Bentley University Record Retention and Destruction Policy

Transcription

1 Bentley University Record and Destruction Policy PURPOSE: The purpose of this Policy is to ensure that necessary records and documents of Bentley University are adequately protected and maintained and to ensure that records that are no longer needed by Bentley University, or are of no value, are discarded at the proper time. This Policy is also for the purpose of aiding employees of Bentley University in understanding their obligations in retaining and destroying both paper and electronic documents - including , Web files, text files, sound and movie files, PDF documents, and all Microsoft Office or other formatted files or paper documents. POLICY: This Policy represents Bentley s procedures regarding the retention and disposal of paper or electronic records. ADMINISTRATION: Attached as Appendix A is a Record Schedule that is approved as the initial maintenance, retention and disposal schedule for physical and electronic records of Bentley University. The Chief Information Security Administrator (the Administrator ) is the individual in charge of the administration of this Policy and the implementation of processes and procedures to ensure that the Record Schedule is followed. In conjunction with General Counsel, the Administrator is also authorized to: make modifications to the Record Schedule from time to time to ensure that it is in compliance with local, state and federal laws and includes the appropriate document and record categories for Bentley University; monitor local, state and federal laws affecting record retention; annually review the record retention and disposal program; and monitor compliance with this Policy. DOCUMENT DESTRUCTION: In accordance with Massachusetts law and Bentley s Data Classification Policy, any documents containing personal or sensitive information should be destroyed so that the information cannot be practically read or reconstructed. For paper documents, this means that personal or sensitive data should be destroyed with a cross-cut shredder; for electronic documents, personal or sensitive data should be destroyed or erased with scrubbing technology, degaussing technology or through other means of physical destruction where the information cannot be practically read or reconstructed. For complete details of what is considered personal or sensitive data, please refer to Bentley s Data Classification Policy. SUSPENSION OF RECORD DISPOSAL IN EVENT OF LITIGATION OR CLAIMS: In the event Bentley University is served with any subpoena or request for documents or any employee becomes aware of a governmental investigation or audit concerning Bentley University or the commencement of any litigation against or concerning Bentley University, such employee shall inform General Counsel and any further disposal of documents shall be suspended until such time as General Counsel determines otherwise. General Counsel shall take such steps as is necessary to promptly inform Last Modified: 8/24/2010 1

2 appropriate staff of any suspension in the further disposal of documents. Upon notice from General Counsel, the account(s) of the individual(s) in question will be copied to a special directory designated for legal holds; automatic archiving for individual(s) in question will be turned off; and all backup tapes pertaining to will be removed from the general rotation cycle and stored in a designated location. Once the litigation is terminated or settled, General Counsel will notify the appropriate individuals so that tapes can be put back into general rotation, archiving can be turned back on and copies of accounts stored in the legal hold area can be deleted. APPLICIABILITY: This Policy applies to all physical and electronic records generated in the course of Bentley University s operation, including both original documents and reproductions. However, many items are no longer generated or stored in paper form, but can be generated into paper from electronic records as needed. ENFORCEMENT: As described in Bentley s Acceptable Usage Policy, anyone found to have violated this policy may be subject to disciplinary action, up to and including immediate. APPROVAL: Approved by Bentley s Information Privacy Committee on August 24, REVIEW CYCLE: This program will be reviewed and updated as needed, at least annually. Last Modified: 8/24/2010 2

3 Corporate Appendix A - Record Schedule Organization Trustee Form 1023, Articles of Incorporation, By-laws, Copyright and Trademarks, Insurance, Insurance Policies Manager Permanent Permanent Executive Asst. to the Press Release & Public Findings Permanent Permanent Executive Asst. to the Meeting Minutes & Other Permanent Permanent Executive Asst. to the Board Materials Publications Catalogs, Commencement Program, Schedule of Classes Permanent Permanent Executive Asst. to the Reports Degree, Enrollment, Grade, and Race Statistics Permanent Permanent Executive Asst. to the Legal Legal/IP Legal Files 10 years 10 years Executive Asst. to the Intellectual Properly & Trade Secrets Life of trade secret Life of trade Executive Asst. to the secret Form 990 or 990 EZ 7 years 7 years Executive Asst. to the Risk Management University Advancement Contracts Contracts, leases, license & other legal documentation life of agreement life of agreement Executive Asst. to the Insurance Insurance/Certificates of Insurance for Vendors Permanent Permanent Executive Asst. to the Insurance Property, liability, travel, etc. 10 years 10 years Executive Director, Financial Operations Donor Files Constituent, Life Permanent Permanent Managing Director, Income Agreements, Advancement Endowment Information, Information Planned Giving Information & Services Gift Receipts Gift Receipts N/A Managing Advancement Information & Services Other Events Event records or all internal and external events held at Bentley Director, Conference Services Last Modified: 8/24/2010 3

4 Finance Manager Accounts A/P Ledgers*, Invoices, Check 7 years 7 years A/P Specialist Payable Requests, Wire Transfers, Journal Entries General Accounting Student Accounts/ Cashier s Office Grant Accounting Payroll Permanent Bank Statements, reconciliations, cancelled checks (maintained by bank) Deposit Slips, supporting documentation and reconciliations, Loan Disbursement Rosters Grant contracts, budgets, reports, time and effort certification 6 years Accounting Manager 6 years Associate Director Student Financial Services close of grant 6 years Assistant Accounting Manager Indirect Cost Rate Calculation 6 years 6 years Assistant Accounting Manager Annual Payroll (W2),1099, 1042, Deduction Authorization (W4) Collective Bargaining Agreements, Income records (auto, moving expenses), Payroll Registers 6 years Dir. of Financial Time Cards, deductions, individual employee pay records (student or employee) External auditor records, Annual Financial Statements, Fixed Asset Recording (Deeds), A-133, NCAA Audit, MOSFA Audit 6 years 6 years Dir. of Financial Permanent Permanent Dir. of Financial *Bentley only keeps an electronic version of our General Ledger. Last Modified: 8/24/2010 4

5 Employee Record Class Existing Employees Record Types Employee Personnel File (Application, Performance Appraisals, Merit, Salary, etc. for staff and academic administrators; Contracts for Adjunct and Full-Time Faculty) Full-time Faculty Personnel File (Biographical, application, transcripts, etc.) Faculty Appointment Negotiation (promotion & tenure information) Visiting scholars and Post- Doc records (vitae, s, etc). Immigration I9 Paper 6 years 6 years 6 years 6 years Manager Director HRIS & Employment Services Dir, Acad & Accred Services 7 years 7 years Dir, Acad & Accred Services 6 years 6 years 6 years 6 years Dir, Acad & Accred Services/ Manager of HR Information Workforce Plan & Recruitment HR Legal Assistant Benefits (certificates of insurance, polices, contracts for benefits, etc.) Special Arrangements/Severance Agreements 6 years 6 years TBD Permanent Permanent Manager of HR Information Medical 30 years 30 years TBD PCDs Permanent Permanent TBD FMLA Dates of FMLA leave, notices, disputes, notes, etc. 4 years 4 years Employee & Labor Relations Last Modified: 8/24/2010 5

6 Employee Record Class Record Types Paper Manager Union NLRB certificates 6 years 6 years Director, from the from the Employee & Labor last last Relations effective effective date date Collective Bargaining Permanent Permanent Director, Agreement Employee & Labor Relations Other Unemployment Insurance 7 Years 7 Years TBD Employment General IPEDS Retirement (ERISA) Position File (including cv s, letters, copies of ads, search waivers and background checks, etc.) for individuals not hired All data used to complete IPEDS survey 6 years filing from date position filled 6 years filing from date position filled TBD Director, HRIS & Employment Services Permanent Permanent Manager of HR Information Vets 100 Affirmative Action Federal Contractor Veterans Employment Report Affirmative Action (Public or Private and supporting reports) Permanent Permanent Workforce Planning Permanent Permanent Workforce Plan & Recruitment IPEDS Affirmative Action All data used to complete IPEDS survey Affirmative Action (Public or Private) Permanent Permanent Manager of HR Information Permanent Permanent Dir. of Workforce Plan & Recruitment and President's Asst. Equal Oppor. Last Modified: 8/24/2010 6

7 Recruit & Applicant Recruits/ Acceptance Letters, AP records, Applicants Applications, correspondence that do not test scores, medical records, application enter recommendations, Military term documents, placement test information, transcripts & international student documents Recruits/ Applicants become students Recruitment materials Dispose enrollment application term Dispose enrollment Manager UGA,, Data & Communication Manager UGA Paper Freshman Coordinator Graduate- Director, Grad Admission UGA- Freshman Coordinator Graduate- Director, Grad Admission Last Modified: 8/24/2010 7

8 Student Manager Students/ UG Permanent File Permanent Permanent Applicants that (Acceptance Letter, enroll Application, Transcripts, DAS, 120, Name Changes) Students/ Applicants that enroll FERPA UG Temporary File (AP records, correspondence, test scores, Military documents, placement test information Graduate File (Acceptance Letter, Application, Transcripts, DAS, 120, Name Changes and other information) International Student Documentation Medical Student Health Insurance Requests for Formal Hearings, Requests/Disclosures for PII, Student Statements, Written Decisions, Student Requests for Nondisclosure, Students Written Consent, Waivers graduation/ date of last Permanent in Banner Permanent Permanent date of last 10 years graduation/ date of last 10 years graduation/ date of last N/A 10 years graduation/d ate of last 10 years graduation/ date of last Director, CISS Dir, Health & Wellness Dir, Health & Wellness and Executive Director, Financial Operations Permanent Permanent Last Modified: 8/24/2010 8

9 Registration/ Academic Action Academic Authorizations graduation or date of last Academic Advising Correspondence Correspondence, Credit by Exam Scores (AP, CLEP, etc.), curriculum change authorizations, degree audits, Grade Authorizations, Transfer Credit evaluations Applications for Graduation, Class Schedules, Personal data information forms Audit Authorizations, Add/Drop, Grade Reports, Pass/Fail Requests, Enrollment Verifications, Social Security Certifications Transcript Requests Academic, Change of Grade Forms, graduation lists graduation or date of last graduation or date of last graduation or date of last graduation or date of last 1 year date submitted/ performed Permanent in Banner N/A Permanent in Banner Permanent in Banner graduation/ date of last Permanent in Banner Manager Associate Dean for Academic Services Permanent Permanent Last Modified: 8/24/2010 9

10 Student Manager Financial Aid SFA Program Permanent Permanent Exec Dir, Enroll (participation agreement) Mgmnt & FA Fiscal Operations Report Permanent Permanent Exec Dir, Enroll (FISAP), all other Mgmnt & FA records/reports HEA Requirement SFA Recipient (SAR, ISIR, DoE, eligibility, Financial Aid history, etc. Requirements for Specific Aid (Campus Aid, Pell Grant) Borrowers eligibility records Disbursement Files (ASA, ELM) Perkins Original Promissory Note Crime Statistics, Security Report, SRK Athletic Participation Institutional Information (cost of, etc.) PIF International SEVIS F-1 and M-1 student leaves Permanent in Banner N/A Associate Financial Aid Associate Financial Aid Associate Financial Aid Senior Associate Financial Aid Director, Student Financial Services Permanent Permanent Director, Public Safety from from Assistant date of date of Director, disclosure or disclosure or Athletics required required disclosure disclosure Permanent Permanent Executive Director, Financial Operations N/A Director, CISS Last Modified: 8/24/