HR Policies & Contracts

PDF Copy of Records Management Policy

ADOPTED 5/6/15 

Section One Statement of Policy

Roger Williams University (RWU) requires that University records, in all formats, be efficiently managed, retained and destroyed in compliance with academic, administrative, business and historical needs, as well as legal requirements and to optimize the use of space.

Section Two Applicability of Policy

 This Records Management Policy applies to each office, department or unit that has or may have the possibility of creating a record. The following is a list of offices, departments and units of the University that have the possibility of creating records; however the list is not intended to be inclusive, but rather illustrative of the entities that have that possibility.

Board of Trustees

President

Provost

Executive & Sr. Vice Presidents

All Vice Presidents

Chief of Staff

Academic Deans

Faculty Senate

Professor

Academic Advisement

Registrar

Human Resources

Sponsored Programs

Library

Learning Center

Enrollment Management

Law School

Financial Aid

Dean of Students

Student Conduct

Student Housing

Health Services

Athletics

Counseling

Camps & Conferences

Accounting

Treasury Management

Purchasing

Payroll

Accounts Payable & Receivable

Facilities Management

Bursar Information Technology

Cashier

General Counsel

Risk Management University Advancement

Alumni Relations Public Relations

Institutional Research

Public Safety

Lock Shop Environmental Health & Safety

Section Three

Definitions of Terms and General Description of Responsibilities

Document. 

A “document” is any piece of information, in any form, produced or received by RWU. It shall include written material such as letters, memoranda and reports; databases; websites; e-­‐mail communications; word and excel files; scanned images and photographs.

A document may be important to an operation of the University (such as an official transcript, letter of acceptance or appointment, approval of academic program, contract or e-­‐mail confirmation of an agreement, building plan, budget document, policy statement or Board resolution) or may not be important to the operation (such as an invitation to lunch, scheduling or confirmation of a routine meeting, a post-­‐it note or message to call home).

A document that is important to the operation of the University, when finalized, would become a record and would be governed by this Records Management Policy.

Record. 

A “record” is a document that is regarded as complete, final and unchangeable, except in controlled circumstances, and is considered important to an operation of the University. Thus, normally a draft of a document or file notes would not be considered a record.

Tangible Record.

Tangible records are those records that are in a format that may be handled and read by an individual, and are often referred to as “hard copies.” Historically, University records have been in tangible format; however, the University is expanding its use of Electronic Records. Tangible records that have been scanned shall be considered Electronic Records. Tangible Records shall be retained, managed and destroyed in accordance with the Records Retention Schedule (attached).

Electronic Record.

RWU has been expanding its use of a non-­‐ tangible “paperless” record format. Such records include but are not limited to word-­‐processor documents, spreadsheets, databases, HTML documents, scanned or imaged documents and any other type of file warehoused on-­‐ line via a hosted storage vendor, on a mainframe, on a computer hard drive or any external storage medium. The same retention standards that apply to tangible University records also apply to Electronic Records, and the retention periods outlined in the Record Retention Schedule (attached) apply equally to University records in all formats.

Active Record.

An Active Record, whether a Tangible Record or Electronic Record, is a University record currently used by a particular office, department or other area of the University that generated or received it. An active record shall be retained in an active file by the originating office for a particular purpose and for a limited period of time. After the record is no longer actively needed by a particular office, department or other area of the University that generated or received it, the record will be entirely destroyed or purged of certain documents and material consistent in compliance with the Record Retention Schedule (attached), or if the record is deemed to be an Inactive, Permanent or Archival Record (as hereinafter defined), the record shall be transferred to the appropriate file within the office.

Inactive Record/University Records Repository.

An Inactive Record, whether a Tangible Record or Electronic Record, is a record that is required to be preserved for a period of time in accordance with the Record Retention Schedule (attached), but which is no longer currently used by a particular office, department or other area of the University that generated or received it. As stated above, at such time as the record is no longer needed for use by a particular office, department or other unit of the University that generated or received it, the record shall be either destroyed or purged of certain documents, if within the timeframe set forth in the Records Retention Schedule, or maintained in the Inactive Records File storage in the generating or receiving office. If during the course of time, the Inactive Record becomes a Permanent or Archival Record, the Inactive Record shall be transferred to the appropriate Permanent or Archival file within the office.

Permanent Record/University Records Repository.

A permanent record, whether a Tangible Record or Electronic Record, is a record that is required to be preserved permanently in accordance with the Records Retention Schedule (attached), but which is no longer used by a particular office, department or other unit of the University that generated or received it. The generating or receiving office shall hold the Permanent Record in a Permanent Records File maintained within the generating or receiving office. Permanent Records shall be preserved in the format in which they are generated or received, except in the case of Tangible Records, which may be converted to and stored as Electronic Records.

Archival Record/University Archivist.

An Archival Record, whether a Tangible Record or Electronic Record, is a University record that has historic significance to RWU and shall be retained in the office or department in which it originated or received or sent to the University Archivist located in the University Library who shall preserve and retain the record in an archival file accessible only through the University Archivist. If the record is sent to the University Archivist, the office sending the record shall retain a copy of the record so transmitted.

Section Four

Confidential Information/Right of Privacy

Many records subject to this Records Management Policy contain personal confidential information, including but not limited to name, address, social security number, bank account information, financial or financial aid information, student identification number, medical information and employment information). Such records are protected by federal and state statutes including the Family Educational Rights and Privacy Act (FERPA), the Health Insurance Portability and Accountability Act (HIPAA), the Gramm-­‐Leach-­‐Bliley Act (GLBA) Information Security Program and Rhode Island Right to Privacy laws. Any such records shall be held confidential in accordance with legal requirements, and destruction of such records shall be undertaken securely and under careful supervision so as to eliminate the possibility of inadvertent release or publication of confidential or private information.

Other records contain information that, if revealed or disclosed, would cause serious harm to the business of the University or an office, department or other area of the University. Such records, which may in addition be proprietary or privileged, should be identified as “Confidential” and the confidentiality of such records shall be maintained. Destruction of such records shall be undertaken securely and under careful supervision so as to eliminate the possibility of inadvertent release of publication of such information.

Section Five

Administration of the Records Retention Policy

Administration of Records Retention Policy /Reports to University General Counsel. 

Each office or department is responsible for the administration of this Records Retention Policy, and any questions regarding the application of this policy shall be submitted to the University General Counsel.

Management of Records within an Office. 

The office, department or other area of the University that generated or received a record shall be the repository of Active, Inactive, Permanent and Archival Records. The head of the office, department or area that generated or received the record shall be responsible for receiving, managing and destroying Active Records under this Records Retention Policy; however, at such time as the records are no longer Active Records, and have not previously been destroyed in accordance with this Policy, the records shall be removed to the appropriate Inactive, Permanent or Archival file (as defined herein) maintained by the office.

The department head shall be responsible for providing appropriate access to Records, limiting access only to those who have job-­‐related responsibility with respect to material contained in the Record. If a department head denies access to a person who believes that she or he has a job-­‐related responsibility with respect to material contained in a Record, an appeal to the Office of General Counsel may be taken in a writing that sets forth in detail the Record requested and the reason why access is needed. The decision of the Office of General Counsel shall be final with regard to the issue of access to the Record.

Separate Files for Records. 

Each office, department or unit that creates a record shall establish a file or files for holding University Records, which files shall be separate from other files. A standard file shall be for tangible records and a computer file for electronic records. At such time as a document becomes a record (see definitions above), that document shall be transferred to the records file, although a copy may be retained elsewhere for as long a period of time as that record is needed in the office. If at any time an Inactive, Permanent or Archival Record is needed by the office, department or unit that created it, that Record may be retrieved from the appropriate file in replaced in the Active Records File.

Records Retention Committee.

The President of the University, after consultation with the President’s Cabinet, shall appoint a committee of five

(5) RWU non-­‐aligned employees to advise the President, through the President’s Chief of Staff, from time-­‐to-­‐time, as requested by the President, and to annually review this Records Management Policy and Schedule and to suggest modifications as deemed appropriate and to ensure compliance. Appointments to the Committee shall be for terms of from one (1) to three

(3) years to allow for Committee continuity. The President shall appoint one Committee member to serve as chair of the Committee. An attorney with the Office of General Counsel shall attend any and all meetings of the Committee.

Legal Advice and Counsel.

In the event the office manager or department head is uncertain as to whether a particular record should be retained or destroyed, he or she shall address the issue to the Office of the General Counsel for a decision based on appropriate law, rule or regulation or University policy. 

Upon the direction of the Office of General Counsel, retention periods may be increased for reasons relating to pending or possible litigation or audit requirements, or for any other reason.

Manner of Record Destruction. 

In the event it is determined that a particular record should be destroyed, the record should be destroyed in one of the following ways:

(a)  Tangible Records should be shredded so that confidential and/or personal information cannot practicably be read or reconstituted; or

(b) Electronic Records and other non-­‐tangible media shall be destroyed or erased so that confidential and/or personal information cannot practicably be read or reconstructed. The office manager or department head, as the case may be, shall contact the Office of Information Technology to ensure that electronic records are destroyed appropriately.

Convenience Copies.

There is no need for employees, offices, departments and other areas of the University that did not generate or receive a particular record to retain copies of University records beyond the time they are useful in conducting University business. Duplicate or multiple copies of University records (“Convenience Copies”) should be destroyed (using secure destruction methods if they contain confidential or personal information) when the records are no longer useful, but in no event later than the retention duration noted in the Records Management Schedule. 

Records, Including Computer Records, Belong to the University.

All records, including but not limited to records maintained on University-­‐ owned computers assigned to University employees, belong to the University and are subject to the within Records Management Policy. Such records shall not be removed from the control of the University.

University records shall not be created, stored or retained in an employee’s personal facility or computer.

Upon Termination of Employment.

At such time as an employee leaves his or her position at the University, he or she shall not remove or delete any record or document from the University, including but not limited to any record or document contained in University-­‐owned computer(s) assigned to him or her while employed at the University. The computer(s) so assigned shall, on or before the last day of the employee’s service to the University, be delivered to the Office of Information Technology, which Office shall be responsible for insuring that records contained in the computer shall be retained or destroyed in accordance with the provisions of this Records Management Policy. Tangible records shall remain in the office in which the employee worked while at the University. 

Section Six

Records Retention Schedule

The following list contains the length of time that specific records shall be managed and retained, then, if not Permanent or Archival Records, destroyed. The list is not exhaustive; and questions regarding the retention period for any specific record or class of records should be addressed to the University Records Administrator, who in appropriate cases, shall seek the legal advice of the Office of General Counsel.