Academic Records Non-credit professional development course registrations  Professional and Graduate Education 7 years
Administrative Records Free educational seminars and webinar participant lists Professional and Graduate Education 7 years
Student Records Fellowship & scholarship awards for graduate students Professional and Graduate Education Permanent
Academic Records Grade Sheets Registrar permanent
Academic Records Course Catalogs Registrar Permanent
Student Records Official Transcripts Registrar Permanent
Administrative Records Room Condition Form  Residential Life 1 year from when they are billed
Operations Records Health & Safety Inspection Residential Life 1 year
Operations Records Master Key Sign Out Sheet Residential Life 1 year
Employment Records Student Staff Applications- applicants not hired  Residential Life 3 years from date of application 
Administrative Records Information Reports Residential Life 7 years
Operations Records Common Room Reservation Requests Residential Life Current
Operations Records Room Change Requests Residential Life Current
Administrative Records Room Rosters (Floor, Alpha) Residential Life Permanent
Administrative Records CPS files for federal aid processing Student Financial Services Current +1 year
Administrative Records Files sent to CSS or CPS (institutional and federal processors) Student Financial Services Five years after award year has finished
Student Records Green bar student account records Student Financial Services Permanent 
Administrative Records PowerFAIDs database Student Financial Services Current +3years
Administrative Records College Board files for Institutional aid processing Student Financial Services Current +3years
Administrative Records Loan documents (paper) for alternative loans  Student Financial Services Current +3years
Administrative Records Files used to create FISAP (annual government report for Title IV aid) Student Financial Services Current +3years
Administrative Records Stored images for financial aid application Student Financial Services Current +3years
Administrative Records Paper financial aid applications Student Financial Services Current +3 years
Student Records Loan documents for institutional or federal loans Student Financial Services Current +3 years
Administrative Records Data files for vendors (MyinTuition, Student Financial Services  
Administrative Records Myriad files used to determine financial aid eligibility Student Financial Services  
Administrative Records Work study reports (payroll reports) Student Financial Services  
Administrative Records Data Warehouse financial aid records Student Financial Services Permanent
Student Records Student Account information in Colleague Student Financial Services Permanent
Student Records Student Government Association records, budgets, treasurers reports Student Programs  permanent
Student Records Student Advising Records Student Success & Advising 7 years
Student Records Academic Conduct Student Success & Advising 7 years
Student Records Student Accommodation Records Student Success & Advising 7 years
Student Records Fellowship applications Student Success & Advising 7 years
Student Records Fellowship Awards Student Success & Advising Permanent
Legal Records Fitness center waivers Athletics current +3 years
Legal Records Racquet sport waivers Athletics 1 year
Legal Records Accident reports Athletics 7 years
Administrative Records Release forms/lease agreements for Equestrian Center Athletics 3 years
Financial Records records re: horses, trailers, horse-related donations to Equestrian Center Athletics Current +7 years
Legal Records NCAA compliance/eligibility docs Athletics 7 years
Administrative Records Alcohol/drug policy violations Athletics Until student graduates
Employment Records Faculty / coach personnel files Athletics/ HR/ Dean of Faculty Permanent
Administrative Records Recruiting/admission impact information Athletics ???
Administrative Records Team and course evaluations Athletics/ HR/ Dean of Faculty/IR Permanent
Student Records Student roll cards  Athletics  
Administrative Records Club sports emergency contact info Athletics 3 years
Administrative Records Sport program histories Athletics Permanent
Student Records Medical clearance Athletics 7 years
Administrative Records Injury reports/rehabilitation forms Athletics 7 years
Administrative Records sport posters and brochures Athletics Permanent
Administrative Records recordings of games, etc. Athletics Current
Financial Records Private Source Grant Records Advancement/ Grants Office 7 years from closing date (final report)
Operations Records Funded Grant Proposals - Private Source Advancement/ Grants Office 7 years from closing date (final report)
Financial Records Federal Grants Financial Services 7 years 
Operations Records Federal Grant Proposals Funded Advancement/ Grants Office 7 years
Operations Records Unfunded Grant Proposal Records Advancement/ Grants Office 5 years
Financial Records Private Source Grant Records - Endowed Funds Advancement/ Grants Office Permanent
Administrative Records Payroll processing information, time sheets Dining Services (Jim Wehner) 7 years
Financial Records Register Tape - Cash, Credit and OneCard detail Dining Services (Jim Wehner) 5 years
Student Records Psychotherapy/psychiatry notes, communication documentation Counseling Service Current +7 years
Operations Records Hood inspections, grease trap inspections Dining Services (Mark Garner) 3 years
Financial Records Vendor contracts Dining Services (Mark Garner) 7 years
Operations Records Annual Food Permits, beer & wine permits Dining Services (Mark Garner) 5 years
Administrative Records Payroll processing information, time sheets  Willits-Hallowell Center 5 years
Financial Records General Ledger Reports Willits-Hallowell Center 7 years
Financial Records Billing, credit cards, daily sales sheets Willits-Hallowell Center 5 years
Operations Records Event Orders & contracts Willits-Hallowell Center 7 years
Operations Records Permits & Licences Willits-Hallowell Center 7 years
Administrative Records Health Services Title IX forms TItle IX Office  
Student Records Personal health records Health Services 10 years: Karen to find out
Student Records Alcohol and drug counseling records Health Services 7 years
Student Records prescription billing records from pharmacy  Health Services  
Administrative Records lab certification and test quality documentation Health Services  
Administrative Records Staff credentialing files Health Services Current +30 years
Administrative Records Employee health records Health Services  
Administrative Records Presidential Correspondence Office of the President Permanent
Administrative Records Board of Trustees (All Files - Not Correspondence) Office of the President Permanent
Administrative Records Strategic Planning documentation Office of the President Permanent
Administrative Records Accreditation Reports and Outcome Documents (NEASC/NECHE) Office of the President Permanent
Operations Records President's House keeps records of guests and events Office of the President Permanent
Financial Records Donor Letters for Endowed Funds Advancement Permanent
Administrative Records Consultant Reports (trying to centrally collect) Office of the President  
Administrative Records Officers Meetings and Other Projects Office of the President  
Operations Records President's Travel (Itineraries and Briefings) Office of the President