Records Management and Confidentional Destruction

Date Issued: June, 2001
Date Revised: January, 2003, May 7, 2009

I. Policy

This policy sets forth the guidelines for document access, retention and destruction.

II. Purpose

To provide for the systematic review, retention, and destruction of documents received or created by Luther College in connection with the transaction of organization business. This policy covers all records and documents, regardless of physical form, contains guidelines for how records can be accessed, how long certain documents should be kept, and how records should be destroyed. 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 Luther College’s operations by promoting efficiency and freeing up valuable storage space.

III. Scope

This policy applies to all departments and faculty/staff of Luther College.

IV. Terms and Definitions

• For the purpose of this policy, Archives shall be defined as the Luther College Archives. The Archives is responsible for collecting, preserving and making available the history and development records of Luther College.
• For the purpose of this policy, records shall be defined as all material on which information is recorded or preserved, regardless of form or characteristics, which is created or maintained by any agency, officer, or employee of Luther College in the transaction of its business. This definition refers to all forms of recorded information or other material bearing upon the activities and functions of Luther College, any of its officers, and employees. This definition also includes but is not limited to handwritten, typed, or printed material; publications; photographs; moving images; sound recordings; drawings; and computer or other machine readable data. Not included in the definition of records as used in this policy are: faculty research or lecture notes; library materials; and materials not published by the institution.

V. Procedures and Guidelines

1. Records produced or received by any office or employee of Luther College in the transaction of College business are the property of the institution and subject to institutional policy for retention, disposal, access, and publication, including records produced or received by individuals in administrative and committee service capacities. Upon their completion, records retention schedules will be distributed to all individual employees. These schedules will serve as the formal institutional policy for disposition of all types of records.
2. No College records shall be discarded, destroyed or transferred from the custody of the home institution or otherwise disposed of except upon the prior approval of the Archivist. The decision to select and preserve records of historical value is the responsibility of the Archivist. The Archivist shall withhold the approval for the destruction of records until satisfied that the records involved need not be retained for legal or accounting reasons, as determined by appropriate officers. Approval either to transfer inactive institutional records to the Archives or to destroy them after an agreed upon period may take the form of written records disposition schedules or other written agreements between the Archivists and the administrative officers, department heads, or committee chairs responsible for the custody of these records during their active life.
3. The College Archives, under the direction of the College Archivist, is the depository for non-current institutional records having enduring and significant historical or research value. At least one copy of every publication issued by the College or by any of its agencies should be forwarded to the archives. The Archives also solicits and accepts donations of professional and personal papers of faculty and staff, records of student organizations, and other relevant material.
4. Restrictions on access to records transferred to the Archives may be negotiated by the department or office of transmittal. Reference service provided by the Archives may include searching records to locate specific pieces of information, making copies of particular documents, or making records available for consultation in the Archives. Offices and departments which transfer records to the Archives may request the return of records to the transmitting office if and when subsequent administrative need reveals their transfer to have been premature.
5. Records Management
   • Follow the Records Retention Schedule and destroy appropriate routine materials. Certain classes of records can and should be destroyed routinely three years after their creation. These include (but are not limited to) copies of requisitions, receipts, and travel expense reports; most printed material received from outside the College; and duplicates of memos and reports generated by your office. These types of records can safely be destroyed without consulting the Archivist about possible historical value. Please see the procedures below for information on confidential destruction.
   • Identify materials that become inactive. Most other paper records in an office—reports, correspondence, minutes, and background material—become inactive after 5 to 7 years. Inactive merely means that the material is rarely referred to and hence could conveniently be moved out of your office. This is most easily done if you break your files at regularly scheduled intervals (e.g. annually or every five years). By doing so, not only do folders not become overcrowded, but it is extremely easy to purge inactive material on a regular basis.
   • Transfer appropriate materials to the Archives. Once you have identified materials that should be destroyed and materials that should no longer be stored in your office, you’re ready to call the Archives.
   • Remove materials that are more than 3 years old: requisitions, receipts, travel vouchers, expense reports, peripheral printed material from outside the college and any duplicates of memos and reports generated by your office.
   • Put the contents into chronological order and break the folders at a predetermined date.
   • Label the old folders with inclusive dates before boxing them. If you are still uncertain, please call the Archives and we will come over and survey the files to determine which files warrant permanent preservation. We can even provide you with boxes in which to put those permanent records.
   • Fill the boxes. Please fill the boxes in the same order that the folders exist in the file cabinets.
   • Number the boxes (1 of 3; 2 of 3; 3 of 3).
   • Prepare a typed list, on CD or sent to the archives as an attachment, of folder titles (including beginning and ending dates) in each box. This insures that the Archives can retrieve material for you should you need it in the future.
   • Finally, put in a work order with Facilities Management to get the boxes moved to the College Archives in Preus Library.
   • Records Retention Schedule – See Appendix A.
   • The records retention schedule will be reviewed periodically by the Archivist and the appropriate departments for updates and additions.
6. Access to College Archives
   • The College Archives are operated year round. Public research hours are posted in the library. In addition, access is readily available at other time by appointment. General Rules:
     • Patrons using the collections in the archives must observe all instructions for the use of archival material.
     • Access to restricted records will be limited to authorized individuals only.
     • For the protection of its collections, the Archive reserves the right to restrict the use of materials which are not processed, materials of exceptional value, and fragile materials.
     • Patrons must honor any restrictions placed by donors of private materials.
     • Failure to observe the rules will result in forfeiture of the privilege of using the Archives.
   • External Access
     • Non-Luther College users will have the same access to materials with the exception of college records that have been closed to the public. Access to these materials may be granted with the permission of the Vice President governing those records.
   • Internal Access
     • Records that are protected by law are only accessible to the originating department or by special permission of the President. These include all forms of personnel records.
     • Generally, the records of the College are available to any staff member who needs access in the course of their official duties. Widely distributed documents, such as Faculty Meeting minutes are easily accessible without question. However, in the event a staff person were asking for something that did not fit his or her role in the institution, and it was a document that had confidential content, conference would be made with the originating department. The only records staff can borrow are the ones their office created. Any department may call for records they created. These records can either be duplicated for their continued use, or the original file can be temporarily borrowed or permanently de-accessioned and returned to the department. However, any department needing access to project files they did not create can only view them in person, or pay for duplication. Original files will not be lent out for use to non-originating departments.
7. Luther College Confidential Destruction Policy
   • Confidential materials that have reached the end of their use at the college (according to the records retention schedule distributed by the Luther College Archives) shall be transferred to the archives for destruction.
   • If your records are to be destroyed according to the records schedule, do the following:
     • Make an inventory including the destruction cycle (i.e. the records are held for 7 years and then destroyed). Please specify the types of records and why they are eligible for destruction.
     • Materials may include staples or paper clips, but no binder clips.
     • Please contact the Archives at x1805.
     • Contact Facilities Management to have the records moved.
     • Records will be staged in a secure location at the archives and then sent to Winneshiek County Recycling for confidential destruction at regular intervals.
     • As outlined in the Luther College Records Management Implementation Guide, the decision to destroy or retain college records requires the approval of the College Archivist. The Archivist shall withhold the approval for the destruction of records until satisfied that the records involved need not be retained for legal or accounting reasons, as determined by appropriate officers. Approval either to transfer inactive institutional records to the Archives or to destroy them after an agreed upon period may take the form of written records disposition schedules or other written agreements between the Archivist and the administrative officers, department heads, or committee chairs responsible for the custody of these records during their active life.
8. College Archivist
   • To retrieve something sent over to the Archives, request the file by phone or e-mail and we will either send over a copy or the original (if it is from your office).
   • If your records are to be destroyed according to the records schedule, make an inventory including the destruction cycle (i.e. the records are held for 7 years and then destroyed), then contact the Archives. Records will be staged in a secure location at the archives and then sent to Winneshiek County Recycling for confidential destruction at regular intervals.
   • If you have any questions or comments about the information in this policy, please feel free to call the College Archivist, Rachel Vagts, at x1805.
     VI. Confidentiality and Record

All departments and staff/faculty are responsible for the maintenance of records in accordance to the guidelines and procedures as set forth in this policy.

Appendix A – Record Retention Schedule

KEY:
Permanent = permanent retention, probably in the Archives after 10 years
Active = retain only as long as frequent reference is made to the document
Current = retain only for the current year/period