Saint Joseph s University Records Retention Schedule NATURE OF 1. Institutional 1.1. Board Documents Office of the General Counsel 1.2. Charter, Amendments and Related Office of the General Documents Counsel 1.3. Institutional Policies and Manuals Planning Office 1.4. Mission Statement/Strategic Plans Planning Office 1.5. Organizational Charts Institutional Research 2. Public Communications 2.1. Institution Publications External Affairs 2.2. Marketing Publications External Affairs Ten years 2.3. Press Releases External Affairs 3. Financial 3.1. Accounts Payable Records Financial Affairs Current plus seven years 3.2. Audit Reports (Internal and Financial Affairs External) 3.3. Bank Statements and Cancelled Financial Affairs Current plus seven years Checks 3.4. Books of Account Financial Affairs Current plus seven years 3.5. Budget Financial Affairs 3.6. Financial Statements Financial Affairs 3.7. Form 990 Financial Affairs Three years following last date for filing 3.8. Payroll Documents Financial Affairs Current plus seven years 3.9. Records Supporting Items of Income, Deductions and Credits Financial Affairs Current plus seven years 3.10. Tax Returns Financial Affairs Current plus seven years 4. Foundation Documents/Development 4.1. Annual Donor Reports Development and 4.1.1 President s Report 4.1.2 Donor Honor Roll 4.2. Annual Gift Income Reports Financial Affairs 4.3. Individual Donor Giving History Development and Files 1
4.4. Donor Agreement Files 4.4.1 Endowments 4.4.2 Gift Agreements 4.4.3 Pledge Agreements 4.4.4 Trusts and Bequests Under Wills 4.5. Contact Information 4.5.1 Alumni Development and Development and 4.5.2 Non-Alumni 4.6. External Voluntary Report Files Development and 7 years 10 years from date of completion 5. Legal 5.1. Contracts and Related Correspondence Financial Affairs Five years after expiration of contract (See, e.g., 42 Pa. C.S. 5525) 5.2. Litigation Files General Counsel Ten years after termination of litigation 6. Intellectual Property 6.1. Copyright Records General Counsel 6.2. Patent Records General Counsel 7. Purchasing 7.1. Evidence of Payment Financial Affairs Current plus seven years 7.2. Invoices Financial Affairs Current plus seven years 7.3. Purchase Orders Financial Affairs Current plus seven years 8. Real Estate 8.1. Deeds Financial Affairs 8.2. Leases Financial Affairs Five years after termination of lease 9. Construction Documents 9.1. Building Plans, Blueprints and Design Plans Facilities Management (Director of FM) 9.2. Engineering Studies and Reports Facilities Management (Director of FM) 9.3. Licenses and Permits Facilities Management (Director of FM) 2
10. Risk Management/Insurance Records 10.1. Incident Reports 10.1.1. Public Safety Reports 10.1.2. Student Life Reports 10.1.3. Student Health Services Reports Public Safety and Security Public Safety and Security Student Life Student Health 3 Five years or until claimant turns 21 years of age, whichever is later 10.2. Insurance Policies Financial Affairs Ten years after expiration 11. Student Services 11.1. Admissions Documents (Admitted Students) Enrollment Management Five years from graduation or last date of attendance 11.2. Admissions Documents (Rejected Students) Enrollment Management Three years from notification of rejection 11.3. Drop/Add/Withdrawal Forms Registrar Five years from graduation or last day of attendance 11.4. FERPA Disclosure Records 11.4.1. Academic Records Registrar To be kept for the life of the student record file (34 C.F.R. 99.32) 11.5. Foreign Student Records (F-1 and M-1 Visas) International Programs One year following notification to INS that student is not pursuing full course of study or three years after student s last day of attendance, whichever is later (8 C.F.R. 214.3(g)) 11.6. Grade Change and Challenge Files Registrar 11.7. Program Advisor Files Deans 11.8. Student Health Records Student Health Seven years from graduation or expected graduation if student leaves the institution 11.9. Suspension/Reinstatement Letters 11.9.1. Academic Letters 11.9.2. Disciplinary Letters Deans Five years from graduation or end of semester last attended 11.10. Transcripts Registrar 11.11. Transcripts (from Other Postsecondary Institutions) Enrollment Management Five years from graduation or end of semester last attended 11.12. Transcript Request Forms Registrar One year 11.13. Veterans Records (Education Benefits) Student Support Services Three years from graduation or end of semester last attended 11.14. Student Discipline Records Student Life Seven years from graduation or seven years from the end of semester last attended 11.14.1 Student Organizations, including but not limited to athletic teams, Discipline Records Student Life Seven years from the end of the semester during which the conduct was reported
11.15. Student Counseling Records Counseling Center During the summer, seven years after the last date that service was rendered 12. Academic Affairs 12.1. Academic Actions, Sanctions and Appeals Registrar for student dismissals; Five years from graduation or last date of attendance for all others 12.2. Academic Program Audit Materials Institutional Research Eleven years (See, e.g., 22 Pa. Code 31.51) 12.3. Accreditation Documents Institutional Research 12.4. Articulation Agreements Provost Five years from expiration of agreement 12.5. Master Calendar Registrar 13. Financial Aid Records 13.1. HEA, Title IV Programs Financial Assistance NOTE: If any Title IV loan, claim or expenditure is questioned by a Title IV program audit, program review, investigation or other review, the records must be maintained for the longer of the Required Retention period identified below or until the expenditure issue is resolved with the U.S. Department of Education. (34 C.F.R. 668.24(e)(3)) Detailed instructions regarding the documents to be retained are set forth in 34 C.F.R. 668.24, as well as two publications issued by the U.S. Department of Education: The Blue Book and the Federal Student Aid Handbook. 4
a. Federal Family Education Loan Program and Direct Loan Program Financial Assistance Records relating to a student or parent borrower s eligibility and participation for three years after the award year during which the student last attended the University (34 C.F.R. 668.24(e)(2)(i)) Other records relating to University s participation in the FFEL or Direct Loan Program, including records of any other reports or forms, for three years after the award year in which the records are submitted (34 C.F.R. 668.24(e)(2)(ii)) b. Federal Work Study Financial Affairs Records relating to administration of program for three years after submission of the Fiscal Operations Report for the award year (34 C.F.R. 668.24(e)) c. Pell Grant Financial Assistance Records relating to administration of program for three years after the award year (34 C.F.R. 668.24(e)) 5
d. Perkins Loan Program Financial Assistance Records relating to administration of program for three years after the award year (34 C.F.R. 668.24(e)) Disbursement and electronic authentication and signature records for each loan made using a Master Promissory Note for three years from the date the loan is canceled, repaid or otherwise satisfied (674.19(e)(3)(i)) e. Supplemental Educational Opportunity Grant Program 14. Personnel 14.1. Employment Records (including application, resume, appointment/salary letters and forms, contracts if any, performance evaluations, requests for accommodation, etc.) 14.2. Faculty Promotion, Tenure and Salary Increase Records Financial Assistance Human Resources Provost/Institutional Research Repayment records, including cancellation and deferment requests, for three years from the date on which a loan is assigned to the Secretary, canceled or repaid (674.19(e)(3)(ii)) Records relating to administration of program for three years after submission of the Fiscal Operations Report for the award year (34 C.F.R. 668.24(e)) Six years after last date of employment (See, e.g., 29 C.F.R. 516.5 and 516.6; 29 C.F.R. 1602.14 and 1602.49; 29 C.F.R. 1620.32; 29 C.F.R. 1627.3) Ten years after last date of employment 14.3. FMLA and ADA Records Human Resources Six years note that regulations identify documents that must be maintained for retention period 14.4. Higher Education Staff Information Report (EEO-6) (See, e.g., 29 C.F.R. 825.500) Human Resources Three years from filing date (29 C.F.R. 1602.50) 6
14.5. I-9 Forms Human Resources Three years after date of hire or one year after last date of employment, whichever is later (8 C.F.R. 274a(b)(2)(i)) 14.6. Pennsylvania New Hire Report Human Resources Three years from filing date 14.7. Recruitment Records a) Applicants who are not hired Human Resources a) Three years from date of rejection or creation of record, whichever is later b) Applicants who are hired 14.8. Background Check Information a) Applicants who are not hired Human Resources b) Three years from date of hire a) Three years from date of rejection b) Applicants who are hired 15. Diversity and Equity 15.1. Records Relating to Student Complaints of Alleged Discrimination (e.g. Title IX, Title VI, Rehabilitation Act, ADA, etc.) 15.2. Records of Title IX Self-Evaluation Vice President for Student Life Vice President for Modifications and Remedial Steps Student Life 15.3. Training Office of Training & Organization Development/Office of Institutional Diversity/Office of Human Resources 15.4. Affirmative Action Plans AAO/EEO Human Resources Three Years 16. Safety and Security Records 16.1. Documents Underlying and Required to Substantiate Pennsylvania Uniform Crime Reports Public Safety and Security (Director of PS) 16.2. Documents Underlying and Required to Substantiate Federal Campus Crime Reports 16.3. Documents Underlying and Required to Substantiate Fire Safety Report Public Safety and Security (Director of PS) Public Safety and Security (Director of PS) b) Three years after date of hire or one year after last date of employment, whichever is later Three years after resolution Three years after self-evaluation (34 C.F.R. 106.3(d)) Five years after training session Four years (See, e.g., 18 P.S. 20.101, et seq., and 22 Pa. Code 33.111) Four years (See, e.g., 20 U.S.C. 1092(f)(1)(F)) Two years (See, e.g., 20 U.S.C. 1092(i)) 7
17. Environmental Health and Safety Records 17.1. Remediation Reports, Permits, Training Records Environmental Health & Safety Director 18. Athletics 18.1. NCAA Eligibility Athletics Department 18.2. Squad Lists Athletics Department 18.3. Academic Progress Rates Athletics Department 18.4. Graduation Rates Athletics Department 18.5. Season Ticket Records Athletics Department 18.6. Game Settlement Reports Athletics Department 18.7. Press Releases Athletics Department Assistant Athletic Director-Athletic Communications 18.8. Publications Athletics Department Assistant Athletic Director-Athletic Communications 18.9. Financial Audits: NCAA, and EADA Athletics Department 18.10. Contracts: Games/Events, Facility Leases, Marketing Agreements Athletics Department 18.11. Compliance Records and Reporting of Athletics Department Violations 18.12. NCAA Student-Athlete Statements and Athletics Department Forms 18.13. HIPAA and FERPA Athletics Department Director of Sports Medicine 18.14. Student-Athlete Discipline Records Athletics Department Director of Athletics 8 (according to contract or permits) Ten years from graduation or last date of attendance Ten years from graduation or last date of attendance Ten years from graduation or last date of attendance Ten years from graduation or last date of attendance 5 years 5 years 10 years 6 years 10 years 10 years Life of Student Records (FERPA) (HIPAA) 7 years from graduation 5 years
18.15. NCAA Certification/Accreditation Athletics Department Director of Athletics 18.16. Student-Athlete Medical and Insurance Athletics Department Records Director of Sports Medicine 18.17. Insurance Policies Athletics Department 18.18. Drug Testing Consent Forms Athletics Department Director of Sports 18.19 Employee Training and Discipline Records Medicine Athletics Department 18.20. Student-Athlete Rosters Athletics Department 19. Student Educational Support Services 19.1 Student Disability Records Office of Students with Disabilities 20. Transportation Policy Records 20.1 Campus Transportation Records Public Safety and Security 10 years from the date of the past self study 7 years from graduation or expected graduation 10 years 6 years after last date of training 5 years following graduation, withdraw, transfer 4 years 9