Document Retention and Destruction Policy

I. Scope

This policy applies to all operating units within IWU and applies to all physical and electronic records identified in Appendix A that are generated in the course of IWU operations.

II. Policy Statement

This policy provides for the systematic review, retention and destruction of documents received or created by Indiana Wesleyan University in connection with the transaction of institutional business. This policy covers all records and documents, regardless of physical form (including electronic documents), contains guidelines for how long certain documents should be kept and how records should be destroyed.

III. Reason for the Policy

The policy is designed to ensure compliance with federal and state laws and regulations, to eliminate accidental or innocent destruction of records and to facilitate IWU’s operations by promoting efficiency and freeing up valuable storage space.

IV. Procedures

1. Document Retention and Destruction Schedule

   Attached as Appendix A is a Document Retention and Destruction Schedule that IWU approved as the initial maintenance, retention and disposal schedule for physical records and the retention and disposal of electronic records. The Vice President for Business Affairs (“Administrator”) is the officer in charge of the administration of this policy and the implementation of processes and procedures to ensure that the Document Retention and Destruction Schedule is followed. The Administrator is also authorized to:

   • make modifications to the Document Retention Schedule from time to time to ensure that it is in compliance with local, state and federal laws and includes the appropriate document and record categories for the University;
   • monitor local, state and federal laws affecting record retention;
   • annually review the record retention and disposal program; and
   • monitor compliance with this Policy.
2. Electronic Documents and Records

   Electronic Mail: Not all email needs to be retained. Length of retention depends on the subject matter.

   Staff shall retain all business related emails by saving/transferring those items to archived folders no later than every six (6) months. If email chains are to be retained, only the last communication in the chain should be saved/transferred to the archive file. Business emails that should be retained include those involving completed and ongoing transactions and matters within the scope of the employee’s job responsibility. Questions regarding emails to be retained should be directed to the employee’s supervisor. Files attached to emails should be separately retained in accordance with document retention provisions of the category of this policy applicable to the document.

   Emails not saved/transferred to archived folders such as personal emails, spam and duplicative emails should be deleted no later than every six (6) months.

   Employees shall not store or transfer IWU related email on non-work-related computers except as necessary or appropriate for legitimate business purposes as authorized by the applicable Vice President.

   Electronic Records (including Microsoft Office Suite and PDF files): The length of retention depends on the subject matter of the record and these electronic records shall be retained in accordance with the periods applicable to the subject matter of the record.

   In certain cases a record will be maintained in both paper and electronic form. In such cases, the official record will be the electronic record.

3. Responsibilities

   Departments and units that maintain University records are official repositories. These administrative units are responsible for establishing appropriate record retention management practices in compliance with this policy. Each department manager must:

   • Implement record-management practices in accordance with this policy;
   • Preserve inactive records of historic value and transfer those records to the University archives;
   • Ensure that access to confidential files is restricted; and
   • Destroy inactive records that have no archival value upon passage of the applicable retention period. When the prescribed retention period has passed, a determination of whether to preserve or dispose of the records must be made. To decide if the record is of historic value to the University, consult the University archivist, who has the authority to designate which records are archival.
4. Disposal of Records

   Records that are to be disposed of in accordance with the policy shall be handled in one of the following ways:

   • non-confidential paper records recycled;
   • confidential records shredded or otherwise rendered unreadable;
   • electronically stored data erased or destroyed.

   Note: No record list can be exhaustive. Questions regarding the retention period for any specific record or class of records not included in these tables should be addressed to the Administrator.

   Caution: Departments and units that are not official repositories and retain duplicate or multiple copies of these University records should dispose of them when they are no longer useful.

5. Suspension of Record Disposal

   Document destruction will be suspended immediately upon any indication of an official investigation or when a lawsuit is filed or appears imminent. Destruction will be reinstated under the direction of the Office of Risk Management and Legal Affairs upon conclusion of the investigation.

6. Ownership of University Records

   University records are property of Indiana Wesleyan University. No employee has any right in or to such records, nor shall any employee remove, limit access to, or destroy such records except in accordance with applicable University policy.

Appendix A

Document Retention and Destruction Schedule