Record Retention Policy
Record Retention Policy
Purpose
The University is committed to effective record management to meet legal and regulatory standards, preserve its history, optimize the use of space, and minimize the cost of record retention.
Each administrative office at the University generates unique records in the course of conducting daily business. The intent of this policy and its associated procedures is to ensure that all University administrative offices, with guidance from the University Archives, take responsibility for the proper management of University Records to ensure compliance with legal and financial requirements, satisfy administrative needs, and identify and preserve historical and permanently valuable records.
Scope
This policy applies to faculty, staff, and students at the University of Dayton.
Policy History
I. Effective Date: September 9, 2014
II. Approval: January 30, 2024
III. Policy History:
- The University-wide Record Retention Policy was first issued in September 2014; however, prior to issuance of this formal university-wide policy, records were maintained in accordance with University archival policies, individual units’ own retention schedules, and legal requirements.
- Approved in its original form: September 9, 2014
- Approved as amended: January 30, 2024
IV. Maintenance of Policy: Vice President and General Counsel, Office of Legal Affairs
Definitions
(a) "Active Record” a record with current use for the unit, department, division or office that generated it. Records remain active for varying numbers of years, depending on the purpose for which they were created.
(b) “Archival Record” a record that is no longer required by the unit, department, division or office in which it originated or was received, and that has permanent legal, institutional, or historical value.
(c) “Inactive Record” a record with no current use for the unit, department, division or office that generated it and that has not yet reached the end of its retention period.
(d) “Office of Origin” is the University unit, department, division or office in which a particular document or record originates.
(e) “University Records” are recorded information created or received in the course of conducting University business and kept as evidence of such activity. An official record may be in hard copy (e.g., paper, magnetic tape,film, etc.) or electronic form. An electronic document (e.g., e-mail, cloud-based documents, etc.) is considered a university record and is subject to the same retention period as the hardcopy 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.
Policy
The University of Dayton requires that university records, regardless of format, be retained for specific periods of time in accordance with legal or other institutional requirements, or for historical value and then be disposed of. The Office of Legal Affairs in consultation with University Archives is responsible for establishing Record Retention Schedules and records management procedures so that University Records are handled in an appropriate manner throughout their life cycle.
The Office of Origin manages the retention and disposal of these records according to procedures outlined in this document. Collaboration among the Office of Origin, the Office of Legal Affairs, and the University Archives should ensure that Active Records are available for business use, that Inactive Records are maintained in accordance with established procedures and schedules, and that Archival Records are retained for research purposes in the University Archives.
Records of enduring historical value shall be accessioned into the permanent collections of the University Archives and identified in such a way as to make them accessible for appropriate research use.
Responsibilities for Managing University Records
Each unit’s administrator or a designee must do the following:
- Implement the unit’s and/or 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 for transfer to the University Archives.
- 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.
- Destroy inactive records that have no archival value upon expiration of the applicable retention period.
- Direct questions about these responsibilities to the University Archivist, who will work closely with units to ensure understanding of this policy and implementation of these responsibilities.
- If you have a question about a particular record classification or a document that is not listed in the retention schedule, please retain the document and contact the University Archivist for clarification.
Note: An official record can be in the form of original paper, or may be a digital surrogate, at the discretion of the official repository.
Preserving or Disposing of University Records
When the prescribed retention period for university records has passed, a determination of whether to preserve or dispose of the documents must be made. The University Archivist has the authority to designate which records are archival. To decide if a record is of historic value to the university, or to initiate a transfer of records, contact the University Archivist.
Disposition Options:
- Destroy-Secured: If the record series contains restricted/confidential information, the records must be destroyed in a secure manner such as shredding or secure electronic destruction.
- Destroy: If the record series does not contain restricted/confidential information, the records may be destroyed by placing in trash or recycling, or electronic destruction (as well as in the manner described for secured destruction).
- Permanent within Department or Unit: Records series that have a demonstrated legal or administrative need to a particular unit on campus to be maintained permanently.
- University Archives: Records that have content that is or may have significant value to the university’s history should be transferred to the Archives.
- Archival Records - Records can be classified as either “restricted” or “open” by the Office of Origin.
- Restricted Records - Processed, preserved, and access controlled by the University Archivist.
- Authority to Request Review - Once an archived record has been classified “restricted,” only certain University offices have authority to request a review of the record including the Office of the President, Office of the Provost, Vice President for Finance, Vice President for University Advancement, and General Counsel.
- Request for Review - Only the Office of Origin may approve requests to access its restricted records. Upon receipt of a request (research or otherwise) to access restricted records, the University Archivist will determine if the request warrants consultation with the Office of Origin. If the request has merit, access to restricted records may be granted by the Office of Origin.
- Classification - Once classified as “restricted,” records will remain so for 50 years from date of creation. “Restricted” classification may not be applied to published material or material intended for public dissemination (e.g., speeches, newsletters, annual reports, and campus-wide initiatives.)
- Open Records - Processed and preserved by the University Archivist, but remain publicly accessible for research unless limited by state or federal law.
- Non-archival Records - Shred or otherwise render unreadable records with confidential information, including records containing social security numbers, credit card information, drivers' license numbers, patient treatment information, or other information as designated by an information steward. Dispose of records containing non-confidential or public information in an appropriate manner.