Records Management Policy
I. Effective Date
July 22, 2025
II. Last Revision Date
N/A
III. Responsible Party
Office of General Counsel
IV. Scope
This policy applies to all Marymount University personnel: administration, faculty, and staff.
V. Purpose
The purpose of this policy is to establish consistent guidelines for the creation, management, retention, and disposal of university records to ensure compliance with legal, regulatory, and operational requirements. This policy supports the preservation of essential university records, promotes efficient recordkeeping practices, and ensures timely and secure disposal of records when appropriate. It applies to all formats of records (physical, electronic, or otherwise) created and maintained in the course of university operations and serves to protect the University’s legal and administrative interests.
VI. Policy Statement
Records, regardless of format, created in the course of business, are the property of Marymount University (MU) (“University”). MU offices and staff that create and maintain these records are responsible for their preservation and security while they are in active use, and are also responsible for consulting the records retention schedule to determine when and how inactive records should be stored or destroyed.
VII. Policy
Records Retention
The Records Retention Schedule is a guideline that sets forth the length of time records are recommended to be retained. This guideline applies to all records listed on the schedule to the extent they are maintained by the University, including storage areas. The schedule is intended to cover all University records for which there is a legal, regulatory or management retention requirement.
Records Disposal
Records may not be destroyed unless permission is granted through an approved records schedule. Prior to disposal, departments must complete and submit the University’s official Records Destruction Form to the Office of General Counsel for review and approval. Records pertaining to any investigation, legal action, or proceeding, litigation, audit, or program review in progress must not be destroyed even if the retention period or disposition date specified for the records has expired. Document destruction will be suspended immediately, upon any indication of an official investigation or when a lawsuit is filed or appears imminent. Destruction will be reinstated upon conclusion of the investigation.
Access to Records
Access to records remaining in the custody of academic units and offices is through a designated staff person. Access to records in the custody of the University is in accordance with its policies and procedures. Some materials may be restricted if there are privacy and/or confidentiality concerns.
Digital or Electronic Records
Disposition of records created, retained, or stored in information systems or computers should proceed on the same basis as traditional records. Digital or electronic records for which there is no retention requirement should be deleted promptly.
VIII. Retention Schedules
|
Academic/Student Records |
|
| Academic dismissal records | Permanent |
| Academic integrity code violations (with sanctions)
|
Permanent
|
| Admissions records | 10 years |
| Grade records | Permanent |
| Other academic records | 5 years |
| Career planning and placement | 4 years |
| Graduation lists
|
Permanent
|
| Class schedules | 5 years from graduation or date of last attendance |
| College catalog | Permanent |
| Data change logs (including date/time stamp information and information of the user that changes the data) | 10 years
|
| Degree audit records | 5 years after date of last attendance |
| Disciplinary action records | 5 years after graduation or date of last incident |
| Enrollment data | 10 years |
| Enrollment statistics | Permanent |
| FERPA related documents/requests (includes requests for formal hearings, requests for and disclosures of PII, requests for nondisclosure of directory information, statements on content of records regarding hearing panel decisions, written consent for records disclosure, waivers for rights of access, and written decisions of hearing panels)
|
Permanent
|
| FFEL and Direct Loan reports | 3 years after the end of the award year in which the reports were submitted. |
| Borrower records (including documentation of loan disbursement, exit counseling, etc.) | 3 years from the end of the award year in which the student last attended. |
| Perkins Loan repayment records (including cancellation and deferment documentation) | 3 years from the date the loan was assigned to the Department, canceled, or fully repaid. |
| Perkins Loan original promissory notes and original repayment schedules | Until loan is satisfied or enforced. |
| General Financial Aid Records (including applications, eligibility documentation, award letters, etc.) | 3 years from the end of the award year for which the aid was awarded. |
| Foreign student forms (I-20) | 5 years after graduation or date of last attendance |
| Student academic files (departmental) | 5 years |
| Transcript requests | 1 year |
| Tuition fees and schedules | Permanent |
|
Student Life Records |
|
| College publications | Permanent |
| Student counseling files | 5 years after case is closed |
| Student groups and organizations | Permanent |
| Student handbooks | Permanent |
| Team rosters | Permanent |
| Athletic contest scores and statistics | Permanent |
| Athletic injury files | 7 years |
| Fitness Center waivers | 3 years after graduation |
| Media guides | Permanent |
| NCAA case files/infraction files | 7 years from date of last incident |
|
Trustee Boards and Other Governance, Committees and Meetings |
|
| Board resolutions and charter | Permanent |
| Proceedings of the Trustee Board and Committees, Academic Committees, and Administrative reports | Permanent |
| Records of other committees and meetings | 5 years |
| Conflict of Interest Disclosure Forms | 3 years following termination of Board or Committee service |
|
Contracts and Risk Management |
|
| Design and construction contracts | Life of building |
| Other contracts, except research administration contracts | 7 years after termination |
| Insurance policies | Permanent |
| Equipment warranties | Life of equipment |
| Patent, trademark and other intellectual property records | Permanent |
| Litigation, claims, risk management, incident reports | 7 years |
| Authorizations for release of records, subpoenas, court orders | 7 years |
| Real property records | Permanent |
|
Regulatory Records |
|
| Accreditation records | Permanent |
| Licensure records | Permanent |
|
Legal Records |
|
| Litigation records | Permanent |
| Memorandum of understanding (MOU) | 7 years from expiration of contract |
| Nondisclosure and confidentiality agreements | 7 years from expiration of contract |
| Settlements | Permanent |
| Outside counsel legal representation letter or agreement | 7 years from expiration of, including any amendment or renewal |
|
Faculty Records |
|
| Faculty meeting minutes | Permanent |
| Faculty promotion and tenure records, and tenure review records | Permanent |
| Conflict of interest disclosures | Permanent |
|
Search Records |
|
| Presidential search records | Permanent |
| Academic search records | 2 years from date search is completed |
|
Publicity Records |
|
| Publicity records | Permanent |
|
Public Safety Records |
|
| Public safety Records | 5 years |
|
Miscellaneous |
|
| Annual reports | Permanent |
| Commencement lists | Permanent |
| Policies and procedures | 10 years after withdrawal/revision |
| Health Records | 6 years from last patient encounter |
|
Alumni Records |
|
| Alumni Club files | Permanent |
| Alumni Council records | Permanent |
| Credential files, alumni | Permanent |
| Reunion class files | Permanent |
|
Accounting, Finance and Payroll |
|
| Accounts payable and receivable records | 7 years |
| Books of accounts | 7 years |
| Banking records | 7 years |
| Financial statements; annual reports to government agencies | Permanent |
| Budgets | Permanent |
| Payroll records | 7 years |
| Employee benefit plans | 1 year after term of plan |
| Records of property subject to gain or loss treatment | 7 years after taxable disposition |
| Records supporting items of income, deductions and credits | 7 years |
| Tax returns and supporting records | 7 years |
| Bond related documents | Life of the bond plus 3 additional years |
|
Development |
|
| Fundraising | 5 years after end of registration period |
| Endowment | Permanent |
|
Employment Records |
|
| Records relating to Family Medical Leave Act | 3 years |
| EEOC reports | 5 years |
| Integrated Postsecondary Education Data System (IPEDS)
|
7 years |
| Personnel files (including, application, resume, payroll/salary, appointment forms, position description, performance evaluations) | 7 years from voluntary termination; permanent if involuntary termination |
| Training records | 4 years |
| In-Service records | 4 years |
| Educational programs | 4 years |
| Records of workers employed under special certificates | 3 years |
| Wage-hour administrator certificates and notices | 5 years |
| Immigration records | 3 years after hire or 1 year after termination, whichever is later |
| Attendance records | 3 years |
| Employee policies & procedures | Permanent |
| Other employment records | 3 years |
| I-9 forms | 3 years or 1 year after termination |
|
Occupational Safety and Health Records |
|
| Medical tests and screening required by law | 30 years after employee termination |
| Records of personal or environmental monitoring of exposure to hazardous substances | 30 years after employee termination |
| Employee records of significant adverse effect to health or environmental hazards | 30 years after employee termination |
| Employee records of allegations concerning exposure to environmental hazards against employer | 30 years after employee termination |
| Other employee health records | 7 years after employee termination |
|
Benefits; Pension Plans |
|
| Description of benefit plans, seniority or merit pay systems | 1 year after term of plan |
| Pension plan descriptions and ERISA benefits | 6 years |
|
Construction |
|
| Building plans and specifications | Life of building |
|
Facilities |
|
| Operational manuals | Life of building |
| Records related to measurement of noise in work environment | 4 years |
| Records of fire, internal disaster and evacuation plan drills | 4 years |
| Records of fire department inspection | 4 years |
| Written report and evaluation of all external disaster plans | 4 years |
|
Health and Safety |
|
| Records of inventory, use and control of radioactive materials | 30 years |
| Records of disposal or abatement of toxic and hazardous waste | 30 years |
| Transportation of infectious and chemotherapeutic waste | 30 years |
| Records of hazardous waste generating | 30 years |
| Records of employee exposure to hazardous substances | 30 years |
| Records of asbestos exposure | 30 years |
|
Equipment |
|
| Records of required testing of fire protection equipment | 4 years |
| Records of periodic inspections of extinguishing systems | Until the container is reinspected or its life |
| Material hoists, personnel hoists and elevator standards and certification records | 4 years |
| Records of inspection, performance, exercising period and repairs of emergency power equipment | 7 years |
| Evidence of required hydrostatic testing or portable fire extinguishers | Until hydrostatically retested at stated intervals or until taken out of service |
| Mechanical and electrical equipment checks | 4 years |
|
Research Administration Records |
|
| Administration records | Up to 7years after completion of research, as specified by individual agency requirements |
| Financial records | Up to 5 years after completion of research |
| Scientific records | Up to 7 years after completion of research |
| Protocols and related documents (including consents and indemnification) on grants and contracts covering use of human subjects and animals in research | Permanent |
| Sponsored research | Up to 7 years unless a longer period is required by sponsor contract |
| Research involving investigational drugs | Up to 7 years after completion of research or possibly longer (see requirements of 21CFR312.62) |
| IRB records; minutes, agendas, other records | Up to 7 years after completion of research |
| Research involving medical devices | Up to 7 years after completion of research |
| Real property and equipment acquired with federal funds | 3 years after final disposition |
IX. Compliance
Failure on the part of employees to follow this policy can result in possible civil and criminal sanctions against the University and its employees and possible disciplinary action against responsible individuals.
The Office of General Counsel will periodically review policy, schedules, and procedures to ensure that they are in compliance with new or revised regulations and best practices.
