Records Retention and Destruction

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