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Information and Updates for the Iona Community on Coronavirus

Document Retention

Effective Date: February 6, 2018

Policy Statement

In accordance with federal, state, local applicable laws, rules and regulations, Iona College requires that College records be retained for specific periods of time, and be maintained in specific repositories. The records will be properly and diligently upheld by following the rules and regulations of this document. This policy relates to original, tangible, hard-copy documentation and does not apply to an electronic record which will be addressed in a separate policy for all electronic formats.

Reason for Policy

Iona College is enthusiastic to achieve accurately and legally responsible record retention to allow us to be historically accountable. The policy’s purpose is to include any hard copy record made, produced or received by any department, employee, or office of the College. The policy will apply to all record documents in paper and other traditional media formats. Individual departments are capable of intensifying procedures if they are consistent with the given policy.

The intention of the policy is to provide the College with an organized procedure and schedule that will comprise of:

  • Meeting legal standards
  • Optimizing the use of electronic and physical storage space
  • Minimizing costs related to record retention
  • Maintaining the history of the College
  • Properly destroying outdated and useless records

Who Should Know the Policy?

All College Faculty and Staff, Independent Contractors, and Board of Trustee members that is responsible for the accurate creation, placement or usage of any record for Iona College.

  • v Recycle non-confidential paper records
  • v Shred or otherwise render unreadable confidential paper records

Definitions

  • Active Record: An original College Record currently used by the office, department or other area of the College that generated it. Active Records remain active for varying numbers of years, depending on the purpose for which they were created and regulatory requirements. Active Records may be retained in the originating office or at an offsite storage company.
  • Data Owners: Each department that maintains records, financial information, employee information either in electronic or paper form, is required to designate an individual who will ensure that records in his or her area are preserved, maintained and retained in compliance with policies and retention schedules.
  • Destruction of Iona College information and records: At the end of the designated retention period for each type of information or record, destruction will take place in accordance with the procedures in this policy unless a legal hold/preservation order exists or is anticipated. Destruction will be finalized through shredding and incineration. Each Department Manager will be responsible for signing off on what is to be destroyed in their area.
  • Historical Record: Materials made or acquired and preserved solely for reference or exhibition purposes.
  • Inactive College Records: An original College Record that is not an Active Record but still must be maintained pursuant to the Record Retention Table set forth below
  • Personal Information: Records that include an individual’s name together with that individual’s demographic information, date of birth, Social Security Number; drivers’ license number or New York state identification card number; financial account number, or credit or debit card number, with or without any required security code, access code, personal identification number or password that would permit access to an individual’s financial account; or biometric indicator. Personal Information is highly sensitive, and must be safeguarded and secured at all times.
  • Permanent Record: Document which is retained permanently because of its administrative, historical, or legal value. For example a student transcript is a student's permanent academic record of all courses taken, all grades received, all honors received and degrees conferred.
  • Property Rights: All records generated and received are the property of Iona College. No employee, by virtue of his or her position, has any personal or property right to such records even though he or she may have developed or compiled them.
  • College Record: The original or official copy of any record/document. The Official Repositories for these records are identified in the table at the end of this document. There is no need for offices and departments that are not the Official Repository for a College Record to retain copies of those records.
  • Record Retention Schedule: The document identifying types of records that, for business and/or legal reasons, are subject to mandatory retention for a specific period of time.
  • Unauthorized Destruction: The unauthorized destruction, removal, alteration, or use of information and records is prohibited.
  • Workforce Responsibility: All employees and agents are responsible for ensuring that Iona College information and records are created, used, maintained, preserved, and destroyed in accordance with this policy.

Record Disposal

After accurately reviewing the retention schedule and the College policy, you can determine whether or not it is suitable to dispose of a record(s). In the event they are applicable for destruction these are the following ways to dispose:

  • Recycle non-confidential paper records
  • Shred or otherwise render unreadable confidential paper records
  • Erase or destroy electronically stored data (ask IT department for assistance).

For questions regarding responsibilities or confusion relating to retention please contact the Data Owners or General Counsel.

General

Any record that is part of a current audit, investigation or litigation may not be destroyed even if the time period for retention per College policy has elapsed. Ultimately, if there is any such doubt regarding the ability to destroy a document you should follow the retention schedule. If unsure, check with the Data Owners or General Counsel.

Record Retention Schedule

Student Records
Type of Record Official Repository Retention Period Guidance
Admissions Files- Unenrolled Students Enrollment Management 3 Years after Application Term AACRAO
IRS – Tax Exempt Status
Grade Book Faculty 1 year after date submitted AACRAO
Unreturned student Exams (Final)/graded coursework Faculty One Year after Course Completion AACRAO
Immunization Records Health Services 3 years after Graduation or last date of attendance AACRAO
Academic Warning or Suspension Office of the Deans 3 years after graduation or last date of attendance AACRAO
Advising Files Office of the Deans & Center for Advising and Academic Services 5 years after graduation or last date of attendance AACRAO
Catalogs Office of the Provost Permanent AACRAO
Academic Integrity Code Violations with sanctions Registrar and appropriate Dean’s Offices Permanent AACRAO
Clery Act – 34 CFR 668.46
Academic Dismissal Registrar and appropriate Dean’s Offices Permanent AACRAO
Admissions Files- Registered Students Registrar 5 years after graduation or last date of attendance AACRAO
CPLR § 213
Class Lists Registrar Permanent AACRAO
Placement Tests and Scores Registrar 5 years after graduation or last date of attendance AACRAO
Audit Authorizations (assume this is “course” audits?) Registrar 1 Year after processing AACRAO
Changes of Course(add/drop) Registrar 1 Year after processing AACRAO
Application for Graduation Registrar 1 Year after processing AACRAO
Correspondence, relevant to student’s academic record Registrar 5 years after graduation or last date of attendance AACRAO
Changes of Grades Registrar Permanent AACRAO
Credit by Examination Reports Registrar 5 years after graduation or last date of attendance AACRAO
Credit/no Credit Approvals (Audit, pass/fail, etc.) Registrar 1 Year after processing AACRAO
Name Changes and changes to Personally Identifiable Information Registrar 3 years after Graduation or last date of attendance AACRAO
Schedule of Classes Registrar 3 years after Graduation or last date of attendance General Education Provisions Act
Transcripts (IONA) Registrar Permanent AACRAO
Curriculum Change Authorizations Registrar 5 years after Graduation or last date of attendance AACRAO
Transcripts (High schools & other colleges) Registrar 5 years after Graduation or last date of attendance AACRAO
Graduation Lists Registrar Permanent AACRAO
Correspondence, relevant to student’s SFS record Student Financial Services 5 years after Graduation or last date of attendance AACRAO
International Students Student Financial Services 3 years after Graduation or last date of attendance 8 CFR 214.3 (g): 22 CFR 62.10 (h)
Residency Classifications Student Financial Services 3 years after Graduation or last date of attendance AACRAO
Student Employment Records Student Financial Services 6 years after employment terminates 29 CFR 519.7
Withdrawal Authorizations & Leave of Absences Student Financial Services & Registrar & Student Success 3 years after Graduation or last date of attendance General Education Provisions Act
Financial Aid Records - Federal Perkins Loans included Student Financial Services 7 years after Graduation or last date of attendance AACRAO
Disciplinary Action Records Student Life Minor Action: 5 years after Graduation or last date of attendance

Major Action: 7 years after Graduation or last date of attendance

Suspension, dismissal, or expulsion: Permanent
AACRAO
Clery Act
Residency Occupancy Records Student Life 6 years after expiration of contract or room assignment CPLR § 213
Residency Change Documents Student Life 5 years after Graduation or last date of attendance AACRAO
Residency Damage Records Student Life 6 years after the end of the fiscal year CPLR § 213
Accounting & Finance
Type of Record Official Repository Retention Period Guidance
Account Reconciliations Office of Finance 7 years AICPA
Accounts Payable Vouchers and Attachments Office of Finance 7 years AICPA
Accounts Receivables Statements Office of Finance 7 years AICPA
Audit Reports Office of Finance Permanent AICPA
Bank Statements including Deposit and Withdrawal Records Office of Finance 7 years AICPA
Financial Statements and Work Papers Office of Finance Permanent AICPA
Cash Receipts Office of Finance 7 years AICPA
Depreciation Records Office of Finance 7 years or Life of Asset AICPA
General Ledger Office of Finance 7 years AICPA
Investment Reports Office of Finance 7 years AICPA
Inventories Office of Finance 7 years or Life of Asset AICPA
IRS Determination Letter Office of Finance Permanent AICPA
Journal Entries Office of Finance 7 years AICPA
Purchase Orders, Contracts & Agreements Office of Finance 7 years AICPA
Travel Reimbursements and Attachments Office of Finance 7 years AICPA
Bond Debt Supporting Materials Office of Finance 3 years after the final redemption date of the bond repayment terms Internal Revenue Code; USC 26-1.6001-1(e) and Section 148
Alumni Affairs & Advancement
Type of Record Official Repository Retention Period Guidance
Gift Records Advancement & External Affairs 7 years or if a multi-year gift then 7 years after the last gift payment is fulfilled. IRS
Original Gift Letter Agreements, All others Advancement & External Affairs 7 years or if a multi-year gift then 7 years after the last gift payment is fulfilled. IRS
Planned Gifts (trusts, life income, agreements, annuities) & Real Estate Gifts Advancement & External Affairs Permanent IRS
Athletic Student Record
Type of Record Official Repository Retention Period Guidance
Player Recruitment Scouting File Athletics 7 Years NCAA
Athletic Scholarship File Athletics 7 Years NCAA
Substance and Alcohol Abuse Testing Records Sports Medicine 7 Years NCAA
Athletic Training Records Athletics 7 Years NCAA
Athletic Eligibility Reports/Health Information Athletics 7 Years NCAA
Athletic Injury Medical Records Sports Medicine 7 Years NCAA
Official Squad Lists Athletics Permanent NCAA
Investigations/Substantiated Allegations Athletics Permanent NCAA
Game Contracts Athletics 7 Years NCAA
Player and Game Statistics Athletics 7 Years NCAA
Practice Log Records Athletics 7 Years NCAA
Photos and Press Clippings Athletics Communications Permanent
Ticket Records Athletics 7 Years NCAA
Clinic Health Information
Type of Record Official Repository Retention Period Directive
Patient/Client Records Respective Clinic 6 years after expiration or discharge or 3 years after individual attains age 18, whichever is longer New York State Office of the Professions
Construction & Facilities Management
Type of Record Official Repository Retention Period Guidance
As-Built Drawings /td> Facilities Management Permanent  
Construction & Renovation Contracts Facilities Management Permanent AICPA
Contracts of Negotiation Records, Executed Contracts Facilities Management For contracts and agreements finalized: 7 yrs after the contract expires; all other records: hold until admin. use ceases AICPA
Records of Preventive Maintenance, Service or Repairs Facilities Management Five years from the date the instrument is no longer in use  
Corporate Records
Type of Record Official Repository Retention Period Guidance
Conflict of Interest Disclosure Employee: Internal Audit

Trustee & Officer: Board Secretary
7 years 29 CFR 1602.48 ADEA Rehabilitation Act VEVRAA • EO
Certification, Licensing and Accreditation Records Office of the President 7 Years after superseded, revoked, or no longer valid AICPA
Board of Trustee and Governance Minutes Board Secretary Permanent AICPA
Board of Trustee Bylaws Board Secretary Permanent AICPA
Charter Office of the President Permanent AICPA
Contracts The Contracting Department and the Office of Finance and/or Information Technology and/or General Counsel. 3 years after contract termination/completion of work AICPA
Survey, evaluation and inspection records covering review of facilities by state or federal agency Facilities Permanent AICPA
Survey, evaluation and inspection records covering review of programs by state or federal agency The Respective Department and the Office of Finance and/or General Counsel. Permanent AICPA
Survey, evaluation and inspection records covering review of programs by professional review organization. Office of the Deans Permanent AICPA
Equal Opportunity
Type of Record Official Repository Retention Period Guidance
Federal & State Required Statistics and Reports Institutional Effectiveness and Planning 7 years 29 CFR 1602.48
Academic & Non-Academic Search Materials and Documents that Support Hiring Selection Decisions Human Resources 3 years from date of decision • Title VII; • Civil Rights Act of 1866 • ADAAA • ADEA • EO • DBRA • Rehabilitatio n Act of 1973 • VEVRAA • FLSA
Complaints of Unlawful Discrimination and Harassment Human Resources Permanent Title VII; 29 C.F.R. § 1602.14 ADEA; 29 C.F.R. § 1627.3(b)(3) ADAAA; 29 C.F.R. § 1602.14 Rehabilitatio n Act; 41 C.F.R. § 60-741.80(a) EO 11246; 41 C.F.R. § 60-1.12(a) VEVRAA; 41 C.F.R. § 60-
Human Resources
Type of Record Official Repository Retention Period Guidance
Contracts & Insurance Policies for Benefits Human Resources Permanent FLSA; 29 C.F.R. § 516.5 EPA; 29 C.F.R. § 1620.32
Deceased Employee Claims Human Resources 7 years after date of death Occupational Safety and Health Act, 29 U.S.C. § 651, et seq.; 29 C.F.R. §§ 1904–1904.46
Employee Personnel Files (hire paperwork, salary records, status changes, tenure/promotion, retirement/termination and appointment recommendations) Human Resources 7 years after departure 29 CFR 1602.48 ADEA • Rehabilitation Act • VEVRAA • EO
Faculty Benefits Applications & Paperwork includes: Long- Human Resources 7 years after departure FLSA, Title 29 U.S. Code § 205; 29 Code of Federal Regulations § 541 EPA; 29 C.F.R. § 1620.32 29 CFR § 516
Term Disability Forms Human Resources 7 years after termination FLSA; 29 C.F.R. § 516.5 EPA; 29 C.F.R. § 1620.32
Faculty & Staff Benefit Handbook Human Resources Permanent AICPA
Federal Reporting Requirements (Welfare benefits and fringe benefits Human Resources Permanent IRS
Files for Disabled Employees Human Resources 7 years after benefits end EO 11246; 41 C.F.R. §§ 60-1.12(c), 60-2.10 through 60-2.17 Rehabilitatio n Act; 41 C.F.R. §§ 60-741.44, 60-741.80(a)-(b) VEVRAA; 41 C.F.R. §§ 60-300.44, 60-300.80(a)-(b)
I-9 Forms Human Resources 3 years after employment date or separation (whichever is greater) – applies to employees hired after November 6, 1986 Coverage: 8 U.S.C. § 1324a to 1324b; 8 C.F.R. §§ 274a.1, 274a.7 Recordkeepi ng Requirement s: 8 U.S.C. § 1324a; 8 C.F.R. § 274a.2
Individual Contracts of Employees Human Resources 7 years after separation FLSA; 29 C.F.R. § 516.5 EPA; 29 C.F.R. § 1620.32
Occupational Injury or Illness records relating to employment (Worker’s Compensation) Human Resources Master Summary Record – Indefinite

Case Records 10 years after termination of employment
29 CFR 1910.20
Performances Reviews Human Resources 7 years after separation  
Search Committee Records (employment application, resumes, applicant search materials Human Resources 3 years after date of decision • Title VII; • Civil Rights Act of 1866 • ADAAA • ADEA • EO • DBRA • Rehabilitatio n Act of 1973 • VEVRAA • FLSA
Severance Agreements Human Resources 7 years after expiration 29 CFR 1602.48 ADEA • Rehabilitation Act • VEVRAA • EO
Wage Theft Protection Annual Notices Human Resources 6 years N.Y. Lab. Law § 195, 661, 663; N.Y. Gen. Bus. Law § 399-H; N.Y. Comp. Codes R. & Regs. tit. 12, § 142-2.6
Insurance Policies Office of Finance Permanent FLSA; 29 C.F.R. § 516.5 EPA; 29 C.F.R. § 1620.32
Volunteer Onboarding Forms Human Resources 7 years after volunteer services  
Title IX Investigations and Outcomes Human Resources Student: 5 years from the outcome of an investigation
Faculty: 6 years from the outcome of an investigation
Title IX, United States Education Amendments of 1972. This is Public Law No. 92-318, 86 Stat. 235 (June 23, 1972), codified at 20 U.S.C. §§ 1681–1688.
Insurance
Type of Record Official Repository Retention Period Guidance
Certificates of Insurance, Indemnification Agreements, Hold Harmless Agreements, Other Contracts Office of Finance
Contracting Department
7 years after expiration AICPA
Insurance Policies (Liability, Property and other Policies) Office of Finance Permanent AICPA
Incident Reports & Accident Reports Office of Finance 7 years after report date unless the incident report pertains to an open litigation matter, then maintained until the case is resolved AICPA
Internal Audit
Type of Record Official Repository Retention Period Guidance
Internal Audit Reports Internal Audit 10 years after Issue Date PCAOB Sec 103(a)
Workpapers Internal Audit 7 years after last date of fieldwork PCAOB
Quality Internal Audit Assessment Internal Audit 5 years IIA Attribute Standard 1312
RFP Bids: Accepted Internal Audit or Contracting Department Life of the Associated Contract AICPA
RFP Bids: Accepted Internal Audit or Contracting Department 3 years AICPA
Legal
Type of Record Official Repository Retention Period
Consent Orders General Counsel Permanent
Court Orders General Counsel Permanent
Judgments General Counsel Permanent
Releases General Counsel Permanent
Settlements General Counsel Permanent
Payroll
Type of Record Official Repository Retention Period Guidance
Annual Payment Records (W-2 Forms) Office of Finance/ Payroll Department Permanent IRS
Information Returns filed with Federal and State authorities (W-2, 941, etc.) Office of Finance/ Payroll Department 7 years IRS
Payroll Deduction Authorization Forms Office of Finance/ Payroll Department 6 years after employment ends N.Y. Lab. Law § 195, 661, 663; N.Y. Gen. Bus. Law § 399-H; N.Y. Comp. Codes R. & Regs. tit. 12, § 142-2.6
Record of Payments and Deduction (payroll registers, deduction lists, adjustments) Office of Finance/ Payroll Department 6 years after employment ends N.Y. Lab. Law § 195, 661, 663; N.Y. Gen. Bus. Law § 399-H; N.Y. Comp. Codes R. & Regs. tit. 12, § 142-2.6
Time Records (student and non students) Office of Finance/ Payroll Department 6 years after employment ends N.Y. Lab. Law § 195, 661, 663; N.Y. Gen. Bus. Law § 399-H; N.Y. Comp. Codes R. & Regs. tit. 12, § 142-2.6
Public Safety
Type of Record Official Repository Retention Period Guidance
Accident Reports Campus Safety & Security 7 years after report date Clery Act
Daily Assignment Sheet Campus Safety & Security Permanent  
Parking Citation Records Campus Safety & Security 7 years after Graduation or last date of attendance  
Fume Hood Testing Records Facilities 3 years  
Hazardous Waste Disposal Manifests and Reports Facilities 10 years  
Incident Reports Campus Safety & Security 7 years after report date Clery Act
Real Property
Type of Record Official Repository Retention Period Guidance
Property Deeds, Easements, Licenses, Rights of Way, Leases, Rights of First Refusal, Mortgages, Remainder Interests Office of Finance Permanent AICPA
Property Tax Returns filed with taxing Jurisdiction Office of Finance Permanent AICPA
Building Plans, Blueprints and Design plans Facilities Permanent AICPA
Sponsored Projects, Contracts & Grants
Type of Record Official Repository Retention Period Guidance
Grant and Contract Applications, Proposals, and Supporting Documentation Office of the Provost 7 years after close of grant or longer if required by granting agency OMB Cir A-110, Uniform Administrativ e Requirement s for Grants and Agreements with Institutions of Higher Education, Hospitals, and Other Non-Profit Organizations
IRB Applications Office of the Provost 3 years  
Records of Human Subject Records, including Consent Forms Principal Investigator (PI) 3 years from completion of study or longer if required by study sponsor  
Taxes
Type of Record Official Repository Retention Period Guidance
Federal & State Tax Filings Office of Finance Permanent IRS
Department Representative responsible for maintaining the departmental inventory of records and executing the policy
Department Department Representative
Advancement & External Affairs Director for Database Management & Compliance
Athletics Assistant Athletics Director of Compliance
Campus Safety & Security Director of Campus Safety and Security
Board Secretary Chief of Staff and Board Secretary
Clinics Health Services: Director
Counseling: Director
Hearing & Speech: Clinic Director
Enrollment Management Senior Assistant Director of Admissions
Facilities Associated Director of Facilities Management
Faculty Dean, School of Arts & Science
Dean, School of Business
General Counsel General Counsel
Human Resources Human Resources Systems and Data Manager
Information Technology IT Project and Process Management
Institutional Effectiveness and Planning Director of Institutional Effectiveness and Planning
Internal Audit Director, Internal Audit
Office of Finance Assistant Controller
Office of the Deans Dean, School of Arts & Science
Dean, School of Business
Office of the President Chief of Staff and Board Secretary
Office of the Provost Associate Vice President of Academic Affairs
Principal Investigator Chair, Institutional Review Board
Registrar Registrar
Student Financial Services Associate Vice President for SFS
Student Life Assistant Vice Provost for Community Standards