| Policy Title | Records Management Policy |
| Policy Category | Information Technology |
| Policy Approval Date | February 14, 2024 |
| Policies Superseded | Interim Information Technology Policy, Section EE (Records Retention) |
| Responsible Office(s) | Office of Information Technology and Office of the Provost |
| Related Policies | Data Governance Policy; Information Technology Policy; Litigation Policy |
| Frequency of Review | 5 Years |
| Date of Next Review | February 2029 |
I. Scope
This Records Management Policy (“Policy”) applies to all departments, offices, committees, boards, and employees of Arcadia University (“Data Users”) and the types of Records generated by them and set forth in the Management Schedule referenced below. See Section IV for the definitions of capitalized terms contained in this Policy which are not otherwise defined in the text of this Policy.
II. Policy Statement
The University is committed to an effective Records management program to meet business needs; protect the privacy of faculty, staff, and students; comply with legal standards; optimize the use of space; minimize the cost of retention; and preserve the University’s history. The University requires that different types of University Records be retained for specific periods of time and that outdated Records are destroyed in the proper manner. The purpose of this Policy is to establish the requirements for how Records should be managed, securely retained, and disposed.
III. Policy
This Policy provides for the secure maintenance, retention, and disposition of Records received, created, or maintained by the University in connection with University business. The Policy contains a schedule for how long certain documents should be retained and how they should be disposed of (unless they are under a legal or other similar investigation, or are otherwise subject to a litigation hold). This Policy is designed to enhance compliance with federal and state laws and regulations, to eliminate accidental or innocent destruction of records, to facilitate the University’s operations by promoting efficiency and freeing-up of valuable storage space, and to preserve the history of the University. Therefore, the University shall manage the retention and disposition of Records in the following manner.
A. Maintenance. Access to Records is based on data classifications as set forth in the Data Governance Policy and described in greater detail in the Arcadia University Data Classification and Handling Reference Sheet.
B. Retention. The University will retain Records in accordance with the Records Management Schedule set forth in Appendix A (the “Records Management Schedule”), in compliance with federal, state, and local legal requirements and institutional needs, including maintaining Records of historical value. The Records Management Schedule identifies Records by their purpose or function, designates a University department or office responsible for retaining them, specifies a time period for retention, and references any relevant legal requirements. Records not identified specifically in the Records Management Schedule that are substantially similar to those listed in the Records Management Schedule, or that pertain to a particular transaction or topic documented in the Records Management Schedule, should be retained for the length of time required for the substantially similar Record. Questions regarding the retention period for any Records should be directed to the University Data Stewards.
- Electronic Records. Records include information and Data maintained in an electronic format. Records in an electronic format will be retained as if they were in any other format, including paper, in accordance with the Management Schedule’s requirements. In most cases, electronic Records should be maintained in their electronic form and in their original format, because preserving the context and structure of Records and facilitating access to them are best accomplished in the Record’s original environment. Information technology systems where electronic Records are maintained should be stored in an “archive” computer file folder. Backup and recovery methods will be tested on a regular basis and include adequate system controls, including audit trails, routine testing of system hardware and software, and procedures for measuring the accuracy of Data.
- Records Management. Improper use of any University Data, including Records, can result in risk to the University. In addition, many Records contain confidential information (e.g., dates of birth, Social Security Numbers, and financial aid information). These Records are protected by federal, state and local statutes, including the Family Educational Rights and Privacy Act (FERPA), and the Gramm-Leach-Bliley (GLB) Act. It is essential that the management of confidential Records is consistent with the University’s Data Governance Policy. The Data Governance Policy sets forth the criteria for four classification levels of Data; identifies requirements for accessing, sharing, and storing University Records; and describes the responsibilities of University staff members in safeguarding University Data. All Records must be handled based on the highest classification level of Data contained in the Record, as specified in the Data Governance Policy.
- Archival Records. When the retention period for a Record specified in the Management Schedule has passed, a determination to preserve or dispose of the Record must be made. Appendix B lists criteria to consider when determining if a Record is of historical or permanent value to the University and must be maintained as an Archival Record in Landman Library’s University Archives and Special Collections. Questions regarding the historical value of Records should be directed to the University Data Stewards and the Director of the Landman Library or their designee.
C. Disposition of Records. If a Record has reached the end of its retention period and is not selected as an Archival Record, it must be destroyed according to its data classification level, as set forth in the following table. If in doubt as to the proper method to destroy a Record, shred it.
| Data Classification Level and Risk of Improper Handling | Paper Destruction | Electronic Destruction |
| Level 1 – Improper handling results in severe risk to the institution | Physically destroy the document (e.g., cross-cut shredding, disintegration, incineration, and pulverization). Use of the University’s secured recycling program complies with this destruction requirement | Electronic Media repurposed for University use: The electronic storage device must be wiped with a multiple pass/DoD secure overwrite prior to being repurposed to another unit or area Electronic Media not repurposed for University use: The electronic storage device must be physically destroyed |
| Level 2 – Improper handling results in high risk to the institution | See Level 1 | See Level 1 |
| Level 3 – Improper handling results in moderate risk to the institution | See Level 1 | See Level 1 |
| Level 4 – Improper handling results in low or no risk to the institution | No special requirements, can make use of University office paper recycling, if available | No special requirements |
D. Transition of Records. When leaving a supervisory or administrative position or rotating out of a committee or board chairship, employees must leave all Records which need to be retained according to this Policy with their successor, transfer them to the University Archives if requested by their successor, or in the case of Records containing sensitive or confidential information, transfer them to the Office of General Counsel for review and recommendation as to the appropriate maintenance or disposition of such Records.
E. Litigation Policy. This Policy is subject to the University’s Litigation Policy which specifies the University’s obligation to maintain Records concerning threatened or pending litigation. When a lawsuit is filed or is reasonably anticipated, Record disposition will be suspended immediately and all potentially relevant Records, whether listed on the Records Management Schedule or not, must be preserved and maintained. Records that are subject to a “litigation hold,” as determined by the Office of General Counsel, should not be destroyed or altered even if the retention date has expired, and shall be preserved and retained until such time as the Office of General Counsel specifically authorizes the disposition of the Records.
F. Roles and Responsibilities. All members of the University community are responsible for the retention and disposition of Records in accordance with the guidelines set forth below.
- Data Users are responsible for retaining University Records in their possession in accordance with this Policy, the Data Governance Policy, the Information Technology Policy, the Acceptable Use Policy, and the FERPA Policy, and any other University policies that govern the use of University Data.
- Data Stewards are responsible for:
- Coordinating the creation of and adherence to the Records Management Schedule in conjunction with Data Trustees and the Office of General Counsel.
- Coordinating the creation of Archival Records in conjunction with the Director of the Landman Library.
- Responding to questions about Data handling, Records retention, Archival Records, and Record destruction.
- Communicating information about Data handling, Records retention, Archival Records, and Record destruction to the University’s Data Users.
- Archivist, and/or Director of the Landman Library or their designee(s). The Director of the Landman Library is responsible for coordinating the creation of Guidance on Archival Records (Exhibit B) in conjunction with the Data Stewards, and for responding to questions about Records with potential historical significance.
- Office of General Counsel. The Office of General Counsel is responsible for answering questions related to the application of laws and regulations to this Policy, including the Records Management Schedule.
- Chief Information Officer. The Chief Information Officer is responsible for recommending and establishing policies to support the University’s Data Governance Program as described in the Data Governance Policy, and is responsible for the operation of information technology systems used to store electronic Records.
- Compliance. The University expects all Data Users to comply with this Policy with regard to all University Records regardless of where located and to cooperate with any University request for disclosure of Records subject to this Policy. Failure on the part of employees to follow this Policy can result in possible civil and criminal sanctions against the University and its employees.
- Updates. While this Policy and the Records Management Schedule at Appendix A identify many of the Records at the University, they do not cover all documents or situations and may be updated to reflect best practices or changing legal requirements.
IV. Definitions
Archival Records: Records of historical significance or those that provide important documentation of decisions and events for the University and may include:
- Legal charters and other institutional constituting documents, vital records maintained by a government authority or essential to the continuation of an organization, policy statements, and University related correspondence of the institution’s governing board, administrators, and other campus leaders
- Reports, including budgets, audits, accreditation, internal evaluations, academic and administrative units operations, fundraising, and research
- Records of departments, the institution’s registrar (e.g., class schedules), academic departments, and campus organizations
- Publications (e.g., newsletters, posters, booklets, magazines, bulletins, handbooks)
- Theses and dissertations (after written approval for publication is received from the author/s)
- Documents related to student events, clubs and athletics
- Special format materials (e.g., non-print resources such as photographs, video, audio, maps, oral history interviews)
- Digital and electronic records pertaining to any of the above mentioned items
Data Users: University employees, students, and third-party affiliates authorized to access University Data within the scope of the user’s employment, affiliation with the University, or enrollment as a student.
Data: facts or figures that can be measured, collected, reported on, and analyzed. Data are the raw words, numbers, and facts that are recorded and stored in paper or electronic information systems. When Data are extracted, reported, and/or analyzed, they may become a Record.
Data Stewards: University employees responsible for a designated institutional Data set; these employees define the appropriate use, quality, and management procedures for that Data set.
Data Trustees: University employees with planning and policy-level responsibility for University Data and management responsibility for a designated institutional Data set.
Electronic Media: any device on which electronic Data or Records can be stored, including internal and external hard drives, magnetic tapes, disks, CDs, DVDs, and USD storage devices.
Permanent Records: University records identified as “permanent” on Appendix A or later designated as “permanent” by the Data Stewards together with the Data Trustees and added to the Management Schedule.
Record: any original or copied recorded information of any kind and in any form (including, but not limited to, writings, papers, drawings, graphs, charts, images, prints, photographs, microfilms, audio and video recordings, Data and Data compilations, and electronic media, including email, webpages, databases) created, received, generated, or maintained as evidence and information by University administrative or academic offices in connection with official University business transactions, administrative functions, or in pursuance of legal obligations regardless of whether located on University property or elsewhere. University Records are the property of the University and not of the individuals who create them or to whom they are entrusted.
University: Arcadia University, its colleges, schools, affiliates, divisions, and subsidiaries.
V. Effective Date
This policy is effective on the date that it is signed by the President of the University.
VI. Signature, Titles, and Date of Approval
Signed: /s/ Ajay Nair
Ajay Nair, President
Date: February 14, 2024
Appendix A
Records Management Schedule
The Records Management Schedule is available here. Note: No document list can be exhaustive. Questions regarding the retention period for documents not identified in the Records Management Schedule should be directed to the University Data Stewards.
Appendix B
Guidance on Identifying Archival Records
Arcadia University’s Landman Library’s University Archives and Special Collections (“University Archives”) collects, organizes, preserves and manages materials of historical, cultural and administrative value to the Beaver College and Arcadia University Community. The University Archives provide primary resources about the University’s history through University publications, formal records and publications, photographs, and artifacts.
Records of historical value or significance to Arcadia University are of long-term value. These Records document significant events for the University. Their value may be derived from their age and/or association with a significant event or person associated with Beaver College or Arcadia University. Records of historical value may be new or relatively new; there is no minimum age.
Some of the Records that the University creates and/or collects each year have long-term historical value, and those that do provide important documentation of decisions and events for the institution. The University Archives accepts Records and other items of significance based on its mission and the Records’ long-term value.
Records of historical significance or those that provide important documentation of decisions and events for the University are known as “Archival Records” and may include:
- Legal charters and other institutional constituting documents, vital records maintained by a government authority or essential to the continuation of an organization, policy statements, and University related correspondence of the institution’s governing board, administrators, and other campus leaders
- Reports, including budgets, audits, accreditation, internal evaluations, academic and administrative units operations, fundraising, and research
- Records of departments, the institution’s registrar (e.g., class schedules), academic departments, and campus organizations
- Publications (e.g., newsletters, posters, booklets, magazines, bulletins, handbooks)
- Theses and dissertations (after written approval for publication is received from the author/s)
- Documents related to student events, clubs and athletics
- Special format materials (e.g., non-print resources such as photographs, video, audio, maps, oral history interviews)
- Digital and electronic records pertaining to any of the above mentioned items
Questions regarding Archival Records that have reached the end of their retention period should be directed to the University Data Stewards, the Archivist and/or the Director of the Landman Library, or their designee(s).
