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Governance

Assignment of Authority and Responsibility for the Retention and Disposal of University Records (V.B.3)

Volume V: Governance
Chapter B: Governance
Issuing Office: Office of the President
Responsible Officer: VP for BS and AT
Responsible Office: VP for BS and AT
Originally Issued: September 6,2007
Most Recently Revised: November 18, 2011

TABLE OF CONTENTS

Statement of Policy
Reason for Policy
Who Should Know This Policy
Related Documents
Contacts
Definitions
Procedures
Special Situations
Responsibilities
History
Attachment A

STATEMENT OF POLICY

Federal and state laws, regulations of federal and state agencies, the requirements of accrediting and other external agencies, and prudent management practices govern the retention and disposal of University records. University records must be retained appropriately and disposed of in a timely manner to meet the requirements of external regulations.

University officials with record retention responsibilities shall actively disseminate information regarding obligations and procedures for the identification and preservation of Evidentiary Records.

REASON FOR POLICY

The policy assigns authority and responsibility for the retention and disposal of records to appropriate University officials for records maintained at all campuses and University locations.

WHO SHOULD KNOW THIS POLICY

President
Executive Vice President for Academic Affairs and Provost
Executive Vice President for Business and Finance, Treasurer
Chancellors
Vice Presidents
Deans
Directors/Department Heads/Chairs
Business Office Staff
Records Liaison Officer
Records Coordinators

RELATED DOCUMENTS

Records Retention Guidelines: www.purdue.edu/business/records/pdf/Records_Retention_Schedule.pdf

University Policy VIII.A.3: Disclosure of University Records in Connection with the “Access to Public Records" Law and in Response to Third-Party Subpoenas

CONTACTS

Director of Business Managers: (765) 494-9452

DEFINITIONS

Word Definition
Evidentiary Records University records which involve or are related to any known or anticipated claim, liability, dispute, investigation, grievance, complaint, audit, and/or litigation.
Records Coordinator Individuals responsible for implementing record retention and disposal policies and procedures for their organizational unit.
Records Liaison Officer Individuals responsible for implementing record retention and disposal policies and procedures for their regional campus.
University Records Includes any writing, paper, report, study, map, photograph, book, card, tape recording, or other material that is created, received, retained, maintained, or filed by or with the University, which is generated on paper, paper substitutes, photographic media, chemically based media, magnetic or machine readable media, electronically stored data, or any other material, regardless of form or characteristics.

PROCEDURES

Selected University officials have been assigned authority and responsibility for the retention and disposal of records by major record category. Attachment A outlines the officials responsible for ensuring appropriate retention and disposal processes and the category of records within their responsibility.

For those records not specifically listed in Attachment A, the provost is responsible for the retention and disposal of academic records while the senior vice president for business services and assistant treasurer is responsible for the retention and disposal of non-academic records.

Regional campus chancellors shall designate a Records Liaison Officer who shall be responsible for coordinating the implementation of the records retention and disposal policies and procedures for their campus with the vice president, dean, or director (University official) assigned responsibility for the record categories detailed in Attachment A.

Each University official assigned responsibility on Attachment A shall:

  1. Establish appropriate record retention and disposal policies and procedures in accordance with relevant federal and state laws, regulations of federal and state agencies, the requirements of accrediting and other external agencies, and prudent management practices. These procedures should include the following information:
    • Identification of the specific records for which he/she is accountable.
    • Instructions for where these records are to be stored.
    • Instructions for the required length of time to retain these records.
    • Identification of the agency specifying record retention requirements.
    • Identification of the storage medium (paper, microfilm, etc.).
    • Instructions for disposal of the record after the retention period is over.
    • Instructions for whom to contact with questions regarding the retention and disposal of these records.
    • Procedures for pre-disposal determination whether records are Evidentiary Records.
  2. Monitor compliance with those policies and procedures.
  3. Designate a Records Coordinator with authority to interact directly with other authorized persons to further the purposes of this policy.

Each Records Coordinator shall:

  1. Identify specific record retention and disposal requirements for records maintained at all University locations.
  2. Serve as a resource to answer questions regarding the retention and disposal of University records.
  3. No later than December 31 of each year, publish and disseminate record retention and disposal procedures and schedules.
  4. Maintain and regularly update a log of Evidentiary Records and, as appropriate, arrange for and monitor segregation of Evidentiary Records.
  5. Regularly monitor compliance with record retention and disposal procedures at all University locations.
  6. Provide training and guidance for all staff responsible for the execution of record retention and disposal procedures at all University locations.

Record retention, disposal plans, and relevant policies shall be on file and available for external and internal audit. In general, it is the University’s policy to retain records in compliance with externally imposed requirements concerning the retention and disposal of records.

After the retention period for a specific record has expired, disposal of the records should occur as soon as is practical.

The senior vice president for business services and assistant treasurer or his/her designee shall be responsible for the overall administration of the University’s record retention and disposal policies and requirements.

SPECIAL SITUATIONS

Electronic Media

To assure that the integrity of records is maintained and that the electronic records meet the rules of evidence, the electronic media recording system and related procedures must be reviewed and approved by the senior vice president for business services and assistant treasurer after consultation with the vice president for information technology and university legal counsel.

If requirements allow for the retention of records via electronic, magnetic, or photo imaging means (a.k.a. electronic media), the duplicate paper copies should be destroyed.

The Records Coordinators must periodically review records stored via electronic media for possible deterioration. The senior vice president for business services and assistant treasurer must approve changes to the record retention process after consultation with the vice president for information technology whenever technology changes require modification to the existing electronic process.

Conflicting Retention Requirements

In the event that conflicting retention requirements are uncovered for a specific record, the longest retention requirement shall prevail.

Preservation of Evidentiary Records Involving Known or Anticipated Claims, Complaints, Grievances, Audits, and Litigation

All University records pertaining to any known or anticipated claim, liability, dispute, investigation, grievance, complaint, audit, and/or litigation shall be retained even if the retention period or disposition date specified for the records has expired. University officials with record retention responsibilities shall, in consultation with the office of the director of business managers or their designee and University counsel, suspend the application of any otherwise applicable disposal policy to identified Evidentiary Records, and shall undertake to preserve the Evidentiary Records for as long as necessary to comply with the University’s legal and evidentiary obligations.

RESPONSIBILITIES

The director of business managers has been designated as the responsible party for the facilitation and review of the University’s record retention and disposal policies and requirements with the Records Retention Coordinators.

HISTORY

November 18, 2011: Policy number changed to V.B.3 (formerly VI.4.2).

July 12, 2011: Titles of university official and departments updated throughout.

September 6, 2007: This policy supersedes Executive Memorandum No. C-41, issued November 14, 1996. Executive Memorandum No. C-41 superseded Business Office Memorandum No. 15, issued May 14, 1953.

ATTACHMENT A

Assignment of Responsibility and Authority for Retention and Disposal of University Records

University Official Record Category
Senior Vice President for Business Services and Assistant Treasurer Board of Trustees Records
Contract/Grant Records
Financial Records
Vice President for Human Resources Employee Records
Vice President for Advancement Donor and Alumni Records
Vice President for Physical Facilities Construction Records
Criminal Case Records
Environmental Records (water, air, etc.)
FAA Records
Hazardous Materials and Occupational
Safety Records
Vice President for Student Affairs Academic Records
Admission Records
Financial Aid Records
Registration Records
Student Conduct/Discipline Records
Student Medical Records
Dean of the Graduate School Graduate School Records
Vice President for Research Research Records
Director of Intercollegiate Athletics Conference Records
NCAA Records
Dean of Agriculture Agency Records
Agriculture Appropriated Funds Records
Director of Purdue Pharmacy Pharmacy Records
Dean of Education Education/Licensure Records
Records of Various Clinics and Engagement Programs
Dean of Health and Human Sciences Records of Various Clinics
Dean of Veterinary Medicine Animal Hospital Records