1.07 Records Retention Policy
Consistent with Iowa Administrative Code (Regents (681), Chapter 10) requiring each institution governed by the Board of Regents, State of Iowa to develop internal rules for the economical, efficient and systematic management of its records, the University has established this policy to maintain, protect and retain or dispose of records in accordance with legal, historical and reference needs.
Records are the property of the state and, by law or contract, may also be subject to federal ownership or regulation. Records shall not be mutilated, destroyed, removed or disposed of, except as provided by law, rule, or policy. Records should be archived or disposed of in accordance with University archive/disposal requirements after the designated retention period, subject to exceptions stated in this policy regarding retention for audit and/or litigation purposes. Record retention may be guided by recommendations or standards from professional organizations; however, records will be retained as provided in the Records Retention Schedule. In addition, records will be maintained as required by other applicable legal or contractual provisions.
All University faculty and staff members have the responsibility for identifying and retaining records in accordance with established criteria and guidelines as outlined in the Records Retention Schedule
Definitions, Identification of Records, and Related Information
Records: anything containing information which is made, produced, executed or received in connection with the transactions or official activities of the University or in the conduct of University business, including research or scholarly or creative work, teaching, service and administration. Examples include documents, books, paper or electronic records, photographs, videos, sound recordings, databases, and other data compilations, regardless of physical form or characteristic.
For purposes of this policy, records are divided into two types, “official records” and “transitory/convenience records.”
Official records: Records that are subject to the records retention requirements as outlined in the Records Retention Schedule. These records are defined as:
- records having the legally recognized and judicially enforceable quality of establishing some fact, policy, institutional position or decision;
- the single official copy of a document maintained on file by an administrative unit of the University which is usually, but not always, the original.
Transitory/convenience records: Records that do not carry a requirement for retention as outlined in the Records Retention Schedule. These records should be destroyed when they cease to be useful, but should generally not be retained beyond the time specified in the Records Retention Schedule. Any destruction must use secure destruction methods if records contain confidential information. These records are defined as:
- duplicate copies of official records;
- extra copies of documents or records created or preserved for convenient access and/or reference, including duplicate computer files;
- miscellaneous papers or correspondence without official significance such as post-it notes, letters of transmittal, or routing slips; and/or
- versions or drafts of reports, memos, files, letters, messages or communication (electronic or otherwise) that are used to develop a final document.
Exhibition and promotional: These documents are not considered University records for the purposes of this policy. Exhibition and/or promotional documents that have historical or enduring value should be preserved for historical purposes in University Archives. Examples include:
- library and museum materials made or acquired and preserved solely for reference or exhibition purposes;
- stocks of publications for promotional or informational purposes;
- unprocessed University forms.
Confidential information: information that the University produces or receives, and holds confidential unless otherwise ordered by a court, by the lawful custodian of the records or by another person duly authorized to release such information. Examples include, but are not limited to, student records, medical records, and personnel records. Either official or transitory/convenience records may contain confidential information. (See Iowa Code section 22.7)
Vital information: information that is considered essential for the operations of a department or unit (and/or the University) and includes information that may prevent a department or unit from incurring serious liability or risk, or that would be extremely costly to replace. This information, if destroyed, would make it difficult to conduct normal business activities. Vital information may be contained in an official record or a transitory/convenience record.
Public record: any record, official or transitory/convenience, may be considered a public record. An exhibition and promotional document may also be considered a public record. A public record may or may not be subject to release, depending on the content of the record. (See Iowa Code Chapter 22; see also UNI “Public Records Requests” at https://publicrecords.uni.edu/.)
Disposal of records
“Disposal” refers to the disposal of a record, whether by physical destruction or transfer to the
University Archives for permanent retention.
- Official records shall not be destroyed or otherwise disposed of except as outlined in the Records Retention Schedule.
- Transitory/convenience records may be destroyed at the discretion of the user.
- Any record or document that may have historical or enduring value should be reviewed by
University Archives prior to any actual destruction.
- Secure destruction is required for any record containing sensitive or confidential information. Paper records must be shredded or destroyed in a manner to make them unreadable and reflecting any standards established for that particular record. Electronic records must be scrubbed or destroyed using current industry standards.
- If a record contains vital information, the record should be retained or disposed of as is appropriate.
Exceptions for the disposal of records:
- Any record, in any form, may not be disposed of if the holder is aware of any audit, litigation, public records request, claim, negotiation, open administrative review or other action involving the record.
- Records must be maintained until all required and relevant audits and requests are satisfied, and should be maintained beyond the required retention period where there is notice of a claim or litigation either involving records or requiring their use.
- If the Office of University Counsel has issued a litigation or legal hold, or the Office of Internal Audit has issued a hold, records relevant to the issue must be preserved until the hold is released.
President’s Cabinet, approved May 19, 2015
President’s Executive Management Team, approved June 1, 2015