Cabrini College's Retention and Destruction Policy provides for the systematic review, retention, and destruction of documents received or created by Cabrini College in connection with the transaction of organization business.
I. Purpose In accordance with the Sarbanes-Oxley Act, which makes it a crime to alter, cover up, falsify, or destroy any document with the intent of impeding or obstructing any official proceeding, this policy provides for the systematic review, retention and destruction of documents received or created by Cabrini College in connection with the transaction of organization business.
This policy covers all records and documents, regardless of physical form, contains guidelines for how long certain documents should be kept and how records should be destroyed. The policy is designed to ensure compliance with federal and state laws and regulations, to eliminate accidental or innocent destruction of records and to facilitate Cabrini College’s operations by promoting efficiency and freeing up valuable storage space.
II. Document Retention Cabrini College follows the document retention procedures outlined below. Documents that are not listed, but are substantially similar to those listed in the schedule will be retained for the appropriate length of time.
Student Life Records
College Administration Records
Board of Trustees and other Governance, Committees, and Meetings
Accounting, Finance, and Payroll
Human Resources Records
Physical Plant and Equipment Records
III. Electronic Documents and Records
Electronic documents will be retained as if they were paper documents. Therefore, any electronic files, including records of donations made online, that fall into one of the document types on the above schedule will be maintained for the appropriate amount of time.
If a user has sufficient reason to keep an email 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.
IV. Emergency Planning
Cabrini College’s records will be stored in a safe, secure, and accessible manner. Documents and financial files that are essential to keeping Cabrini College operating in an emergency will be duplicated or backed up at least every week and maintained off site.
V. Document Destruction
Cabrini College’s vice presidents are ultimately responsible for each of their departments for the ongoing process of identifying its records, which have met the required retention period and overseeing their destruction. Destruction of financial and personnel-related documents will be accomplished by shredding. Shredding must be documented by a College approved document shredding company.
Document destruction will be suspended immediately, upon any indication of an official investigation or when a lawsuit is filed or appears imminent. Destruction will be reinstated upon conclusion of the investigation.
Failure on the part of employees to follow this policy can result in possible civil and criminal sanctions against Cabrini College and its employees and possible disciplinary action against responsible individuals.
The chief financial officer and finance committee chair will periodically review these procedures with legal counsel or the organization’s certified public accountant to ensure that they are in compliance with new or revised regulations.