Records Retention Policy

Cabrini University’s Retention and Destruction Policy provides for the systematic review, retention, and destruction of documents received or created by Cabrini 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 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’s operations by promoting efficiency and freeing up valuable storage space.

II. Document Retention
Cabrini 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.

Academic/Student Records

Admission records: 10 years
Grade records: Permanent
Other academic records: 5 years
Career planning and placement: 4 years
Class schedules: Permanent
University catalog: Permanent
Degree audit records: 5 years after date of last attendance
Disciplinary action records: 5 years after graduation or date of last incident
Enrollment statistics: Permanent
Financial aid records: 5 years after annual audit has been accepted
Foreign student forms: 5 years after graduation or date of last attendance
Student academic files (departmental): 5 years
Transcript requests: 1 year
Tuition fees and schedules: Permanent

Student Life Records

University publications: Permanent
Fraternities/sororities files: Permanent
Publications locally produced: Permanent
Student counseling files: 5 years after case is closed
Student groups and organizations: Permanent
Student handbooks: Permanent
Team rosters: Permanent
Athletic contest scores and statistics: Permanent
Athletic injury files: 7 years
Media guides: Permanent
NCAA case files/infraction files: 7 years from date of last incident

University Administration Records

Board of Trustees and other Governance, Committees, and Meetings

Proceedings of the Board of Trustees and Committees, Academic Committees, and Administrative reports: Permanent
Records of other committees and meetings: 5 years

Contracts/Legal

Design and Construction contracts: Life of building
Other contracts: 7 years after termination
Insurance policies: Permanent
Equipment warranties: Life of equipment
Patent, trademark, and other Intellectual property records: Permanent
Litigation, claims, risk management, incident reports: 7 years
Authorizations for release of records, subpoenas, court orders: 7 years
Real property records: Permanent
Regulatory Records Accreditation records: Permanent
Licensure records: Permanent

Faculty Records

Faculty meeting minutes: Permanent
Faculty promotion, tenure records, and tenure-review records: Permanent
Conflict of interest disclosures: Permanent

Search Records

Presidential search records: Permanent
Academic search records: 2 years from date search is completed

Miscellaneous

Publicity records: Permanent
Public Safety records: 5 years
Annual reports: Permanent
Commencement lists: Permanent
Policies and procedures: 10 years after withdrawal/revision

Alumni Records

Alumni Association files: Permanent
Alumni Council records: Permanent
Credential files, students and alumni: Permanent
Reunion class files: Permanent

Financial Records

Accounting, Finance, and Payroll

Accounts payable and receivable records: 7 years
Books of accounts: 7 years
Banking records: 7 years
Financial statements, annual reports to government agencies: 7 years

Budgets

Permanent Payroll records: 7 years
Employee benefit plans: 1 year after term of plan
Records of property subject to gain or loss treatment: 7 years after taxable disposition
Records supporting items of income deductions and credits: 7 years
Tax returns and supporting records: 7 years

Development

Fundraising: 5 years after end of registration period
Endowment: Permanent

Human Resources Records

Employment Records

Records relating to leave under FMLA: 3 years
EEOC reports: 5 years
EEO-1: 7 years
Personnel files: 7 years from termination
Training records: 4 years
In-Service records: 4 years
Educational programs: 4 years
Records of workers employed under special certificates: 3 years
Wage-hour administrator certificates and notice:s 5 years
Immigration records: 3 years after hire or 1 year after termination, whichever is later
Attendance records: 3 years
Other employment records: 3 years

Physical Plant and Equipment Records

Construction

Building plans and specs: Permanent

Facilities

Operational manuals: Life of building
Records related to measurement of noise in work environment: 4 years
Records of fire, internal disaster, and evacuation plan drills: 4 years
Records of fire department inspection: 4 years
Written report and evaluation of all external disaster plans: 4 years
Health and Safety Records of inventory, use and control of radioactive materials: 30 years
Records of disposal or abatement of toxic and hazardous waste: 30 years
Transportation of infectious waste: 30 years
Records of hazardous waste generation: 30 years
Records of employee exposure to hazardous substances: 30 years
Records of asbestos exposure: 30 years

Equipment

Records of required testing of fire protection equipment: 4 years
Records of periodic inspections of extinguishing systems:
Until the container is re-inspected or its life
Material hoists, personnel hoists, elevator standards, and certification records: 4 years
Records of inspection, performance, exercising period, and repairs of emergency power equipment: 4 years

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’s records will be stored in a safe, secure, and accessible manner.

Documents and financial files that are essential to keeping Cabrini operating in an emergency will be duplicated or backed up at least every week and maintained off site.

V. Document Destruction

Cabrini’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 Cabrini-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.

VI. Compliance

Failure on the part of employees to follow this policy can result in possible civil and criminal sanctions against Cabrini 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.