Records Management and Retention Policy
Lackawanna College requires that different types of records be retained for specific periods of time, and has designated official repositories and custodians for their maintenance. These records must be managed according to procedures that are outlined in this document. The College is committed to effective records retention to preserve its history, meet legal standards, optimize the use of space, and minimize the cost of record retention.
This Policy sets forth procedures to manage the retention and disposal of these Records, and is intended to ensure that the College:
- meets legal standards;
- properly manages the use of electronic and physical storage space;
- preserves the history of the College;
- disposes outdated Records.
No one person or unit can be directly responsible for all College Records. Therefore, every office or department managing College records is responsible for:
- Implementing records management practices consistent with this Policy.
- Educating staff in the Records management practices.
- Preserving Records as required under this Policy.
- Properly disposing of Inactive Records at the end of the applicable retention period.
- Protecting Records against misuse, misplacement, damage, destruction, or theft.
- Monitoring compliance with this Policy.
College Records are the property of the College and not of the officers, faculty members, or employees who create them or to whom they are entrusted.
This policy applies to all records and documents, including both original documents and reproductions generated in the course of the College’s operations. It applies to records stored electronically and on microform as well as paper records. Duplicate or multiple copies of records retained in locations other than official repositories must be disposed of in compliance with the College Record Retention Schedule.
Record: A record is anything containing information reflecting College educational and business transactions regardless of format (paper, digital, photographic, recordings, etc.). Typical records include official publications, fiscal data, incoming/outgoing correspondence including email, meeting minutes, reports, and student files.
“Archival records” – An original record that is inactive, not required to be retained in the office in which it originated or was received, and has permanent or historic value.
“Documents” or “Records” – when used in this policy, includes any original documents or reproductions created, received, or maintained by College departments, divisions, offices, and employees of the College in connection with College business, regardless of physical form (hard copy or electronic form, including email). Electronic documents will be retained as if they were paper documents. E-mail messages and/or other electronic files that need to be retained under this policy should be stored in their native file formats .
“Inactive Records”-Records no longer required to carry out the administrative or operational functions for which they were created, but must be kept for administrative, fiscal, legal, or historical purposes in accordance with approved records retention schedule.mu be kept for administrative, fiscal, legal, or historical purposes
“Official Repository” – the unit originating a record or receiving an original record from an external party is designated as having responsibility for retention and timely destruction of original records and documents as indicated on the College Record Retention Schedule. Such responsibility is assigned to the administrative director/academic dean or his/her designee.
A: Document Retention
Each department within the Lackawanna College organization has different requirements for the retention of documents. All offices strictly adhere to the rules and regulations of their governing body regarding their specific area. I.e. Business Office follows the guidelines of the IRS and local, state and federal guidelines. Grant Support Services follows the dictates of each grant obtained, etc. Each department will be required to have on file, the rules and regulations that fulfill the specific criteria that are required for the retention of documents for their area.The College will retain documents in accordance with the College Record Retention Schedule.
B: Disaster Planning and Preparedness
Lackawanna College records will be stored in a safe, secure, and accessible manner. Documents and financial files that are essential to keeping the College operating in an emergency are to be duplicated and backed-up on a regular schedule.
C: Document Destruction
All paper documents that do not include sensitive material are discarded to be recycled. All paper documents that have sensitive material included, i.e. social security numbers, credit card numbers, etc. are shredded on-site under the supervision of a College representative. Any record, paper or electronic, containing cardholder data (CHD) must have the CHD portion immediately destroyed after the data has been used to authorize the payment. Upon removal of the CHD from the record, the remainder of the document must be retained in accordance with the College Record Retention Schedule. Documentation is then received to validate that the documents have been shredded correctly. Document shredding occurs twice a year and is overseen by the Director of Facilities for the College.
D: Litigation Hold
Departments and office must ensure that they not destroy College records that are currently part of, or are likely to be a part of, any legal action or proceeding, litigation, audit, investigation, or review, even if the records retention schedules or other policies or procedures indicate that the records are eligible for destruction. Documents that are subject to a “litigation hold” as determined by General Counsel shall be preserved and retained until such time as General Counsel specifically authorizes the documents to be disposed.
E: Duties of Administrative Manager/Dean or designee
The Administrative Manager/Dean or his/her designee for a College department or division will be responsible for the following: serving as the “official repository” for original records, implementing the department or division’s record management practices for both original and reproduced documents, ensuring that the record management practices are consistent with this policy, preserving inactive records of historic value and transferring those records to the College archives, and destroying inactive records that have no archival value upon passage of the applicable retention period.
Failure on the part of employees to follow this policy can result in possible civil and criminal sanctions against the College and its employees. Failure on the part of employees to follow this policy may result in disciplinary action.
G: Policy Review
This policy and the record retention schedule will be reviewed annually for the purpose of making any necessary revisions in light of technological developments, changes in legal requirements, or changes in administrative practice.
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