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20.23 / Retention of University Records

Purpose:
The purpose of this statement is to set forth University policy on the retention and disposal of University records.

Preamble:
It is necessary and appropriate that Wichita State University requires that different types of records be retained for specific periods of time and that it designate official repositories for maintenance and retention of records.  University records must be managed in accordance with this policy.

Policy Statement:
The University is committed to effective record retention to meet legal standards, optimize the use of space, ensure security of confidential information, minimize the cost of record retention, preserve institutional history and ensure that outdated and useless records are destroyed.

Definitions:

A.  Active Record: A University record with current administrative use for the department that generated it.  Records remain active for varying numbers of years, depending on the purpose for which they were created.
B.  Archival Record: A University record that is inactive, not required to be retained in the office in which it originated or was received, and has permanent or historic value.  Archival records are retained and preserved indefinitely in the appropriate archival repository (i.e. Special Collections, salt mines, etc.).
C. Custodian/Electronic Record: The originator of an e-mail message or the creator of an electronic document if that person is a University employee; otherwise it is the University employee to whom the message is addressed or to whom the electronic document is sent.  If the record is transferred, by agreement or policy, to another person for archival purposes, then that person becomes the Custodian/Electronic Record.
D.
 Electronic Record: Any record that is created, received, maintained or stored on University local workstations or central servers.  Examples include, but are not limited to:
  1. Electronic mail (e-mail)
  2. Word processing documents and spreadsheets
  3. Databases - both static and those that are transactional in nature (i.e. tables in Banner with multiple user access and modification capabilities)
E.  Inactive Record: A University record that is inactive, not required to be retained in the office in which it originated or was received.
F.
Official Repository: The department designated as having responsibility for retention and/or timely destruction of particular types of official University records.  Such responsibility is assigned to the department head or a designee.
G.
 University Archives: A component of the Special Collections Department of University Libraries that promotes knowledge and understanding of the University's origins, aims, programs, and goals.  This work includes permanent retention of records and reports of the University, its officers and component parts; maps and architectural records; audiovisual materials, including still photographs and negatives, motion picture film, oral history interviews, audio and videotapes; and artifacts and ephemera documenting the University's history.
H.
 University Record: The original copy of any record in printed or electronic format.  Official Repositories and retention schedules for these records are identified in the University's Records Retention Schedule located here.

Procedures:

A.  Responsibilities for Managing Official University Records

Departments that maintain any University Records are the Official Repository of such records and each department head or designee must:

1. Implement the department's record management practices consistent with this policy.

2. Educate staff within the department in understanding sound record management practices, including a system for efficient retrieval of Active Records.

3. Transfer Inactive Records that may have historic value to the University Archives.

4. Ensure that access to confidential files is restricted.  Long-term restrictions on access to selected Archival Records should be negotiated at the time of their transfer to the University Archives.

5. Destroy Inactive Records that have no historic value upon passage of the applicable retention period.  If in doubt as to the potential historic value, consult with the Curator of Special Collections and University Archivist (hereinafter University Archivist) before destroying the Inactive Records.
B.  Preserving or Disposing of Official University Records

 
 When the prescribed retention period (see University Records Retention Schedule) for official University records has passed, a determination of whether to preserve or dispose of the documents must be made.  To decide if a University Record is of historic value to the University, consult the University Archivist who has the authority to designate which University Records are archival.
  1. Archival Records:


If it has been determined that the University Records are Archival Records, they may be transferred to Special Collections.  Call the University Archivist to initiate the following:


  1. Review records to be sent to University Archives;
  2. Request a transfer form;
  3. Depending on the amount of material to be transferred and staff availability, the Special Collections staff may make a site visit and pick up the records.  If staff is unavailable to pick up the material, the department of origin may take the material to Special Collections at a prearranged time; and
  4. Small quantities may be sent through campus mail.
 
University Records that are transferred to Special Collections are not in storage.  The transfer is permanent and the University Records become part of the University Archives (see definition G above).


2. Inactive Records:


If it has been determined that University Records are Inactive Records, and therefore, not of permanent historic value, they, consistent with K.S.A. 45-403, should be destroyed in one of the following ways: 



  1. Recycle non-confidential paper records; or
  2. Shred or otherwise render unreadable confidential records; or
  3. Erase or destroy Electronic Records (periodically review records generated and maintained in University information systems or equipment to ensure that these requirements are met).
C.  Location and Duration for Record Retention
  1. The University Records Retention Schedule lists the Official Repositories for University Records, as well as how long these records must be maintained.

2. Record retention periods may be increased by government regulation, judicial or administrative consent order, private or governmental contract, pending litigation or audit requirements.  Such modifications supersede the requirements listed in this policy.  Any suspension of record destruction required will be accomplished by a notice sent out to the affected units or individuals by the Office of the Vice President and General Counsel.

3. Questions regarding the retention period for any specific document or class of documents not included in the schedule should be addressed to the Office of the Vice President and General Counsel.

4. Departments that are not Official Repositories, and that retain duplicate or multiple copies of University Records, should dispose of the records when they are deemed to be no longer useful.
D.  Electronic Records

  1. Maintenance and disposal of Electronic Records, as determined by the content, is the responsibility of the Custodian/Electronic Record and must be in compliance with the University Records Retention Schedule.  Work related e-mail is a University Record and must be treated as such.

2.
 E-mail messages and any associated attachment(s) with retention periods greater than three (3) years are to be maintained according to the University Records Retention Schedule in a format capable of reproduction.  It is important to note that the e-mail message should be kept with the attachment(s).  If e-mails are printed and filed in similar fashion to paper records for retention purposes, the printed copy of the e-mail must contain the following header information:
  1. Who sent message
  2. Who message was sent to
  3. Date and time message was sent
  4. Subject

3.
 When e-mail is used as a transport mechanism for other record types, it is possible, based on the content, for the retention and disposition periods of the e-mail and the transported record(s) to differ.  In this case the longest retention period shall apply.

4.
 University Computing and Telecommunications Services (UCATS) performs backups on a regular schedule of the e-mail and electronic files stored on central servers for disaster recovery.  These backups are to be used for system restoration purposes only.  The information technology system administrator is not the Custodian/Electronic Record of messages or records which may be included in such backups.

5.
 When litigation against the University or its employees is filed or threatened, the law imposes a duty upon the University to preserve all documents and records that pertain to the issues.  As soon as University Counsel is made aware of pending or threatened litigation, a litigation hold directive will be issued to the appropriate individuals.  The litigation hold directive overrides any records retention schedule that may have otherwise called for the transfer, disposal or destruction of the relevant documents, until the hold has been cleared by the Vice President and General Counsel.  E-mail and computer accounts of separated employees that have been placed on a litigation hold by the Vice President and General Counsel will be maintained by UCATS until the hold is released.  No employee who has been notified by the Vice President and General Counsel of a litigation hold may alter or delete an electronic record that falls within the scope of that hold.  Violation of the litigation hold request may subject the employee to disciplinary action, up to and including dismissal, as well as personal liability for civil and/or criminal sanctions by the courts or law enforcement agencies.

Implementation:
This policy shall be included in the WSU Policies and Procedures Manual and shared with appropriate constituencies of the University.

The Vice President and General Counsel shall have primary responsibility for publication, dissemination and implementation of this University policy.

Effective Date:
April 15, 2010

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