Summary of Policy:
To identify the record retention responsibilities and to document the storage and
destruction of the College’s documents and records
Dept. or Position Responsible for Policy: Finance & Operations Dept.
Date of Last Revision: October 8, 2008
[Approved by President’s Cabinet on October 8, 2008]
The retention of records by Juniata College is required by many governing agencies, including the Internal Revenue Service, Employee Retirement Income Security Act (ERISA), and the Uniform Commercial Code. In addition, the Labor Management Reporting and Disclosure Act of 1959 requires all records supporting a filing be kept for five years. Furthermore, ERISA regulations require all records be kept for seven years.
Therefore, the following record retention schedule is hereby established for Juniata College.
Juniata is committed to reduce impacts on the environment in a number of different ways. Therefore, it is Juniata’s recommendation that efforts be used as much as possible to move records into an electronic format to comply with the record retention requirements. An excerpt from the Internal Revenue Service website dated August 2008 listing the electronic format guidelines for record retention is attached to this policy.
- Change of grade forms
- Class lists
- Academic records (including narrative evaluations, competencies)
- Graduation Lists
Five Years After Graduation or Date of Last Attendance
- Academic Action authorizations (dismissal, etc.)
- Advanced Placement records (GRE’s)
- Independent Study/Internships
- Curriculum change authorizations
- Degree Audit records
- Program of Emphasis
- Secondary Emphasis
- In POE
- Minor Change Form
- Financial Aid documentations
- Foreign Student forms
- Graduation authorizations
- Name Change authorizations
- Transfer credit evaluations
- Tuition and Fee charges
Three Years After Graduation or Date of Last Attendance
- Application for admission or readmission
Two Years After Graduation or Date of Last Attendance
- Withdrawal authorizations
One Year After Date Submitted or After Graduation or Date of Last Attendance
- Applications for graduation
- Audit authorizations
- Drop/Add forms
- Class Schedules
- Credit/No Credit Approvals
- Grade reports (Registrar’s copies)
- Medical Records
- Pass/Fail requests
- Personal data information forms
- Registration forms
- Transcript requests (student)
Permanent While Active
- Student Evaluation Info. [SEI] data and student comments in electronic form while a member of the faculty holds a particular rank.
- SEI summary reports and student comments. Material older than 6 years is discarded from file; faculty member is contacted and given option to receive the info. or direct it to be discarded. JC retirees also provided that option.
- All data for deceased persons will be destroyed.
- Faculty data forms, colleague evaluations (internal and external) and other materials considered by PEC for purpose of promoting or retaining a faculty member. After 3 years, material is removed from PEC archives without option of returning to the faculty member.
- PEC final report and recommendation following promotions, tenure, actions
SEI summary reports and student comments for faculty no longer employed (for reasons other than retirement)
- Pertinent sports information
Five Years After Graduation or Date of Last Attendance
- Most written documents
- Audit reports of CPA’s
- Board of Trustees’ minutes, bylaws and articles of incorporation
- Cancelled checks for important payments, i.e., taxes, property purchases, special contracts, etc. Checks should be filed with papers pertaining to underlying transaction.
- Chart of accounts
- Correspondence (legal and important matters)
- Deeds, mortgages, contracts and leases still in effect
- End of year financial statements
- Fixed asset records and depreciation schedules
- General ledgers and year end trial balances
- Insurance records, accident reports, claims, policies, etc.
- Tax Returns
- Capital stock and bond records
- Property appraisals by outside appraisers
- Personnel records, retirement and pension records [electronic copy acceptable]
- Personnel records after termination
- Trademark registrations and copyrights
Six to Seven Years
- Accounts payable and receivable ledgers, trial balances
- Bank statements
- Contracts and leases (expired)
- Expense analyses and expense distribution schedules
- Inventory records
- Vendor invoices
- Payroll records and summaries, including payments to pensioners (W-2 forms, 1099’s and 941’s)
- Subsidiary ledgers to the general ledger and trial balances
- Travel expense reports and supporting documentation
- Vouchers for payments to vendors, employees, etc. (including allowances and reimbursement of employees, officers, etc., for travel and entertainment expenses)
- Stock and bond certificates (cancelled)
Two to Three Years
- Employment applications
- General correspondence
- Insurance policies-expired
- Miscellaneous internal reports
- Petty cash vouchers
One Year or Less
- Bank reconciliations
- Correspondence with customers or vendors
- Duplicate deposit slips
- Purchase orders
- Documentation pertaining to an endowment gift (electronic copy acceptable)
- Maintain electronic file copies for at least 5 years after an estate is closed
One Year following Maturity
- Hard copies of Planned Giving documentation (contracts, etc.) should be retained for a year following maturity (death of both donor and any beneficiary).
Recordkeeping & Disclosure requirements are governed by Federal regulations as found on the website link referencing the Federal Register that houses specific details: http://www.ifap.ed.gov/sfahandbooks/attachments/Vol2Ch90809.pdf
Chapter 9 Highlights of those regulations include:
- Program records
- Fiscal records
- Loan program records
- Record retention periods
- Acceptable formats
- Special requirements for SARs and ISIRs
Access to records & personnel
- Location & timely access
- Reasonable access to personnel
- FSA recipient information
Privacy of student & parent information
- FERPA rules
Excerpt from IRS website regarding Record Retention Requirements
Electronic Format Guidelines
August 19, 2008
In what format must the records be kept?
All records should be kept in a manner that ensures their complete access to the IRS for so long as they are material. While this is typically accomplished through the maintenance of hard copies, taxpayers may keep their records in an electronic format if certain requirements are satisfied.
Rev. Proc. 97-22, 1997-1 C.B. 652 provides guidance to taxpayers that maintain books and records by using an electronic storage system that either images their hardcopy (paper) books and records, or transfers their computerized books and records, to an electronic storage media. Such a system may also include reasonable data compression or formatting technologies so long as the requirements of the revenue procedure are satisfied. The general requirements for an electronic storage system of taxpayer records are provided in section 4.01 of Rev. Proc. 97-22. A summary of these requirements is as follows:
1. The system must ensure an accurate and complete transfer of the hardcopy books and records to the electronic storage system and contain a retrieval system that indexes, stores, preserves, retrieves, and reproduces all transferred information.
2. The system must include reasonable controls and quality assurance programs that (a) ensure the integrity, accuracy, and reliability of the system; (b) prevent and detect the unauthorized creation of, addition to, alteration of, deletion of, or deterioration of electronically stored books and records; (c) institute regular inspections and evaluations; and (d) reproduce hardcopies of electronically stored books and records that exhibit a high degree of legibility and readability.
3. The information maintained in the system must be cross-referenced with the taxpayer’s books and records in a manner that provides an audit trail to the source document(s).
4. The taxpayer must maintain, and provide to the Service upon request, a complete description of the electronic storage system including all procedures relating to its use and the indexing system.
5. During an examination, the taxpayer must retrieve and reproduce hardcopies of all electronically stored books and records requested by the Service and provide the Service with the resources necessary to locate, retrieve, read and reproduce any electronically stored books and records.
6. The system must not be subject, in whole or in part, to any agreement that would limit the Service’s access to and use of the system.
7. The taxpayer must retain electronically stored books and records so long as their contents may become material in the administration of federal tax law.