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CW 090 - Records Retention

Number

CW 090

Purpose

  1. To define CWI records;
  2. To provide best practices for managing CWI records;
  3. To provide a schedule for the retention and disposal of CWI records.

Department

Human Resources and Student Affairs

Effective

February 4, 2022

Last Revision

February 4, 2022

Last Reviewed

February 4, 2022

Scope

Applies to all CWI records.

Definition

Active Record: An Institutional Record currently used by the administrative unit that created or received it.

Administrative Unit: Any department, office, division, or other administrative component of the College.

Archival Records: Documents that have historic value and are not in active use. A document has historic value if it contains information that is of enduring value to the public.

Inactive Records: An Institutional Record that is not in active use but still must be maintained pursuant to the Record Retention Schedule. Inactive Records may be maintained off-site or as determined by IT unless it has historical significance according to the Records Administrator or designee, in which case it will be maintained as an Archival Record.

Institutional Records: Information fixed on any media that is created or received in connection with the administration of CWI’s business. Institutional Records are the property of CWI. Institutional Records exist in a variety of forms, including but not limited to, paper and electronic documents, audio and video recordings, databases, and email. Institutional Records include, but are not limited to, the following categories of records and non-exhaustive examples:

  1. Governing Documents – policies, manuals, procedures, SOPs, handbooks, orders, and other directives issued from the President or the President’s direct reports, and Board of Trustee resolutions.
  2. Reporting Documents – annual reports, strategic plans, performance reports, analyses, development plans, studies, accreditation reports and evaluations and reports prepared by CWI administration for the Board of Trustees.
  3. Fiscal Records – budgets, accounting records, audits and information collected for the performance of audits, invoices, purchase orders, payroll records, and grant and/or sponsored projects documentation. 
  4. Institutional Correspondence - hard copy or electronic mail that is created or received by CWI in connection with the administration of CWI’s business. 
  5. Electronic media – digital publications, social media posts, online advertisements, posted video content, website pages. 
  6. Personnel Records – name-linked files of documents related to potential, current, and former employees of CWI as referenced in HR 090 – Personnel Records Policy.
  7. Education Records – records directly related to a student and maintained by CWI or by a party acting for CWI as referenced in STU 090 – Student Records and Confidentiality Policy.
  8. Campus Operations Records – maintenance records, inspection records, safety reports, environmental health reports, incident reports and construction specifications.
  9. Legal Records – contracts, agreements, leases, real property records, licenses, proprietary information, settlements, litigation, and discovery documents and/or records collected or created in anticipation of litigation. 
  10. Risk Management – insurance policies, workers’ compensation records, claims, evaluations, investigatory records, and documents or reports communicated to or from claims representatives.
  11. Instruction Records – syllabi, course curriculum guides, program guides, course content presented through Blackboard including student grades and attendance where applicable. Program admissions documents, placement exams scores, and field trip consent. Faculty records that pertain solely to professional development are not regarded as Instruction Records.
  12. Archival Records – faculty, staff, and student organization records such as minutes, agendas and committee reports, Board of Trustees’ agendas and minutes, student and faculty achievements and awards, and documents that have historical value for CWI.
  13. Financial Aid Records – program and fiscal records related to CWI’s use of Federal Student Aid program funds. Records related to school and student eligibility, fiscal records, and loan program records, among other records, shall be maintained in accordance with federal regulations, including but not limited to 34 CFR 668.24

Personal Records: Personal documents or records created or received by faculty and College employees that pertain to their personal affairs and/or their professional careers including but not limited to documents accumulated by an individual prior to employment by the College, materials relating to private activities such as outside business and professional affiliations, and journals and correspondence that are not created or received through conducting College activities or business.

Records Administrator: Operations Program Manager. The designated Records Administrator will conduct annual reviews to confirm the policy is being followed by the respective business areas.

Policy

CWI recognizes the value effective records retention guidelines provide in preserving historical data, ensuring critical records are available to meet business needs, complying with legal requirements and optimizing physical and electronic storage by disposing of unnecessary and redundant records.

Guidelines

General Retention Guidelines

Institutional Records should be retained in accordance with the State Board of Education Records Retention Schedule of the Records Management Guide (Revised April 2008) (“Record Retention Schedule”) or as otherwise required to serve the official functions of the Administrative Unit involved. At the end of a retention period, records should be disposed of in accordance with these guidelines.

Institutional Records will ordinarily be kept in the Administrative Unit that created or received the document until the time that they are archived or destroyed. In consultation with and subject to the direction of the Records Administrator or designee, each Administrative Unit head must:

  1. Implement records management practices consistent with this policy;
  2. Educate staff about records management practices;
  3. Preserve records as required by this policy;
  4. Properly dispose of records at the end of the applicable retention period unless the records are of historic value, according to the Records Administrator or designee;
  5. Protect records against misuse, loss, damage, destruction, or theft; and
  6. Monitor compliance with this policy.

If, after consulting this policy and the schedule set forth in Record Retention Schedule, there exists a question regarding the proper disposition or retention of a particular document or class of documents, or the retention period for any such documents is not included in the Record Retention Schedule, it shall be the responsibility of the Administrative Unit head in possession of the document to determine its proper disposition in consultation with the Records Administrator or designee.

Record retention schedules set forth in state or federal law or which are established by individual program requirements shall supersede Record Retention Schedule.

Archival Records

The Records Administrator or designee determines which records qualify as Archival Records. Administrative Unit heads are responsible for forwarding Archival Records to the appropriate repository upon the expiration of the applicable retention period. Archival Records shall be preserved even though they might otherwise be subject to disposal pursuant to the Record Retention Schedule. 

Electronic Records

The same retention guidelines and schedule that apply to tangible Institutional Records also apply to electronic records. Under Idaho law, if a record is required to be retained, the requirement is satisfied by retaining an electronic record of the information where the record (1) accurately reflects the information set forth in the record after it was first generated in its final form as an electronic record; and (2) remains accessible.

Litigation Holds

All records pertaining to ongoing or pending audits or lawsuits (including reasonably anticipated lawsuits) should not be destroyed, damaged, or altered, even if the retention period has expired, until the matter has been resolved and employees have been specifically advised in writing that such records may be destroyed.  A representative from the Office of General Counsel, the Business Office, Risk Management or Human Resources shall take such steps as are necessary to promptly inform employees of the need to retain any records pertaining to ongoing or pending audits or lawsuits.  A litigation hold supersedes any record retention policy or schedule. CWI shall suspend any automatic deletion of electronic records to the extent necessary to ensure compliance with a litigation hold. 

Personal Records 

Personal records are considered personal property and are not owned by the College, nor are they typically subject to public records law. They should be kept separate from institutional records and generally are not subject to this policy.

Disposal of Records

Tangible Records: Tangible records containing confidential and/or personally identifying information must be shredded before disposal. Non-confidential records should be disposed of by recycling.

Electronic Records: Electronic records containing confidential and/or personally identifying information shall be destroyed or erased so that such information cannot practicably be read or reconstructed. Information Technology shall be responsible for ensuring electronic records or media are deleted pursuant to security standards.

Referenced