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in any legal hold may be destroyed, even if the scheduled destruction date has passed, until the legal hold is withdrawn in writing by the President.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
	eLearning course materials	5 years from end of relevant semester/term
	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 Ms. Lauri Strimkovsky, Vice President for Finance and Administration. ( lstrimkovsky@albertus.edu)