CoE Guidelines for Record Retention

This document is a companion to the University’s Records Policy and Procedures Manual (available on the web at https://bentley.umich.edu/wp-content/uploads/2014/manual.pdf) and is intended to guide departments in the development of department-specific policies and procedures regarding record retention.  Included are references to relevant state and federal laws, University and College policies, and recommendations for consideration in each of the following areas:

  • Financial
  • Student
  • Human
  • Resources
  • Governance
  • Grievances
  • Facilities & Safety

Over-Arching Guidelines

Avoid redundancy –In general, the storing of redundant information should be avoided.  In many cases, the central offices have primary responsibility for retaining records.  In cases where departments are storing centrally-maintained information beyond the limits set forth in the other sections of this document, departments are encouraged to weigh the value of easy access to the information vs. the cost of storage.

Freedom of Information Act –Because University records are subject to disclosure, it is a good practice to be mindful of potential public dissemination when deciding whether a document needs to be retained.

Historic Value – Contact the Bentley Historical Library before destroying materials that are not available through a central office to receive an assessment of whether the documents have potential historic value.

Internal Consistency –Review practices to ensure that the same retention rules apply to like activities.  Purge files on a timely basis to avoid erroneous interpretations of record retention policies.

Primary Responsibility – Avoid retaining draft or outdated copies of documents for which the primary responsibility lies within another unit.

Imaging

Refer to the University Records Policy and Procedures Manual https://bentley.umich.edu/wp-content/uploads/2014/manual.pdf for guidelines on managing and preserving records in digital form.

Financial

Financial Operations has set the following expectations for financial record retention (see SPG

604.1 for additional information).  It is important to note the following:

  • time period is dependent upon the source of funding
  • when the time period has expired, the records should be destroyed (e.g., shredded)

Per the SPG, “Financial records include but are not limited to vendor contracts, purchase orders, vendor payments, payroll payments, reimbursement documentation, income and expense summaries, allocations and reconciliations.  Business and financial records, whatever their format, are to be retained for the proper periods.  The business and financial records may be retained in the traditional written format, in electronic format or in an imaged format…“

Documents Retained Solely by the Unit

Documentation that is available only in the unit must be maintained for the time period specified by the funding source (see below).

Unit files serve as the working files for monitoring and managing a unit’s activities.  These files are often used to verify appropriateness of financial activity.  Therefore, this information must be available to internal and external auditors for the time period specified by the funding source (see below).

Documents Retained Centrally

Financial documents that arc maintained centrally, either in original, microfilm, or electronic format (e.g., MPathways data warehouses or imaging), should be retained within the College only for two years plus the current year.  Appropriate documentation should include:

  • Payroll Documentation
  • Transfer, Invoice & Travel Vouchers
  • Unit Billing Statements
  • Sales Invoices & Credit Memoranda
  • Purchase Orders & Requisitions
  • Approval of Application for Grant or Contract Forms
  • Cash Receipts
  • Cash Payments Service
  • Statements of Activity
  • Encumbrance Reports
  • Organization  Reports
  • Project Budget Reports

Audits & Court Proceedings

Please note that the unit should retain any records pertaining to financial activity that is currently undergoing an audit or is part of a court proceeding even if the general guideline for retention has expired.  Direction on the appropriate disposition of such files should be sought from the Director of Financial Operations, Director of University Audits, and/or The Office of the General Counsel, as appropriate.

Sales Tax, Unrelated Business Income & Tax Returns

If your unit is involved in any of these, please consult the SPG (604.1) for specific information on record retention.

Sponsored Program Funds

Per the SPG, “Sponsored activities administered under the terms and conditions of a grant or contract agreement normally required retention of records for seven (7) years from the expiration date of the agreement except as otherwise stated therein.  This time period is measured from the final project ending date extended by any amendments or medications.”

Gift and Endowment Funds

Per the SPF, “Department gift records should be maintained for a period of seven (7) years from the time of receipt.  To ensure a complete understanding, and compliance with, al agreements relating to an Endowment, all documents relating to all Endowment are to be maintained in the permanent trust endowment files in the Financial Operations’ vault.  All such documents should be forwarded to the Endowment Fund, Attention:  Endowment Supervisor, Sixth Floor Wolverine Tower, for proper filing.”

The College policy is to retain all documentation that describes the purpose of gifts until seven (7) years after the financial activity on the gift has ended.  It is important that departments note whether any restrictions placed upon use of these funds were identified by the donor(s) or by the unit (as the latter can more easily be modified).

General, Designated and Auxiliary Funds

All of these funds are considered non-sponsored activities.  The required  record retention is the current fiscal year plus the two prior fiscal years.

Rebilling Funds

Since service (rebilling) units bill sponsored projects, they are required to meet the retention period identified for Sponsored Programs (i.e. seven years from the date of final activity).

Student Records

Many offices at the University of Michigan collect and maintain information about students.  All student files are subject to the federal Family Education Rights and Privacy Act (referred to as FERPA or the Buckley Amendment).  Departments are encouraged to maintain working files to support student services functions and must, therefore:

  • Understand the rights of students to examine their records;
  • Dispose of information in a manner that will not violate its confidential nature;
  • Have a written statement of its policies and procedures for handling student records; students have a right to examine this statement.

The student records retention website is https://ogc.umich.edu/frequently-asked-questions/student-records/.

Template for written statement of departmental policies and procedures for handling student records:

Handling of Student Records within the Department (Date)

The following offices are responsible for retaining the official student records:     

  • Office of Undergraduate Admissions, as the admitting office for new freshman
  • CoE Transfer Admissions, as the admitting office for CoE transfer students
  • Rackham Graduate School, as the admitting office for Rackham graduate programs
  • CoE office of Graduate Education, as the admitting office for CoE Non-Rackham graduate programs
  • Office of the Registrar and College of Engineering Student Records Office

It is the policy of this department to maintain working files to support student services functions for students who are active in our programs.  The department retains such working files for (insert time period) for students who have graduated from our programs.

The department maintains working files to manage our graduate admissions activity.  Once an admissions cycle is complete, the following documents are integrated into the department’s active student files:

(insert as appropriate)

The files for applicants who were not admitted (insert as appropriate are not retained or are retained for one year in case the individual decides to reapply).

Consistent with the FERPA, only those who have a need to know have access to these records. This includes:

(insert as appropriate)

The department prohibits the release of “personally identifiable records” without consent of the student, consistent with FERPA.

Students wishing to inspect their working file, should (insert procedure)

Students may wish to review the University’s policy, “Student Rights and Student Records”, which is published on the Office of the Registrar web site:  http://ro.umich.edu/ferpa/.  The department prohibits the release of “personally identifiable records” without consent of the student, consistent with FERPA.