Penn State - Administrative
This policy specifies the regulations by which University records are defined, captured, utilized, stored, disposed of, and properly archived when they meet the University's criteria for constituting a “University Record.” This policy provides the means to define and offer counsel to University offices during the creation and use of all University records. Further, it sets records management standards and creates Records Retention, Disposition, and Destruction Schedules for those records. It establishes archival criteria to maintain and assure continued access to appropriate historical records, in all formats in which they are created and retained.
This policy is applicable to all areas, locations, campuses, offices and units (hereinafter referred to as "Units" of the University). A Records Management Liaison, hereinafter referred to as a "RML," must be appointed for each Unit to serve as steward for those records in conjunction with University Archives/Records Management Program. Certain Units that store and maintain institutional records may have individual guidelines which supplement, but do not supplant, this policy.
The record retention guidelines that correspond with this policy apply only to the originating Unit, the Unit responsible for action related to the record(s), and/or the originating employee. Other Units or employees receiving copies of these records should retain such copies only as long as useful, but in no event longer than the record retention guidelines. Where multiple Units are responsible for action related to a single record, those Units should agree as to which will be responsible for record retention. The objective is to minimize the number of copies kept while ensuring that records are retained as required.
Archival Records - University records which are non-current and are not required to be retained in the office in which they originate or are received. These records have permanent or enduring legal, fiscal, research or historical value and, in consequence thereof, should be retained and preserved indefinitely.
Born Digital Records – University records created and maintained in digital format throughout their life span.
Data Classification- See policy AD71, Data Categorization.
Disposable (or Transactional) Records - University records which have temporary value and, in consequence thereof, may be destroyed after the lapse of a specified period of time delineated in Records Retention, Disposition and Destruction Schedules, specified by federal or state law, or after the occurrence of some act which renders them valueless, in accordance with policy.
Electronic Records – Electronic records are created and stored in a wide variety of technologies; for example, email, data (in structured or unstructured formats), web pages and other “born digital” records. Any of these technologies are used to store University records. As such, AD35 applies to all University records that are electronic.
Faculty-Related Records – University records that typically are created, maintained, kept, or stored by University faculty. See the General Retention, Disposition and Destruction Schedule for more information.
Financial Document Retention Schedule - a list indicating the length of time specific financial records must be retained before disposition, as well as the appropriate means of disposition for each series of records.
General Retention, Disposition and Destruction Schedule - a list indicating the length of time general records must be retained before disposition, as well as the appropriate means of disposition for each series of records.
Public Records - publicly distributed information which is available to anyone.
Record Series - any groups of related records which are normally used and filed as a unit and which can be evaluated as a unit for disposition purposes.
Records Management Liaisons (RML)– University employees assigned by the Budget Executive to serve as a conduit for policy, procedure, and information between the University Archives/Records Management Program and their respective administrative area.
Records Management Assistants (RMA)– University employees designated to support the Records Management Liaison with specific responsibility for a unit or units within the administrative area.
Retention Period - the time that must elapse before the records are disposed, stored or archived.
University Records - Information that documents a transaction or regularly conducted activity of the University and that is created, received or retained pursuant to law, University policy, or in connection with a transaction, business, or activity of the University. The term includes documents, papers, letters, books, drawings, maps, plans, photographs, tapes, film or sound recordings, microforms, digital or analog files, information stored or maintained electronically, and data- or image-processed documents.
University records are categorized as follows:
University Confidential Records - records which have the highest level of confidentiality attached to them and which may only be used by a limited number of people at the University.
University Restricted Records - records having a high level of confidentiality attached to them and where access is limited to the staffs of a small number of Units.
University Official Records - records which are available to University faculty or staff members (usually within the Unit), but are not made available to the public. Generally speaking, the bulk of University records fall into this category. Permanent records within this category would be transferred to the University Archives at the end of their life cycle as delineated in the retention schedules.
University Vital Records - Records essential to the continued functioning or reconstitution of the University during and after an emergency, and also those records essential to protecting the rights and interests of the University and the individuals directly affected by its activities. Permanent records within this category would be transferred to the University Archives at the end of their life cycle as delineated in the retention schedules.
Excluded from the definition of University records are three categories of materials:
University library and museum material made or acquired and preserved solely for reference or exhibition purposes, stocks of publications and of processed documents, and extra copies of documents preserved only for convenience of reference;
Faculty Personal Papers that are maintained at the sole discretion of a faculty member for scholarly purposes that shall not contain personally identifiable information; and
Personal papers not related to the official function of a Unit or created in pursuance of non-University activities.
University records in custody of the University Archives will be available for public inspection, copying, and general research use subject to those constraints which may apply by virtue of federal or state law or regulation, University policy or guideline.
Regardless of format, University records have a life span and eventually become inactive in their offices of origin. At that time, it is in the interest of the University for economy, efficiency, history, or administrative necessity to determine and carry out the most appropriate disposition of these records. Records will be either designated as archival records and transferred to the custody of the University Archives, or they will be designated as disposable records and destroyed in a systematic manner as outlined in this policy. Designations are delineated by record series in the Records Retention, Disposition, and Destruction Schedules.
University records in custody of their originating and receiving offices are University property and may not be disposed of except through policy and guidelines established herein. Access to University records still in originating or receiving offices is governed by statute, regulation, or existing University policies and guidelines. Records from offices which are merged in reorganizations should be brought into the new offices carrying out those functions; records from those offices which are phased out should be reviewed by the University Archives/Records Management Program for appropriate action.
RECORDS RETENTION, DISPOSITION AND DESTRUCTION SCHEDULES:
Schedules will be developed for particular categories of records and for the records of a particular office. All general schedules shall be included in the General University Reference Utility (GURU) as part of the General Retention, Disposition and Destruction Schedule. Disposition information for specific financial forms is included as Financial Document Retention Schedule in the General University Reference Utility (GURU).
- Purpose of the Records Retention, Disposition and Destruction Schedule: To provide uniform, effective, and systematic control of record keeping and destruction. Ensures that valuable records are preserved and that records of a temporary nature are properly disposed of when no longer needed.
- Steps in creating schedules: The University Archives/Records Management Program surveys records and drafts retention, disposition, and destruction recommendations; proposed schedules are approved by officials primarily concerned with the records; proposed schedules are then reviewed and approved by the Records Management Advisory Committee, the Office of General Counsel, and the Office of the President.
Units shall annually review the records in their possession and under their operational jurisdiction, and document such review. The regulations defined in this policy must be consulted and followed in determining the retention, disposition and destruction of the records they manage.
The Budget Executive will be responsible for the certification of such a review in his or her administrative area, certifying that the area is in compliance with AD35 to the best of his or her knowledge and belief. To this end, the area's Budget Administrator, Department Head(s), Unit Head(s)and Director/s and/or other administrators, as applicable and as designated by the Budget Executive, will support him/her in the certification process. In fulfilling this process, the Budget Executive will designate one (1) primary RML to oversee such a review for his or her administrative area. There should be a minimum of one primary RML per administrative area. Based on the size of the Unit, an RML has the option to designate additional individuals, hereinafter referred to as Records Management Assistants (RMA), to support the RML.
Documentation of this review will be maintained by the Unit RML as evidence that the review was conducted. The RML can document what records were reviewed through whatever means is most efficient and effective for the administrative area.
Note that records retained on centrally provided servers, such as in Administrative Information Systems (AIS), fall under the responsibility of the Unit that generated, collected, or maintained the records (as opposed to the Unit that manages the centrally provided server).
University vital records shall, in all instances, be transferred to the University Archives, as delineated in the Records Retention, Disposition and Destruction Schedules.
Archival records as designated in the Records Retention, Disposition and Destruction Schedules, must be transferred to the University Archives for permanent preservation; the University Archives/Records Management Program shall designate which records are archival and shall have the authority to examine any and all University records in their offices of origin, subject to possible conditions of national security classification.
Any archival records created more than twenty (20) years prior to the current date must be transferred to the University Archives.
The transfer of archival records from the Unit of origin to the University Archives shall be made at such times and in the manner and form prescribed by the University Archives and subject to the appropriate Records Retention, Disposition and Destruction Schedules.
University records deposited in the University Archives shall be subjected to the following restrictions: "University Confidential" and "University Restricted" records are closed until such time as their status is changed by the Office of the President. "University Official" records are closed to public access until twenty (20) years after their date of creation.
University archival records may be used by any individual, subject to their agreement to abide by archival rules governing access and use.
Requests for exception to access to "University Restricted" and "University Official" records shall be governed by criteria approved by the Office of General Counsel and the Office of the President, and such requests will be handled by the University Archives/Records Management Advisory Committee. Requests for exceptional use of "University Confidential" records will be handled by the Office of the President, or the President's designated representative.
University records may be microfilmed, and/or scanned for storage in optical or other electronic media, for the purpose of reducing storage costs and/or improving access to and manipulability of the data. Documentation of reformatting process and procedures must be maintained.
All significant detail on originals must be included on the new medium. Reformatted reproductions must have the same acceptability and legal status as the original record. The reformatted reproduction must meet archival standards.
Units must provide advance notification to the University Archives/Records Management Program of their intent to reformat records. Such Units must show that space savings and/or improved access to information will result from reformatting, as well as meeting quality and metadata standards. No reformatting shall take place unless an approved Records Retention, Disposition and Destruction Schedule exists which covers the records in question. All notifications of reformatting will be checked against established standards.
Master negatives of microfilmed records which are identified as archival will be transferred to the University Archives for inclusion in the "Vital Records" master negative storage program. Original archival records which have been microfilmed may be destroyed if the use-copies of the microfilm are scheduled for later transfer to the University Archives. Original archival records which are scanned or otherwise converted for digital storage shall be transferred to the Archives unless an Archives-acceptable copy of the information can be provided for Archives storage.
University records which are determined to be disposable may be stored on any medium that ensures the maintenance of the information until its designated disposal point. Units should submit notifications of intent to dispose of non-archival originals. Notices of intent to dispose are also required for reformatted records whenever they are ready for disposal.
No destruction shall take place unless an approved Records Retention, Disposition and Destruction Schedule exists which covers the records in question. Questions about documents not covered should be directed to the University Archives/Records Management Program.
Units may submit notifications of intent to dispose or transfer, or they will be notified on a regular basis of the need to dispose of records; those record series which require disposition will be listed and offices will be required to complete the disposal and notify the University Archives/Records Management Program, indicating the means by which disposal was completed and the amount of material destroyed. Transfer guidelines will be provided by the University Archives/Records Management Program upon request.
The manner of destruction of disposable (or transactional) records will depend on the category of University records destroyed. "University Confidential" or "University Restricted" and any records containing unencrypted or unredacted personally identifiable information must be shredded; "University Official" records should be recycled.
The destruction of records, documents, drafts, and copies will be suspended immediately upon notice that an investigation or litigation is pending, imminent, or reasonably foreseeable. The suspension will be tailored to cover only those records, documents, drafts, and copies relevant to the investigation or litigation.
Retention procedures will be suspended when, in the judgment of the University’s Office of General Counsel, a record or group of records should be placed on a legal hold. A legal hold requires preservation of appropriate records under special circumstances, such as litigation or government investigations. The Office of General Counsel determines and identifies what records and documents are required to be placed under a legal hold.
Members of the University community will be notified if a legal hold is placed on records for which they are responsible. Members of the University community are then required to locate, index, segregate, and protect the necessary hard copy records and records in electronic form, in conjunction with the Office of Information Security and local Information Technology staff, where appropriate. Any record that is relevant to a legal hold must be retained and preserved. If a member of the University community is unsure whether a record is relevant to a legal hold, that member of the University community should protect that record until consultation with the Office of General Counsel.
A legal hold remains effective until it is released in writing by the Office of General Counsel. After the University community receives written notice of the lifting of a legal hold, all records relevant to the legal hold shall return to their normal handling procedures and retention schedules.
Other Policies in this Manual should also be referenced, especially the following:
AD11 - University Policy on Confidentiality of Student Records, and
AD20 - Computer and Network Security,
AD22 - Health Insurance Portability and Accountability Act (HIPAA),
AD23 - Use of Institutional Data,
AD34 - University Recycling Program,
ADG01 - Glossary of Computer Data and System Terminology, and
ADG02 - Computer Facility Security Guideline,
ADG08 - Collection, Storage and Authorized Use of Social Security Numbers (SSNs) and Penn State Identification Numbers,
BS15 - Disposal and Purchase of Obsolete, Surplus or Scrap University-Owned Equipment, Supplies and/or Materials,
FN14 - Use of University Tangible Assets, Equipment, Supplies, and Services,
FN19 - Policy for Handling and Distributing Confidential Internal Audit Reports and Other Documents,
HR60 - Access to Personnel Files,
IP01 - Patents and Copyrights (Intellectual Property), and
General University Reference Utility (GURU) Appendices General Retention, Disposition and Destruction Schedule and Financial Document Retention Schedule
Most Recent Changes:
Revision History (and effective dates):