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Document Retention Policy

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Premier Collage | Document Retention Policy | Litigation Hold Notice | | | 8/26/2113 |

Table of Contents
1.0 POLICY STATEMENT ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐---‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 4
2.0 PURPOSE ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 4
3.0 APPLICABILITY ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐--‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 5
4.0 DEFINITIONS ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 5
1. Official Records Retention and Disposition Schedules ------------------------------------------------------------- 5
2. File Breaking ------------------------------------------------------------------------------------------------------------------- 5
3. Litigation Hold -----------------------------------------------------------------------------------------------------------------6
4. File Integrity ------------------------------------------------------------------------------------------------------------------- 6
5. File Maintenance ------------------------------------------------------------------------------------------------------------- 6
6. Personally Identifiable Information ------------------------------------------------------------------------------------- 6
7. Confidential Information -------------------------------------------------------------------------------------------------- 6
8. Legal Custodian of Electronic Records ---------------------------------------------------------------------------------- 7
9. Records ------------------------------------------------------------------------------------------------------------------------- 7
1. Essential Records ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 8
2. Official Records Defined by Frequency of Access ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 8
3. Official Records Defined By Subject Matter ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐10
10. Record Retention Schedule -------------------------------------------------------------------------------------------- 13
11. Record Retention Period ----------------------------------------------------------------------------------------------- 13
12. Record Storage ------------------------------------------------------------------------------------------------------------ 13
5.0 ELECTRONIC RECORDS GENERAL REQUIREMENTS ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐--------------‐‐‐‐‐‐‐14
1. Electronic Communications --------------------------------------------------------------------------------------------- 14
2. Information Technology Service Backup Files -----------------------------------------------------------------------15
6.0 RESPONSIBILITIES ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐---‐‐‐‐‐‐16
1. Record Retention Officer ------------------------------------------------------------------------------------------------- 16
2. Departments/Committees ----------------------------------------------------------------------------------------------- 16
3. Employees/Consultants/Independent Contractors --------------------------------------------------------------- 16
7.0 RECORD RETENTION AND STORAGE ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐--------‐‐17
1. Format of Storage by Category ----------------------------------------------------------------------------------------- 17
a. Financial Aid Records ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐-‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 17
2. Time Period for Storage by Category ---------------------------------------------------------------------- -----------18
a. Education/Student Records ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 18
b. Financial Aid Records ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 19
c. General Records ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 19
8.0 PLACE OF STORAGE ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐---‐20
1. Storage Vendor – Inactive Records ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 20
2. Active and Archival Records Containing Confidential or Personally Identifiable Information ‐‐‐‐‐‐‐‐ 20
3. Historic and Essential Archival Records ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐-20
9.0 METHOD OF DISPOSITION OF RECORDS BY CATEGORY ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐-----------‐‐‐‐‐‐21
1. Destruction of Confidential Records ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐ 21
2. Transfer to Archives ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐-‐‐21
10.0 LITIGATION HOLDS ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐-----‐22
1. Legal Hold Notice ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐22
2. Interviews with Legal Custodians ‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐‐22

1.0 Policy Statement
This Policy is designed to outline a process to manage the records created in the course of the College’s academic and administrative operations. This Policy covers all records and documents, including electronic documents, contains guidelines for how long certain documents should be kept and how records should be destroyed. The Policy is designed to promote compliance with federal and state laws and regulations, to minimize accidental or innocent destruction of records and to facilitate the College’s operations by promoting efficiency and freeing up valuable storage space.
2.0 Purpose
The purpose of this Policy is to provide guidelines to establish a records retention program at Premier College. This Policy will be made available on-line for the continued reference of the College community. The management of records includes appropriate practices for organizing and archiving those records determined to have permanent or enduring value, and proper destruction of those records deemed not to have permanent or enduring value once operational needs have been met and no legal considerations require attention. The retention periods set forth in the Record Retention Schedule generally do not apply to drafts and work papers. Drafts of Records, documents, work papers, notes, fragmented data, and deleted electronically stored information are temporary in nature and will not be retained beyond active use. Unless instructed otherwise in connection with a Legal Hold, drafts, work papers and notes may be discarded upon completion of the final document, unless they are an integral part or essential backup of an Official Record (in which case, the drafts and work papers shall be retained with the Official Record). Drafts and work papers should not be retained longer than the related Official Record. Official Records that are not listed in the Record Retention Schedule shall be retained in accordance with the retention period for substantially similar Records. Exact duplicates of Official Records can be destroyed at any time and should not be kept beyond the time period set within the Retention Schedule for the Official Record. Informational copies should not be retained longer than the Official Record.
3.0 Applicability
This Policy applies to all faculty and staff who manage Premier College’s Records. This Policy also applies to all student employees, independent contractors, and volunteers whose work or services for Premier College require the management of the College’s Records.
4.0 Definitions 1. Official Records Retention and Disposition Schedules
Official records retention and disposition schedules are the general and departmental program schedules that have been approved by the College and specified in this Policy. 2. File Breaking
File breaking is defined as the breaking or ending of files containing Official Records at regular intervals, at the end of a year or other duration, to permit their destruction, transfer to archives, or transfer to inactive storage areas. Regular breaking of files containing Official Records permits the establishment of new files and records series sequences within existing file space. For academic departments and academic committees, the end of the academic year is a file breaking point. For administrative departments, supporting units and administrative committees, the end of the fiscal year is a file breaking point. 3. Litigation Hold
A "litigation hold" is a suspension of the College’s document retention/destruction policies for those documents that may be relevant to a lawsuit that has been actually filed or one that is "reasonably anticipated.” See section 10 – Litigation Hold. 4. File Integrity
Complete, original file order, and unbroken custody of Official Records in a filing system should be maintained for Official Records to maintain file integrity. 5. File Maintenance
File maintenance is the application of records management practices to maintain Official Records properly, retrieve them, maintain integrity, and make their regular disposition more practical. 6. Personally Identifiable Information
Personally Identifiable Information is data or information that includes either the name of an individual or other family member, the individual’s address, a social security number or identification number, and other information that would make an individual’s identity easily traceable. 7. Confidential Information
Confidential Information is defined as information that is protected as confidential by law, such as the Family Educational Rights and Privacy Act of 1974 (education records), or the Health Insurance Portability and Accountability Act’s Privacy Regulations (medical records). Confidential Information also includes: a. Personnel information, b. Purchasing records related to a sealed response to a request for proposal prior to the award of contract, c. Proprietary information, and d. Information Premier College has contractually agreed not to disclose 8. Legal Custodian of Electronic Records
The term "legal custodian of electronic records" shall mean the originator of an e-mail message or the creator of an electronic document if that person is a College employee, consultant, or volunteer. Otherwise, it is the College 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 legal custodian. Records that are scanned are the responsibility of the individual department and shall be retained according to this Policy. 9. Records
Records are information fixed in any media including paper and electronic documents, audio and video recordings, databases, emails and text messages. 1. Unofficial Records
Unofficial Records are not subject to this Policy. Unofficial Records are: • Private or personal documents that are not created or received in the course of Premier College’s business; Faculty Records created or received in the course of faculty research or professional activities, such as interview or survey results, databases, or manuscript materials. 2. Official Records
Official Records include: correspondence, minutes, memos, drawings, maps, computer data, reports, newsletters, published materials, institutional policies and procedures, financial records, including invoices, journals, ledgers, purchase orders, grant documentation and other records pertaining to fiscal information. Official Records are classified by subject matter category (General, Legal, Financial, Student, etc.) and by the frequency of access to the Record that is required (Active, Inactive, And Archival). Official Records may also be further classified as Essential Records, as defined below. 1. Essential Records
Essential Records are a subset of Official Records. An Essential Record is a Record containing information essential to re-establish or continue the operations of the College in the event of a disaster. Essential Records are necessary to recreate Premier College’s legal and financial status and determine the rights and obligations of the Board, employees, donors, parents, students, and alumni. Examples include personnel records, leases and contracts, land deed and easement files, patents, engineering drawings of Premier College’s buildings, construction specification files, student records, accounting records and donor agreements. 2. Official Records Defined by Frequency of Access a. Active Records
Active Records are Official Records that continue to be used by the creating administrative unit for conducting regular business and are maintained in active office files. Official Records remain Active Records for varying periods of time, depending on the purpose for which they were created. b. Archival Records
Archival Records are Official Records that include organization charts, correspondence, minutes, architectural drawings, theses, temporary documents, memorabilia, personal papers, etc. Materials collected by the archives include but are not limited to: meeting minutes, reports, correspondence, financial records, program records, documentation of events, images, audio/visual recordings, personnel files, news clippings, course files, topical files (unique to creating office), publications, artifacts, publicity, personal papers, legal documents, architectural drawings, student records, histories, and student papers. Archival Records may be permanently retained even if there is no legal, regulatory, or management retention requirement (for example, historical records such as clippings, programs, and photographs). c. Historic Archival Records
Historic Archival Records are Official Records that are of permanent or historical value but are no longer required to be retained in the originating or receiving office. d. Essential Archival Records
Essential Archival Records are Official Records that have continuing administrative, research, or historical value, or which document Eckerd College’s organization, functions, policies, decisions, procedures, or operations. e. Inactive Records
Inactive Records are Official Records that are no longer required by their creating unit or other units to carry on current business and, therefore, are ready for final disposition in accordance with the Eckerd College Records Retention Schedule, as set forth in this policy. 3. Official Records Defined By Subject Matter
All Official Records are also classified by the following subject matter categories: a. General Records
General Records are Records created in the course of administering, or managing a department, unit, or office at Eckerd College. b. Education/Student Records
Education/Student Records are Records created when dealing with students, including but not limited to transcripts, disciplinary hearing files, student files or test score reports. c. Financial Aid Records
Financial Aid Records are Records created during the Administration of Title IV financial aid funding or any other financial aid programs, grants or scholarships. This includes all Records that must be maintained in accordance with the Federal Student Aid Handbook. d. Personnel Records
Personnel Records are Human Resources and related Records created for employees and volunteers, including but not limited to personnel files, payroll records, employee medical records, and workers’ compensation files. e. Publicity/Marketing Records
Publicity/Marketing Records pertain to dealings with the public, the media or while conducting outreach activities, including but not limited to handouts, publications, maps, catalogs, or brochures. f. Accounting/Financial Records
Accounting/Financial Records pertain to the development and administration of Eckerd College’s budget and financial transactions, including but not limited to invoices, checks, insurance policies, audit reports, budget reports and grant agreements. g. Regulatory/Compliance Records
Regulatory/Compliance Records pertain to compliance with applicable regulations, not otherwise covered in the categories set forth in this Policy. For example, this includes but is not limited to the Occupational Safety and Health Administration (“OSHA”), hazardous waste disposal records and the Fair & Accurate Credit Reporting Act (“FACTA”). This does not include Records pertaining to compliance with workers’ compensation, which would be covered by Personnel Records. h. Campus Safety Records
Campus Safety Records pertain to Campus Safety, institutional crime, Cleary Act reporting, safety on campus, Safety Committee Records and any other Records pertaining to law enforcement or safety at Eckerd College. i. Legal Records
Legal Records are created by an attorney Premier College or by Premier College for the purpose of seeking legal advice on behalf of Premier College. j. Library Records
Library Records are created during the administration of the Library including patron information, circulation records, and Inter-Library Loan records. This definition does not apply to the holdings of the Library, whose retention and destruction is governed by the Collection Maintenance Policy which is available at the Library. k. Institutional Research Records
Institutional Research Records pertain to Eckerd College’s student composition, ranking, statistics, including surveys, US News & World Report rankings, and Integrated Postsecondary Education Data System surveys and reports. l. Electronic Records
Electronic Records include, but are not limited to: * Electronic communications * Word processing documents and spreadsheets * Databases * Scanned documents 10. Record Retention Schedule
A Record Retention Schedule describes Records by subject matter category, provides a timetable for the maintenance, archiving, and destruction of the Records, provides an ultimate disposition for the Records, and serves as authorization for the disposition of Records. 11. Record Retention Period
A Record Retention Period is the length of time that a Record must be kept by law, or institutional Policy. The Record Retention Period for each Official Record is given in Premier College’s Records Retention Schedule. The Record Retention Period may be designated as “permanent,” “until superseded,” “until obsolete (business need ceases),” or for a certain number of years or months. 12. Record Storage
The College has limited space to store records. Therefore, records identified in the retention schedule should be stored at the warehouse (Iron Mountain). Each department has a designated staff member with access to Iron Mountain’s web page where requests for storing documents are made by asking for a specific number of cartons. When feasible, departments are encouraged to scan and save documents onto an encrypted electronic medium, and store them in a fireproof filing cabinet or container.
5.0 Electronic Records General Requirements
Maintenance and disposal of electronic records, as determined by the content, are the responsibility of the legal custodian. Electronic Records will be retained as if they were paper documents. Information Technology Services will facilitate the routine and secure destruction of Electronic Records with oversight by the Chief Financial Officer or designee. 1. Electronic Communications
College e-mail addresses are provided to employees for work purposes only. Work related e-mail is a College record, and must be treated as such. E-mail users must take responsibility for sorting out personal messages from work-related messages and retaining College records as provided in this Policy. E-mail that does not meet the definition of a College record, e.g., personal e-mail or junk e-mail, shall be deleted from the system. Information Technology Services maintains a back-up schedule. Legal Custodians may file documents in an encrypted electronic medium and store in a secure location, preferably a fireproof filing cabinet or container. Otherwise, printed copies may be retained according to the retention schedule and stored at the warehouse (Iron Mountain). E-mail messages should be kept with the attachment(s). The printed copy of the e-mail must contain the following header information: * who sent the message * to whom the message was sent * date and time the message was sent * subject of the message
2. Information Technology Service Backup Files
Information Technology Services performs backups on a regular schedule of the email and electronic files stored on central servers for disaster recovery. These backups are to be used for system restoration purposes only. These backups are kept by the department for a period of 90 days after which time the backups are erased.
3. Litigation Holds (Pertaining to Electronic Records)
When litigation against the College or its employees is filed or imminent, the law imposes a duty upon the College to preserve all documents and records that pertain to the issue in dispute. As soon as College Counsel or the Chief Financial Officer or designee is advised of pending litigation, a hold directive will be issued to the legal custodians. 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 College Counsel or the Chief Financial Officer. E-mail and computer accounts of separated employees that have been placed on a litigation hold will be maintained by Information Technology Services until the hold is released. No employee who has been notified by College Counsel of a litigation hold may alter or delete an electronic record that falls within the scope of that hold. Violation of the hold may subject the individual to disciplinary action, up to and including termination, as well as applicable personal liability for civil and/or criminal sanctions by the courts or law enforcement agencies.
6.0 Responsibilities
1. Record Retention Officer
All employees of Premier College are responsible for managing and maintaining the records they create in compliance with this policy and the record management program developed by the College. The Chief Financial Officer (CFO) or designee has ultimate responsibility for the record retention program. Questions concerning compliance with this policy shall be directed to the CFO or designee. Premier College has contracted with an outside vendor for record storage and destruction.
2. Departments/Committees
All departments and committees of Premier College are responsible for properly managing their Official Records and shall have a designated employee who is primarily responsible for compliance with this Policy.
3. Employees/Consultants/Independent Contractors
Employees, consultants, and independent contractors are responsible for being familiar with this Policy and for managing records in their possession, custody, or control in accordance with this Policy. These individuals may request guidance from the Record Retention Officer or designee.
7.0 Record Retention and Storage
1. Format of Storage by Category
Official Records shall be maintained in their original format, unless otherwise specified in this Policy, or directed by the Record Retention Officer or designee.
a. Financial Aid Records
In accordance with federal requirements, as set forth in the Federal Student Aid Handbook, Eckerd College shall keep its Federal Student Aid (“FSA”) records in one of the following formats: Original signed promissory notes and signed repayment schedules for Perkins Loans, National Direct Student Loans, and National Defense Student Loans must be kept in a locked fireproof container until the loan is repaid or until Premier College needs the originals to enforce collection of the loan. If a loan is assigned to the Department of Education (DOE), Premier College must send to the DOE the original promissory note or a certified copy of the note, as well as a copy of the original deferment or cancellation form(s). Premier College may not send computer-generated form(s) or microform(s). Premier College may keep other required records in hard copy or in microform, computer file, optical disk, CD-ROM, DVD or other media formats, but all record information must be retrievable in a coherent hard copy format or in other media formats acceptable to the DOE except that (1) a student’s Student Aid Reports (“SAR”) or Institutional Student Information Records (“ISIR”) used to determine eligibility for FSA program funds must be kept in the format in which Eckerd College received it, unless Premier College keeps the SAR in an imaged media format; and (2) any document that contains a signature, seal, certification, or any other image or mark required to validate the authenticity of its information must be kept in its original hard copy or in an imaged media format. Any imaged media format used to keep required records must be capable of reproducing an accurate, legible, and complete copy of the original document, and, when printed, this copy must be approximately the same size as the original.
2. Time Period for Storage by Category
Official Records containing mixed Record Retention Periods shall be retained for the longest Record Retention Period set forth in any applicable Record Retention Schedule. The Record Retention Periods are dependent on the particular department/area. Some are based on fiscal years (July 1 to June 30) and are exact retention periods, which mean that the department must keep an Official Record as long as stated in the Record Retention Period (minimum). Never destroy a Record related to an ongoing/current litigation matter, criminal or civil investigation, or audit.
a. Education/Student Records
Premier College shall keep all Education/Student Records in accordance with the principles set forth by the American Association of Collegiate Registrars and
Admissions Officers’ Retention of Records: Guide for Retention and Disposal of Student Education/Student Records. a. Financial Aid Records
Premier College shall keep Records relating to the school’s administration of a campus-based program for three years after the end of an award year for which the aid was awarded and disbursed under that program. Premier must retain the Fiscal Operations Report and Application to Participate (“FISAP”) containing reported expenditures and any Records necessary to support the data contained in the FISAP, including “income grid information,” for three years after the end of the award year in which the FISAP is submitted. Premier must keep repayment Records for Perkins Loans, including Records relating to cancellation and deferment requests for at least three years from the date a loan is repaid, cancelled, or assigned to the Department. If a loan is assigned to the Department due to total and permanent disability, the College must retain any loan-related documentation that it does not submit until the Department approves a final discharge or the loan has been paid in full. Records questioned in an accounting or legal audit must be kept until the questions are resolved or until the end of the Record Retention Period, whichever comes last. b. Legal Records
Legal Records shall be maintained for the length of time directed by the attorney involved in the communication.

8.0 Place of Storage
1. Storage Vendor – Inactive Records
The College contracts Iron Mountain to store and secure records according to the retention schedule identified in this policy. Departments may place requests to store cartons or retrieve stored cartons by accessing Iron Mountain’s web site. Storage areas for Inactive Records awaiting destruction or disposal must be physically secure and environmentally controlled, to protect the records from unauthorized access and damage or loss from temperature fluctuations, fire, water damage, pests, theft, and other hazards. Due to limited storage space on campus, these types of storage areas are currently provided by Iron Mountain.
2. Active and Archival Records Containing Confidential or Personally Identifiable Information
Active Records containing Confidential or Personally Identifiable Information should not be stored on the C: or local hard drive of a desktop or laptop computer, floppy or Zip disk, unencrypted thumb/jump drive, CD-ROM or DVD. Mini-storage facilities, and off-campus personal or rental property of staff members, including garages, homes, mobile homes, trailers, etc., are not acceptable for storage of Active Records containing Confidential or Personally Identifiable Information. These records should be stored on the College’s server or an encrypted electronic medium.
3. Historic and Essential Archival Records
Hard copies of Historic and Essential Archival Records should be stored in fireproof containers in a manner accessible on an as-needed basis. Electronic copies of Essential Historic Archival Records should be stored in an encrypted medium and file in a fireproof filing cabinet.
9.0 Method of Disposition of Records by Category
In the age of identity theft and data breach reporting requirements, it is important that records are disposed of in a manner that protects the College, its employees and students. Accordingly, a copy of an Official Record shall be destroyed in the same manner as the Official Record from which it originated. Official Records shall be destroyed or retained at the conclusion of the Record Retention Period set forth in this Policy.
1. Destruction of Confidential Records
All paper Records that have been designated confidential or that contain Confidential or Personally Identifiable Information and are subject to destruction shall be shredded. All Records that would pose a security risk or risk of identity theft shall be shredded. In the case of electronic Records, these Records shall be electronically purged in a manner that ensures they are not accessible on Premier College’s server and that provides for destruction of all Confidential or Personally Identifiable Information. See the ITS Director for further details about proper methods of electronically purging Records.
2. Transfer to Archives
If an Official Record is to be maintained permanently as an Essential or Historic Archival Record, it may be transferred to Archives for storage. The College is currently evaluating the space available and the cost of maintaining the Official Records. Departments may be directed to physically preserve hard copies or digitally archive Official Records. Historic Archival Records shall be authorized for destruction by the senior officer of each administrative or academic office of origin after considering historic value and consulting with the Record Retention Officer.
10.0 Litigation Holds
1. Legal Hold Notice
In the event that the College determines that litigation or an administrative agency claim is reasonably likely to occur that may result in a legal hold, the College will take appropriate steps to initiate a litigation hold on relevant records so that this information can be preserved. A memorandum providing the details of the case will be sent by the CFO to the appropriate Director, Dean, and/or Vice President.
Records that are subject to a litigation hold shall not be destroyed in accordance with Premier College’s standard destruction procedures. As such, upon initiation of a litigation hold, these Records must be immediately segregated from other records so they are protected from any routine Record purges. This is especially critical for emails or other electronic documents that may be subject to a computerized purge cycle. Please consult with the Director of Information Technology Services if you have any questions about this procedure.
2. Interviews with Legal Custodians
Interviews with legal custodians or other personnel may be conducted by Counsel representing the College to determine each individual’s knowledge of the situation, including confirming the receipt of the Legal Hold and the existence of potential relevant Documents. If documents are stored at the warehouse (Iron Mountain), staff responsible for the Department’s Record Retention shall retrieve these documents promptly. This person shall also identify the drives and folders that contain potentially relevant information, so that ITS can preserve the relevant information stored in these electronic folders. E-mail and computer accounts of employees that have been placed on a litigation hold by College Counsel will be maintained by ITS until the hold is released. No employee who has been notified by College Counsel of a litigation hold may alter or delete an electronic record that falls within the scope of that hold.

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