Title of Policy: Record Retention Policy
Policy No.: 1.3019
Type of Policy: Administrative
Effective Date: July 1, 2021
Last Revised: November 10, 2011
Policy Owner: Florida Memorial University
Policy Contact: Office of Administration and Finance
I. Reason for Policy
The Record Retention Policy exists to ensure effective record management at Florida Memorial University and to ensure FMU employees understand their obligations in retaining Records. FMU is bound to comply with legal and regulatory standards, preserve its history, optimize the use of space, and minimize the cost of record retention. The Policy is designed to ensure that necessary records and documents are adequately protected and maintained, to eliminate accidental or inadvertent record destruction, document the destruction of records at the proper time, and to facilitate FMU’s operations by promoting efficiency and reducing unnecessary storage of documents.
II. Policy Statement
Florida Memorial University disposes of records in accordance with an established records retention and disposition schedule. See Appendix. Certain records are permanent records and may never be destroyed. The University has designated official repositories to manage the retention and disposal of these records accordingly herein. Applicable documents will be archived per FMU policies and procedures.
III. Scope
This Policy applies to all University employees.
IV. Definitions
| Term | Definition |
| Records Custodian | A University administrator or designee who has supervisory authority over a particular business practice, and, in that capacity, who has responsibility for ensuring effective implementation of this policy in their area of authority. |
| Records Destruction | The physical or electronic destruction of a record after it has become obsolete or otherwise in accordance with this Policy.
Destruction includes: Recycling – generally appropriate for all non-confidential paper documents, including public documents of other organizations, magazines, newsletters, announcements, and drafts of policies or other memoranda which are not confidential. Shredding – using a shredder for all documents that should not be read by another after they are no longer needed or that contain personnel or confidential information. This is essential for any document containing personal information, information that is student protected information under FERPA, health related information, certain annual reports, or financial information. |
| Electronic Documents and Records | E-mail, Web files, text files, photographs, sound and movie files, PDF documents, and all Microsoft Office or other formatted files. |
| Litigation Hold | A communication issued as the result of current or anticipated litigation, audit, government investigation or other similar matter that suspends the normal process regarding the retention and disposition of FMU records. Violation of the hold may subject the individual to corrective action, up to and including dismissal, as well as personal liability for civil and/or criminal sanctions by the courts or law enforcement agencies. |
| Record | A record is anything containing information reflecting FMU educational and business transactions regardless of format (paper, digital, photographic, recordings, etc.). |
V. Responsibilities
All FMU employees are required to comply with this Policy.
A Records Custodian will oversee the day-to-day transactions related to the office’s records related functions and manage the disposition of records at the conclusion of the designated retention period.
VI. Enforcement
This Policy shall be enforced by University administrators. It is the responsibility of the Office of Administration and Finance to oversee enforcement of this policy. Any employee who violates this policy will be subject to corrective action that may result in warning, probation, suspension or separation from the University.
The University Policies and Procedures Library is updated regularly. In order to ensure a printed copy of this document is current, please access it online at http://policies.fmu.edu
Appendix
Document Type and Retention Period
| Accounts payable ledgers, supporting documentation, and schedules | 7 years |
| Accounts receivable ledgers, supporting documentation and schedules | 7 years |
| Accreditation records | 10 years |
| Annual budget | 7 years |
| Audit reports | Permanently |
| Bank reconciliations and bank reconciliations | 7 years |
| By-laws, articles of incorporation | Permanently |
| Capital campaign solicitation documentation (permanent) | Permanently |
| Capital campaign solicitation documentation (Temporary) | 7 years after expiration of donation |
| Charitable remainder trusts — permanent gift documentation | Permanently |
| Charitable remainder trusts — temporary gift documentation (all donations spent) | 7 years |
| Charts of accounts | Permanently |
| Checks (cancelled, except for below) | 7 years |
| Checks (cancelled, for important payments, purchases of property, special contracts) | 7 years to permanently |
| Construction contracts | 7 years |
| Contracts and leases (expired) | 7 years |
| Contracts and leases (not expired) | 7 years after expiration |
| Correspondence (legal and important matters) | 7 year to permanently |
| Deeds, mortgages, and bills of sale | 7 years after expiration or sale |
| Deposit slips and receipt documentation | 7 years |
| Depreciation schedules (expired assets) | 7 years |
| Depreciation schedules (non-expired assets) | 7 years after expiration |
| EEOC investigations | 7 years after conclusion |
| Employee applications | 3 years |
| Employee personnel records | 3 years after termination of employment |
| Faculty tenure records | 7 years after expiration |
| Federal reimbursement reports and documentation | 3 years after submission of the final expenditure report |
| Financial statements (end-of-year, other periods optional) | Permanently |
| Fiscal agent contracts/MOUs | 7 years |
| Fiscal agent subsidiary ledgers | 7 years |
| General ledgers | 7 years |
| Governance minutes | Permanently |
| Governance/board meeting packets | Permanently |
| Grant agreements (federal and non-federal) | 7 years after expiration |
| I-9 forms | 7 years after termination of employment |
| Insurance policies (expired) | 3 years |
| Insurance records, current accident reports, claims | 3 years after expiration of claims |
| Internal audit reports (may desire a longer retention) | 3 years |
| Inventories | 7 years |
| Investment ledgers and asset sale and purchase records | 7 years after disposal |
| Invoices to customers | 7 years |
| IRS correspondence | 7 years to Permanent |
| Litigation records | Permanently |
| Notes receivable (expired) | 7 years |
| Notes receivable (not expired) | 7 years after expiration |
| OSHA investigations | 7 years after conclusion |
| Patent records | Permanently |
| Payroll records and summaries | 7 years |
| Payroll registers | Permanently |
| Permanent donations documentation | Permanently |
| Permanent Trusts | Permanently |
| Phase 1, 2 property reports | 7 years after sale or disposition of property |
| Physical inventory documentation | 3 years |
| Property and equipment documentation | 7 years after sale or disposition |
| Purchase orders | 7 years |
| Receiving sheets | 7 years |
| Student Education Records | Permanently |
| Student Conduct Records | 7 years |