Policies Westmont Records Management Policy

Policy Statement

The College is committed to effective record management to preserve its history, meet legal standards, optimize the use of space, minimize the cost of record retention, and ensure that outdated and useless records are destroyed. To that end, the College enacts this policy for the management of active and inactive departmental records.1

Procedure

Departments that maintain college records have established appropriate record retention management practices that are outlined in this policy. Each department:

  • Implements the department's record management practices
  • Ensures that the practices are consistent with applicable law
  • Educates staff on appropriate records management
  • Ensures access to confidential records is restricted

When the record's retention period has passed each department makes a determination of whether to preserve or dispose of the documents.

  • Preservation: Transfer inactive records of historic value to the college archivist2 
  • Destruction: Destroy inactive records that have passed their retention period and have no archival value
    • Where destruction of records is appropriate:
      • Non-confidential records: recycle using bins in respective offices
      • Confidential records: shred; or discard for shredding by college's confidential document destruction service
      • Electronic: Purge electronic records from local drives and server
Records Schedule

The following table, while not exhaustive, represents the retention and destruction schedule for record of administrative departments. Record retention periods may be increased by government regulation, judicial or administrative consent order, private or governmental contract, pending litigation or audit requirements. Such modifications supersede the requirements listed in this policy. Suspension of record destruction required for any of these reasons will be accomplished by a notice sent out to affected department and/or individual personnel by College Counsel. 

Office
Record Type
Storage Location
Duration
Academic Dean
  • Faculty Contracts
  • Candidate applications
  • Promotion & Review Evaluations
  • Academic Dean's Office cabinet files
  • 3 years applications
  • 3 years Promotion and Review Evaluations indefinitely
Admissions
  • Denied & Incomplete Applications
  • Supporting material for confirmed and/or enrolled students
  • Office of Admissions cabinet and electronic files
  • 1 year cabinet file storage retained electronic retention for indefinite period thereafter
Advancement (OCA)
  • Prospect and donor contact reports
  • Gift backup
  • Pledge agreements
  • Correspondence
  • Research
  • Endowment reports
  • Trustee giving reports
  • Credit card receipts (merchant copy)
  • Voided checks for recurring EFT transactions
  • Matching gifts forms
  • Gift in kind forms
  • Grant agreements/contracts
  • OCA cabinet files located in "Great Room" and electronic files
  • Credit card receipts 2 years
  • All other documents retained indefinitely
Accessibility Resources Office (ARO)
  • Student Advising Records
  • Student Accessibility Resources records
  • Accessibility Resources Office cabinet and electronic files
  • 5 years all records
Business
  • Invoices
  • Notes Receivable
  • Investment Records
  • Account Statements
  • Business office electronic files
  • 7+ years
Finance
  • Contracts for sale/purchase of land
  • Housing agreements
  • Wills & Trusts
  • Campus Storage - Kerrwood Hall Basement
  • Business Office Safes
  • 6 years
  • 10 years
Human ResourcesSee Separate Schedule Attached  
Payroll
  • Time cards
  • Witholding Forms
  • Schedule of pay
  • Deductions
  • Levy Notices
  • Paid Time Off Reports
  • Tax Records
  • All records kept in the Business Office
  • 7 years all records
Procurement
  • Service provider contracts
  • Purchase agreements
  • Office of procurement cabinet and electronic files
  • 7 years all records
Registrar
  • Transcripts
  • Student Schedules
  • Subpoena for student records
  • Electronic PDF storage
  • Permanent retention
Student Life
  • Discipline records
  • Consent to release records
  • All records stored electronically in Advocate system
  • 5 years
  • 1 year

Records Requests

  • Internal Requests
    • Internal requests for inspection, review and/or copy of college records can be made to the office where the records are maintained. Generally, the law provides the college with a reasonable amount of time to comply with student and employee requests to access their personnel or educational record. Employees may request to inspect their own files by appointment with the office of Human Resources; and will be provided copies of any documents bearing their signature within a reasonable time upon request.
    • Students may request to inspect and review their educational record by contacting the Office for Student Life. In accordance with federal law, multi-student recordswill require redaction in order to protect the privacy of the non-requesting student(s).
    • Inter-office requests for records of other types for legally appropriate and legitimate business purposes is determined in accordance with regular practice.
  • External Requests
    • External requests for inspection, review and/or copy of college records should be directed to College Counsel.

Policy Review

The college will review this policy periodically to ensure its consistency with applicable law and make modifications where appropriate. For questions regarding records covered under this policy, contact the department responsible for maintaining the records in question. For questions about the policy, contact College Counsel, Toya Cooper, at extension 6832 or by email at tcooper@westmont.edu

 Human Resources Document Retention Schedule

Record Type
Duration
Destruction Date
Employee Files3 yrsKept even after termination
Reference letters3 yrsKept even after termination
Offers3 yrsKept even after termination
Applications3 yrsKept even after termination
Performance Reviews3 yrsKept even after termination
Changes in pay, title, etc.3 yrsKept even after termination
Interview records3 yrsKept even after termination
Applicant information on those not hired2 yrs2 years
Legal filesUntil final disposition of caseNot destroyed
First Aid and Worker's Comp claims5 yrs after date of injuryhave paper files back to 1978
Pre employment physical results1 yearEvery 2 years
Asbestos exposure results30 yrskeep indefinitely
Respirator testing30 yrskeep indefinitely
OSHA log5 yrskeep indefinitely
Classified ads2 yrs(have stored electronically back to 2001)
I-9 forms3 years after hire date or 1 year after termination, whichever is laterRecords examined and purged as required
Immigration files1 year beyond the last date an H-1B is employedNot destroyed
FMLA/SDI files3 years, if no claim is pending(have paper files back to 1992)
Insurance bills6 yearsEvery 6 years
Retirement plans contracts1 year from termination of planNot destroyed
Background checks not kept at Westmont College-database w/ vendor only5 yrs(saved electronically by vendors)
Unemployment claims 3 yrsindefinitely
Temporary agency contracts1 yr2 yrs
Benefits bills6 yrs6 yrs
Plan descriptionsduration of plan and 1 yr after termination of planindefinitely
Contracts1 yr after termination of planindefinitely
COBRAindefinitelyindefinitely
HIPAA docs6 yrs6 yrs

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1A record is the original or copy of any writing, sound or video recording, in any format, generated and/or received by a department for its administrative use. Active records are current writings, sound and/or video recordings, in any format, necessary for departmental administrative purposes and retained for a requisite statutory period. Inactive records are writings sound and/or video recordings, in any format, that have passed their retention period, are no longer necessary for departmental administrative purposes and outside of archival use.
2The purpose of the Westmont College Archives is to appraise, collect, organize, preserve, exhibit, make accessible and permanently retain items relating to college history.
3A multi-student record is an educational record which includes information directly related to more than one student. The Family Educational Rights and Privacy Act of 1974 requires that educational institutions redact all information leading to the identity of the non-requesting student where the requesting student record includes information about any other student.
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