Overview
This policy is intended to ensure that the College complies with appropriate legal requirements for documentation of its activities, has access to the documents required for business purposes, and identifies documents whose retention is not required.
Definition of Retention:
For the purposes of this policy, documents are considered to be retained if they meet the following criteria:
- Financial information is considered retained if it is contained in the accounting system, payroll system and appropriate folder on the server or in paper files.
- Corporate information is considered retained if it is placed, in paper form, in the corporate files maintained in the Clerk’s office or in electronic files on its server.
- Employment information is considered retained if it is contained in the College’s human resources database, its payroll system and electronic files on its server or in its paper files.
- Student records are considered retained if they are contained in electronic format on the server or, in the case of transcripts or other permanent records of students’ academic histories, in paper files.
This policy assumes that the College continues its practice of regular, off-site back-ups of electronic files. If this practice changes the College should revisit the definition of retention.
Documents maintained in either e-mail or voicemail format are not considered retained for the purposes of this policy. E-mail documents should be converted to another electronic format, or printed; voicemails should be transcribed.
Litigation:
In the event any documents retained under this policy become material, or potentially material, to litigation filed by or against the College, the retention limits for these documents are suspended. Any such documents must be retained until the appeal periods for litigation have passed, or as specified in any settlement agreement or court order. This includes circumstances under which litigation has not yet been filed, but which might be reasonably expected by the College. The determination of the applicability of this section rests with the president or his or her designee in consultation, if necessary, with counsel.
Destruction of Documents:
Documents that are not designated for retention under this policy may be discarded by the College staff at their convenience; but any such documents that become material, or potentially material, to litigation filed by or against the College must be retained until the appeal periods for litigation have passes or as specified in any settlement agreement or court order. The officers having charge of human resources, information technology, and finance will develop a protocol for an annual review of documents held by the College and designate (subject to the approval of the president or his or her designee) documents to be discarded.
| Type of Document | Retention Period |
| FINANCIAL RECORDS | |
| Accounts receivable, payable ledgers, schedules. (This requirement is satisfied by retention of monthly AR schedule, and by electronic back-up of accounting system). | 7 years |
| Audit reports, Financial Statements (year end): general ledgers, trial balance, journal entries. (This requirement is satisfied by retention of annual audits and schedules prepared for the audit, as well as back-up of accounting system in a format that allows reconstruction of all transactions and journal entries) | Permanently |
| Bank statements, deposit records, electronic fund transfer documents, canceled checks, bank reconciliations, and voided checks. This includes investment accounts. | 7 years |
| Chart of accounts. (This requirement is satisfied by electronic back-up of accounting system). | Permanently |
| Checks (for important payments & purchases) | Permanently |
| Contracts, mortgages, notes and leases | 7 years following the expiration of the contract. |
| Correspondence (with customers and vendors, including grantors). This applies to correspondence that sets or amends terms and conditions but does not apply routine correspondence generated in the course of receiving or providing the service. | 2 years |
| Donations | 7 years |
| Deeds, mortgages, and bills of sale for capital equipment. Sales of used computer equipment to staff and other organizations for amounts under $500 are not included. | Permanently |
| Depreciation schedules | Permanently |
| Expenses Analyses/expense distribution schedules. (This requirement is satisfied by electronic back-up of accounting system). | 7 years |
| Grants and related correspondence (foundations and grantors). This includes proposals for funding, grant letters, amendments to grants, and progress reports. | 7 years after closure of grant. |
| Invoices (to customers, from vendors) | 7 years |
| Loan documents and notes | Permanently |
| Tax returns and worksheets | Permanently |
| CORPORATE RECORDS | |
| Correspondence (legal and audit) | Permanently |
| Articles of Incorporation, charter, bylaws, minutes and other incorporation records | Permanently |
| Insurance Policies (expired) | 3 years |
| Insurance records, current accident reports, claims, policies, etc. | Permanently |
| Trademarks, patents and related papers | Permanently |
| EMPLOYMENT AND PAYROLL | |
| Employment records. This includes documents related to hires, rehires, tests, evaluations, promotions, transfers, demotions, selection for training, layoff, recall, termination or discharge. This specifically includes requests for reasonable accommodation under the ADA, and the disposition of such requests. |
3 years following the last date of the employee’s employment |
| I-9 Forms | 3 years after date of hire or 1 year after termination |
| EEOC reports | Permanently |
| Records of job-related injuries and illnesses, specifically, logs with dates and summaries and details of accidents. | 5 years |
| Garnishments | 7 years |
| Payroll records & summaries including records related to employee’s leave, sufficient to document compliance with the Family and Medical Leave Act. | 7 years |
| Personnel files (terminated employees) | 3 years after termination |
| Retirement and pension records including Summary Plan Descriptions (ERISA) | Permanently |
| Timesheets | 7 years |
| Withholding tax statements (FICA, FUTA, Federal Income) This is satisfied by retaining IRS Form 941, and its state equivalents. | 7 years |
| Workers compensation documentation | 10 years |
| Job Applications | 2 Years |
| ACADEMIC AND STUDENT RECORDS | |
| Accreditation documents, including self-study and external evaluative report | Permanently |
| Accreditation documents, other | 5 years after submission of self-study |
| administrative records, including faculty schedules, student assignments, course assignments | 1 year after academic year ends |
| Student complaint files (exclusive of discrimination claims) | 4 years after closure |
| Student application records (matriculated students) | 5 years after graduation or last course taken |
| Student application records (non-matriculated students) | 1 year after receipt |
| Course catalogs, brochures | Permanently |
| Transcripts | Permanently |
| Student accommodations (ADA) | 5 years after graduation or last attendance |
| Instructor’s grade reports, related records, course records | 2 years after completion of course |
| Internship records, assessments | 5 years after graduation or last attendance |
| Advisor’s notes/records | 1 year after graduation or last attendance |
| Academic actions (dismissals, change of status, etc.) | 5 years after graduation or last attendance |
| Student disciplinary records | 5 years after graduation or last attendance |
| Commencement programs, graduation lists | Permanently |
| International students: immigration records | 5 years after graduation or last attendance |
| FERPA requests and disclosures | Life of requested record |
If you have any questions, please contact the WJC Support Team by either emailing Support@williamjames.edu, calling 617-327-6777 ext. 1600, or visiting the IT Office on the ground floor.
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