Document Retention Policy

Purpose

This policy provides guidance for the systematic review, retention, and destruction of documents received or created by Albertus Magnus College in connection with the transaction of College business. This policy applies to all records and documents regardless of physical form and contains guidelines for how long certain documents should be kept and how records should be destroyed (unless under a legal hold). The policy is designed to promote compliance with applicable laws and regulations, eliminate accidental destruction of records, and facilitate operations and reduce costs by encouraging efficiency and freeing up valuable storage space.

Document Retention

Albertus Magnus College takes seriously its obligations to preserve information relating to litigation, audits, and investigations.

The information listed in the retention schedule below is intended as a guideline and does not contain all the records the College keeps or may be required to keep in the future. Questions regarding the retention of documents not listed in this chart should be directed to the President.

From time to time, the President may issue a notice, known as a “legal hold,” suspending the destruction of records due to pending, threatened, or otherwise reasonably foreseeable litigation, audits, government investigations, or similar proceedings. No records specified in any legal hold may be destroyed, even if the scheduled destruction date has passed, until the legal hold is withdrawn in writing by the President.

File Category

Item

Retention Period

Corporate Records

Annual Reports to Secretary of State/Attorney General

Permanent

 

Bylaws and Articles of Incorporation

Permanent

 

Board policies/resolutions

Permanent

 

Board and committee meeting agendas and

Minutes

Permanent

 

 

Construction Documents

Permanent

 

Fixed Asset Records

Permanent

 

IRS Application for Tax-Exempt Status (Form 1023)

Permanent

 

IRS Determination Letter

Permanent

 

State Sales Tax Exemption Letter

Permanent

 

Contracts (after expiration)

7 years

 

Conflict-of-interest disclosure forms

4 years

 

Correspondence (general)

3 years

Finance and

Administration

Annual Audits and Financial Statements

Permanent

 

 

Auditor management letters

Permanent

 

Depreciation schedules

Permanent

 

IRS Form 990 tax returns

Permanent

 

General ledgers

Permanent

 

Business expense ledgers

7 years

 

IRS Forms 1099

7 years

 

Journal entries

7 years

 

Invoices

7 years

 

Investment performance reports

7 years

 

Equipment files and maintenance records

7 years after disposition

Insurance Records

Policies — occurrence type

Permanent

 

Policies — claims-made type

Permanent

 

Accident reports

7 years

 

Safety (OSHA) reports

7 years

 

Claims (after settlement)

7 years

 

Group disability records

7 years after end of benefits

Real Estate

Deeds

Permanent

 

Leases (expired)

7 years after all obligations end

 

Mortgages, security agreements

7 years after all obligations end

Human Resources

Employee personnel files

Permanent

 

Retirement plan benefits (plan descriptions, plan documents)

 

Permanent

 

 

Employee handbooks

Permanent

 

Workers comp claims (after settlement)

7 years

 

Employee orientation and training materials

7 years after use ends

 

 

Employment applications

3 years

 

IRS Form I-9 (store separate from personnel file)

Greater of 1 year after end

of employment, or three years

 

Withholding tax statements

7 years

 

Timecards

3 years

 

Perkins Repayment Records

Kept until the loan is satisfied, or the documents are needed to enforce the obligation.

 

Perkins Original Promissory Notes

Three (3) years from the date the loan is assigned to the Department of Education (ED), cancelled, or repaid.

Student Academic Records

Student application files (non-attending)

3 years

 

Student application files (attending)

Permanent

Academic action authorizations (dismissals, etc.)

5 years after graduation or date of last attendance

Academic records (including narrative evaluations, competency assessments, etc.)

Permanent

Admission letters of recommendation

Until admitted

Advanced placement and other placement tests, records/scores (ACT,SAT, TOEFL)

5 years after graduation or date of last attendance

Applications for graduation

5 years after graduation or date of last attendance

Applications for admission or readmission (reentry)

5 years after graduation or date of last attendance

Change of course (add/drop)

1 year from end of relevant semester/term

Change of grade forms

5 years after graduation or date of last attendance

Class lists

5 years from end of relevant semester/term

Class schedules (students)

Permanent

Correspondence, relevant

5 years after graduation or date of last attendance

Credit by examination reports/scores (AP, CLEP, DANTES)

5 years after graduation or date of last attendance

Credit/no credit (pass/fail, audit, WP/WF, etc.)

5 years after graduation or date of last attendance

Degree audit records

5 years after graduation or date of last attendance

Foreign/international student forms (1-20, etc.)

5 years after graduation or date of last attendance

Graduation lists

Permanent

Grade submission data

Permanent

Hold or encumbrance authorizations

Maintained for 1 year after hold is released

Leave of absence

5 years after graduation or date of last attendance

Military documents

5 years after graduation or date of last attendance

Name change authorizations

5 years after graduation or date of last attendance

Personal data information forms

1 year after graduation or date of last attendance

Registration forms (paper copies)

1 year from end of semester/term

Substitutions/waivers (including Honors Program and Aquinas Scholars)

5 years after graduation or date of last attendance

Transcript requests (alumni, students)

1 year from date of service

Transcripts (high school, other colleges)

5 years after graduation or date of last attendance

Transfer credit evaluations

5 years after graduation or date of last attendance

VA certification records

5 years after graduation or date of last attendance

Withdrawal from the college

5 years after graduation or date of last attendance

 

Official academic transcript

Permanent

Financial Aid

Pell and Campus-Based Programs

3 years

 

Fiscal Operations Report (FISAP) and supporting records

Three (3) years from the end of the award year in which the report was submitted.

 

Direct Loans – records related to borrower’s eligibility and participation

Three (3) years from the end of the award year in which the student last attended.

 

Direct Loans – all other reports

Three (3) years from the end of the award year in which the report was submitted.

Technology

Software licenses and support agreements

7 years after all obligations

End

1. Electronic Documents and Records.

Electronic files will be retained as if they were paper documents. Therefore, any electronic files that fall into one of the document types on the above schedule will be maintained for the designated amount of time.

If a user has sufficient reason to keep an e-mail message, the message should be printed in hard copy and kept in the appropriate file or moved to an “archive” computer file folder. Backup and recovery methods will be tested on a regular basis.

2. Emergency Planning.

Albertus Magnus College’s records will be stored in a safe, secure, and accessible manner. Documents and financial files that are essential to keeping the Organization operating in an emergency will be duplicated or backed up at least every week and maintained off-site.

3. Document Destruction.

The President is responsible for the ongoing process of identifying College records which have met the required retention period and overseeing their destruction. Destruction of financial and personnel-related documents will be accomplished by shredding.

Document destruction will be suspended immediately upon any indication of an official investigation or when legal proceedings are filed or appear imminent. Destruction will be reinstated upon conclusion of the investigation or legal proceedings.

4. Compliance.

Failure to follow this policy may result in possible civil and criminal sanctions against the College and its employees and possible disciplinary action against responsible individuals. The President and Board Chair will periodically review these procedures with legal counsel and/or the College’s certified public accountant to ensure that they are in compliance with applicable laws and regulations.

For additional information regarding document retention policies, contact Mr. William Guerrero, Vice President for Finance and Treasurer. ( wguerrero@albertus.edu)