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.
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.
- 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
- 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 meeting minutes: Permanent
- Faculty promotion, tenure records, and tenure-review records: Permanent
- Conflict of interest disclosures: Permanent
- Presidential search records: Permanent
- Academic search records: 2 years from date search is completed
- Publicity records: Permanent
- Public Safety records: 5 years
- Annual reports: Permanent
- Commencement lists: Permanent
- Policies and procedures: 10 years after withdrawal/revision
- Alumni Association files: Permanent
- Alumni Council records: Permanent
- Credential files, students and alumni: Permanent
- Reunion class files: Permanent
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
- 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
- Fundraising: 5 years after end of registration period
- Endowment: Permanent
Human Resources 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
- Building plans and specs: Permanent
- 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
- 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.
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.