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5.12-1 RECORDS RETENTION POLICY

Purpose 

The Saginaw Valley State University (SVSU) Records Retention Policy is established to provide the university community with guidance on the retention and disposal of University records.  The policy creates a Records Retention Schedule (RRS) that sets retention periods based on the content and purpose of university records and sets the minimum length of time that campus officials must retain the records covered by this policy before the records may be disposed of legally. This policy replaces and supersedes any existing retention authorizations and guidance that campus and University officials may have adopted for specific records.   

The purpose of this Records Retention Policy is to:

  1. ensure that records are retained as long as needed for administrative, legal, and fiscal purposes;
  2. ensure that state and federal records retention requirements are met;
  3. ensure that records with enduring historical, archival, and other research value are identified and retained permanently; and
  4. encourage and facilitate the systematic disposal of unheeded records. 

How to use the Records Retention Schedule (RRS) 

This policy is reflected through a Records Retention Schedule (RRS).   Many of the items covered by this policy and the RRS are broad and describe the purpose or function of records rather than identifying individual documents and forms. 

Specific items in the RRS are arranged Records Retention Schedule (RSS) Alpha Listing (226kB), by Records Retention Schedule (RSS) Departmental Listing (222kB), and by Records Retention Schedule (RSS) Functional Heading (222kB) (e.g., Payroll, Purchasing, Housing, eta.).  Campus and University officials should check with the University Records Management Officer when they are uncertain regarding coverage of a function. 

In situations where a department has related types of records covered by different items on the RRS into a single file, it may be impractical to separately apply the retention periods of the various applicable RRS items to the individual records in the file. In such situations, officials may find it more convenient to dispose of the entire set of records by using the applicable retention item with the longest retention period. 

Retention periods on the RRS apply to one "official" copy designated by a University department, regardless of physical form or characteristic (paper, electronically imaged file, or other medium), unless otherwise stated. No matter what the medium, University officials must ensure that the information will be retained for the specified retention period.  The time identified as the minimum retention period begins with the creation of the record as defied in the RRS, unless otherwise specified. 

Special Situations 

1.        Legal Actions

Some records may be needed for use in legal actions involving the University. Records that are identified in or relevant to such actions must be retained for the entire period of the action, including any appeals, or the period for making an appeal, plus an additional year, even if their retention period has expired. Prior to disposing of records related to or retained for a legal action, University officials should consult with the University Records Management Officer, who will work with Administration and Business Affairs Division to verify that no new legal actions or appeals have been initiated that would require longer retention of the records.

 2.        Electronic Records

Generally, records transmitted through e-mail systems have the same retention periods as records in other formats that are related to the same function or activity. E-mail records should be scheduled for disposition in conjunction with any other records related to that function or activity. Campus and University officials may delete, purge, or destroy e-mail records if the records have been retained for the minimum retention period established in the RRS and are not being retained for a legal action or otherwise subject to a litigation hold, audit, or accreditation needs. Transitory messages, e.g., those relating to office events, meeting reminders, personal matters, may be destroyed when no longer needed.  

3.        Drafts and Personal Working Papers

When drafts are created in the preparation of University records, the final version is considered the official copy for retention purposes.  Temporary drafts that were not reviewed, circulated or used to make decisions may be discarded when no longer needed.  This should be done at the earliest opportunity following approval of the final version.  This policy applies to drafts in all forms, including word processing files, spreadsheet files, and other computer files. 

Personal working papers, including notes, may be developed during the transaction of University business or during the preparation of University records. Most personal working papers, such as notes taken at a meeting or annotations on a draft record that is ultimately superseded by a final version, have no legal, operational, or research value that warrants retaining them beyond their moment of immediate usefulness. These records should be discarded at the earliest opportunity, generally within one (1) year after the purpose for which they were created has been fulfilled. This policy applies to personal working papers in all formats, including word processing files, spreadsheet files, and other computer files.

 4.        Audits 

Program and fiscal audits and other informational requirements of state and federal agencies are taken into account when retention periods are established in the RRS. However, in some instances agencies with audit responsibility and authority may formally request that certain records be kept beyond the retention periods. If such a request is made, these records must be retained beyond the retention periods until the campus or the University receives the audit report or until the need is satisfied. 

5.        Archival Records 

Archival records are records that the University must keep permanently to meet its fiscal, legal, or administrative needs or that the University retains because these records contain historically significant information. Records do not have to be old to be archival; campus and University officials frequently create and use archival records in their offices. What makes a record worthy of permanent retention and special management is the continuing importance of the information it contains. 

Knowledge of people, places, or events in our campus community and the unique circumstances of each potentially archival record will determine which are significant. Campus and University officials will need to appraise records with non-permanent retention periods for potential historical value before destroying them.  

 6.        Appraising Records for Historical Significance 

A University record has historical or other importance if it provides significant evidence of how the campus or University functions and/or if it provides significant information about people, places, or events that involve the University.  University records may contain a tremendous amount of information about the people, buildings, and sites in the University community, as well as important time periods or significant events that affected the people associated with the University. This information can be very valuable to staff, researchers, and the public, but only if the information itself is significant. The significance of the records will depend on: 

  • When the records were created. Records created during a time of momentous change, which are scarce, or which cover a long period of time tend to be more significant.
  • What kind of information the records contain? Records that contain more in-depth information are more likely to have enduring value.
  • Who created the records? Records that reflect an employee's perspective or individual point of view may be more significant.
  • What other records exist. If the information in the records exists in other records within the University or elsewhere, then the records are less likely to be significant.
  • The unique history of the University. Records created during important time periods or events can provide clues to how the events affected the development of the University and the community it serves.

7.        Records Not Listed on the RRS and Non-Existent Records 

The RRS covers the majority of all records of the University. For any record not listed, the custodian of the records should contact the University Records Management Officer for assistance. If the record is not covered by an item on the RRS, it must be retained until a revised edition of or addendum to the RRS is issued containing an item covering the record in question and providing a minimum legal retention period for it. 

8.        Public Access to Records/Confidentiality

The RRS does not address the issue of public access to records. Access issues are covered by the Michigan Freedom of Information Act (FOIA) (MCL 15.231 et seq.), as well as by the federal Family Educational Rights and Privacy Act (FERPA). Campus and University officials should consult with the University's FOIA Coordinator (FOIA) or the Registrar's Office (FERPA) on questions related to public access to records.

Records on the RRS may or may not be confidential, depending on what information they contain and on the possible effect of disclosure of that information. In approaching issues of confidentiality and access, it may be helpful to consider the following: 

  • What was the purpose for which the records were created?
  • What information do they contain? What subjects are covered?
  • How are the records used?
  • How do they relate to other records that may have similar information?
  • What would be the likely effect of disclosure of the information in the records?

Campus and University officials should consult the University Records Management Officer with questions related to public access to records that may contain confidential information.

 9.        Migration of Records to Different Media 

Many of the records within the RRS have been migrated from original paper records into electronic formats.  As a result, once paper records are scanned and reformatted as electronic records, the original paper records maybe destroyed even if the assigned retention period has not expired.  The new electronic records must be retained for the remainder of the applicable retention period.  New migration of paper records into electronic formats should only occur under the following conditions. 

(1) the images will accurately and completely reproduce all the information in the records being imaged;

(2) the imaged records will not be rendered unusable due to changing or proprietary technology before their retention and preservation requirements are met;

(3) designees of SVSU will be able to authenticate the imaged records by competent testimony or affidavit which shall include the manner or method by which tampering or degradation of the reproduction is prevented. 

Accordingly, offices planning to replace original records with electronic or imaged copies for retention purposes must ensure that all conditions listed above are met and that a campus official will be able to attest to the manner in which replacement of records occurred to fulfill these conditions. 

Guidelines for Records Disposition 

Records without historical value must be disposed of continually as they meet their stated minimum retention periods. The advantages of a program for systematic, legal disposal of obsolete records: 

  • Demonstrates routine, good faith operation of the records retention system;
  • Ensures that records are retained as long as they are actually needed for administrative, fiscal, legal, or research purposes;
  • Ensures that records are promptly disposed of after they are no longer needed;
  • Frees storage space and equipment for important records and for new records as they are created;
  • Eliminates time and effort required to service and sort through superfluous records to find needed information;
  • Eliminates the potential fire hazard from storage of large quantities of valueless records; and
  • Facilitates the identification and preservation of archival records.

Guidelines for systematically approaching the disposition process include the following: 

  • Disposition should be carried out regularly, at least once a year. It should not be deferred until records become a pressing storage problem.  
  • Records must be destroyed appropriately.  For records containing confidential information (e.g., Social Security numbers, credit card numbers, personnel evaluations, salary levels), disposition should be carried out in a way that ensures that the confidentiality of individuals named in the records is protected.
  • The utilization of the University Records Destruction/Transfer Form (55kB), as a record of the identity, inclusive dates, and approximate quantity of records that are disposed of must be maintained by the office/department.

Records Management Officer at Saginaw Valley State University

The University has designated a University Records Management Officer to coordinate the proper retention and disposition of records. Inquiries about records management should be referred to the University Records Management Officer, and whenever necessary, Administration and Business Affairs Division for resolution.

 

Adopted 07/11/2016 EVP-ABA