Chapman University's Memorial Hall
Institutional Compliance

» Record Retention Policy and Matrix

POLICY STATEMENT

Chapman University and various federal and state laws require that different types of records be retained for specific periods of time. The University has designated official repositories and a retention schedule for maintenance of these records.

 

REASON FOR THE POLICY

The University is committed to effective records retention to meet business needs, preserve its history, comply with legal standards, optimize the use of space, minimize the cost of record retention, and ensure that outdated and useless records are destroyed.

Definitions

  • Official Repository
    • The office/department listed on the Records Retention Schedule that is responsible for maintaining Records.
  • Record
    • Recorded information of any kind an in any form, including writings, papers, drawings, graphs, charts, images, prints, photographs, microfilms audio and video recordings, data and data compilations, and electronic media, including email, made or received by the University or pursuant to law or in connection with the transaction of University business, and preserved or appropriate for preservation by the University as evidence of its organization, functions, policies, decisions, procedures, compliance, operations or other activities, or because of the informational and historical value of data contained in the record.
  • Records Retention Schedule (RRS)
    • A descriptive schedule that provides a guideline for the minimum length of time that selected Records should be retained before they are deleted/destroyed.
  • Retention Period
    • The length of time a Record must be kept before it should be deleted/destroyed.

 

POLICY

University Records Management Program

The primary reasons for retaining Records are that they are required for business or legal purposes or they have enduring value.

The Records Retention Schedule (RRS) is a guideline that sets forth the minimum length of time that Records should be retained by the Official Repository. The Schedule allows the University to meet its business and legal needs, and to optimize the use of space, minimize the cost of record retention, and

ensure that outdated or useless Records are deleted/destroyed. Offices/departments should review their retention practice with the office/department identified as the Official Repository.

 

Preservation Holds

Record retention periods for selected Records may be increased for various reasons including government regulation, judicial or administrative orders, contracts, pending or threatened litigation or audit requirements. Suspension of Records destruction required for any reason will typically be accomplished by a Preservation Hold Notice sent out to the affected units by the Office of Legal Affairs directing that specified Records be retained and/or produced notwithstanding the retention guidelines set forth in the Retention Schedule. Instructions to preserve and/or produce Records may also be issued by the Chief Compliance Officer, Director of Internal Audit, Office of the Dean of Students, or the Human Resources Office. Upon receipt of instructions directing the preservation of Records, employees in the affected department are responsible for ensuring that the Record Retention Schedule is suspended; and that Records are not altered or deleted/destroyed until further instruction, regardless of whether the Records are stored on a University device or on an employee’s personal device (including, but not limited to, emails, text messages, voice messages, photographs, videos, and phone logs). Compliance with preservation holds, and requests for production of Records (regardless of whether the Records are stored on a University device or personal device); is required of all employees of the University, including Faculty, Staff and Administrators. Failure by any employee to comply with a Preservation Hold Notice or a request for production of Records may be cause for disciplinary action against that employee.

 

University Records Disposal

Records for which there is a retention requirement in the RRS are recommended to be deleted/destroyed by the Official Repository when they have reached the conclusion of their retention period unless there is a business or other reason to retain the Records, or unless directed otherwise to preserve Records.

Offices/departments other than the “official repository” should delete/destroy any duplicate records promptly unless there is a business or other reason to retain the Records, or unless directed otherwise to preserve Records.

Records should be deleted/destroyed in ways that commensurate with their confidentiality and with methods that do not permit recovery, reconstruction, or future use of confidential information. Before disposing of any Records containing confidential or sensitive information (including, but not limited to, Records containing personally identifiable information), or any Records that are being stored in accordance with an information security plan issued by the Information Security Office, the office/department should consult with the Information Security Office regarding the proper method for securely destroying the Records.

Any Record not listed on the RRS is not covered by this policy and should be retained in a manner consistent with existing practice and procedure, unless such Records are within the scope of a Preservation Hold Notice, in which case the terms of the Preservation Hold Notice must be followed.

Records created, retained, or stored electronically should be retained or deleted/destroyed on the same basis as traditional/paper Records.

 

APPENDIX

A – Record Retention Schedule (RRS)

 

OFFICE RESPONSIBLE FOR POLICY

Office of the Provost and Office of the Chief Operating Officer/Chief Financial Officer

Contact information for questions about this policy: Office phone number: Office of Legal Affairs: 714-997-6533 or Office of Institutional Compliance: 714-532-7795

 

WEBSITE ADDRESS FOR THIS POLICY

https://www.chapman.edu/campus-services/institutional-compliance-and-internal-audit/institutional-compliance/policies/record-retention-policy-and-matrix.aspx

 

WHO APPROVED THIS POLICY

Senior Staff member(s) submitting the policy: Harold Hewitt and Glenn Pfeiffer

Date approved: October 15, 2019

___________

President

 

Publication Date

Effective: October 2019

Revision history: Updated 11/5/19

 

Related Materials

Code of Ethics Policy

Fraudulent Activities Policy

Student Code of Conduct

Reporting Misconduct Policy