Records Retention Policy

The University will retain Records in accordance with the University Record Retention Schedule. All University employees and others subject to this policy must comply with this policy, the University Record Retention Schedule, and any litigation hold communications. Failure to do so may subject the University, its employees, and outside vendors to civil or criminal liability.

Note: No document list can be exhaustive. Questions regarding the retention period for any specific document or class of documents not included in the University Record Retention Schedule should be addressed to the Office of General Counsel (OGC).

The Record retention schedule is a control document that describes the Records of the University by subject matter category, establishes a timetable for the maintenance, archiving, or destruction of the Records, prescribes an ultimate disposition for the Records and serves as the authorization for the disposition of Records.

Records not listed in the schedule that are substantially similar to those listed in the schedule, or that pertain to a particular transaction or matter documented by a Record listed in the schedule should be retained for the length of time required for the substantially similar/related Record.

Electronic records will be retained as if they were paper documents. Therefore, any electronic files that fall into one of the document types on the schedule or that represent a substantially similar/related document as discussed above, will be maintained for the scheduled length of time. E‐mail messages and/or other electronic files that need to be retained under this policy should be either (i) printed in hard copy and stored in the appropriate file or (ii) downloaded to a computer file and stored electronically or on a disk as a separate file.

This policy does not cover all situations or scenarios within the workforce of the campus community.  It has been established to guide processes that outline and define Trinity's actions in handling email accounts, data, etc. It is understood and recognized that not all categories and events may be captured within this policy.  In these instances, we will work with the authoritative department to work out flexible or other suitable arrangements as required.  It is the authoritative department’s responsibility to request changes or modifications to this policy and Trinity University’s process and procedures for disabling and deleting accounts and user data.  Additionally, it is the authoritative department’s responsibility to request access to a recently separated or terminated employee’s files in order to review and take appropriate action for the retention of documents, email correspondence and files.
 *Does not include legal holds or other University proceedings that require longer retention and preservation of data and files. 
 Classification, maintenance, retention, archiving and/or disposal of electronic records is the responsibility of the e-mail user, depending on the category of the Electronic Record, and must be in accordance with guidelines established by the University and also in compliance with Record Retention Schedule. For example, if an email contains housing assignments, it would be considered a Housing Assignment Record and maintained permanently per the Retention schedule.

Failure to properly maintain electronic records may expose the University and individuals to legal risks. Work-related emails are University records, and must be treated as such. E-mail that does not meet the definition of University record, e.g., personal or junk email, should be deleted immediately from the system and not be commingled with work-related messages.

It is important to note that the e-mail message should be kept with the attachment(s). The printed copy of the e-mail must contain the following header information: (1) who sent the message, (2) whom the message was sent to and (3) the date and time the message was sent, and (4) the subject of the message.

When an email is used as a transport mechanism for other types of records, it is possible, based on the content, for the retention and disposition period of the e-mail and transported record(s) to differ. In this case, the longest retention period shall apply.

The University servers are intended for short-term record retention. Information Technology (IT) performs backups on a regular schedule of the email and electronic files stored on central servers for disaster recovery. These backups are to be used for system restoration purposes only. IT administrators are not the legal custodians of messages or records which may be included in such backups. The disposition and retention of electronic records must be coordinated with the University’s Information Technology Department.

It is the end user’s responsibility to manage the proper maintenance, storage and handling of email messages and documents received via email.  This management process includes following the Trinity University Retention Schedule as email is not a storage location for files, documents or official University business correspondence.
 

University records will be stored in a safe, secure, and accessible manner. Documents and financial files that are essential to keeping the University operating in an emergency are duplicated and backed up on a regular schedule.

Departments are responsible for the safe and secure maintenance, storage, and disposition of their own records, with oversight by each vice president or their designee. The Office of Finance & Administration will serve as a resource for the ongoing process of identifying records that meet the required retention period. Once Records have been identified as having met the retention period, the following hardcopy Records will be destroyed by shredding: 1) University financial records; 2) individually-identifiable financial, medical, student, or personnel-related records; and 3) any other documents or records containing Confidential Information, as defined above, and/or non-public information about the University. If in doubt as to the proper method to destroy a document, shred it.

The disposition of electronic records must be coordinated with the University’s Information Technology Department.

When litigation against the University or its employees is filed or threatened, the law imposes a duty upon the University to preserve all documents and records that pertain to the issues. As soon as the OGC is made aware of pending or threatened litigation, a litigation hold directive will be issued to the legal custodian. The litigation hold directive overrides any record retention schedule that may have otherwise called for the transfer, disposal, or destruction of the relevant documents until the OGC has cleared the hold.

If a litigation hold is placed with respect to certain documents, there is a legal duty to maintain these documents in their original form, and they should not be destroyed or altered until the lawsuit is resolved.  The documents may be scanned into electronic form, but the original paper documents should not be destroyed after scanning and should be maintained for the pendency of the lawsuit. Once the litigation is resolved and the litigation hold is lifted, the paper documents may be shredded after the documents have been scanned.

Email and computer accounts of separated employees that have been placed on a litigation hold by University Counsel will be maintained by IT until the hold is released.

No employee whom University Counsel has notified of a litigation hold may alter or delete any record that falls within the scope of that hold.