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Record Retention and Document Destruction Policy

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        Purpose

        Consistent with the Sarbanes-Oxley Act, which makes it a crime to alter, cover up, falsify, or destroy any document with the intent of impeding or obstructing any official proceeding, this policy provides for the systematic review, retention, and destruction of documents received or created by DePauw University in connection with the transaction of University business. This policy covers all records and documents, regardless of physical form, contains guidelines for how long certain documents should be kept, and how records should be destroyed (unless under a legal hold). The policy is designed to ensure compliance with federal and state laws and regulations, to eliminate accidental or innocent destruction of records, and to facilitate DePauw University’s operations by promoting efficiency and freeing up valuable storage space.

        Document Retention

        DePauw University follows the document retention procedures outlined below. Documents that are not listed, but are substantially similar to those listed in the schedule, will be retained for the appropriate length of time.

        Corporate Records

        Annual Reports to Secretary of State/Attorney General Permanent
        Articles of Incorporation Permanent
        Board Meeting and Board Committee Minutes Permanent
        Board Policies/Resolutions Permanent
        Bylaws Permanent
        Construction Documents Permanent
        Contracts (after expiration) 7 years
        Correspondence (general) 3 years
        Fixed Asset Records Permanent
        IRS Application for Tax-Exempt Status (Form 1023) Permanent
        IRS Determination Letter Permanent
        State Sales Tax Exemption Letter Permanent

        Accounting and Corporate Tax Records

        Annual Audits and Financial Statements Permanent
        Business Expense Records 7 years
        Cash Receipts 3 years
        Credit Card Receipts 3 years
        Depreciation Schedules Permanent
        General Ledgers Permanent
        Invoices 7 years
        IRS Form 990 Tax Returns Permanent
        IRS Forms 1099 7 years
        Journal Entries 7 years
        Petty Cash Vouchers 3 years
        Sales Records (box office, concessions, gift shop) 5 years

        Bank Records

        Bank Deposit Slips 7 years
        Bank Statements and Reconciliations 7 years
        Check Registers 7 years
        lectronic Fund Transfer Documents 7 years

        Payroll and Employment Tax Records

        Earnings Records 7 years
        Garnishment Records 7 years
        Payroll Registers Permanent
        Payroll Tax Returns 7 years
        State Unemployment Tax Records Permanent
        W-2 Statements 7 years

        Employee Records

        Accident Reports and Worker’s Compensation Records 5 years
        Employment and Termination Agreements Permanent
        Employment Applications 3 years
        I-9 Forms 3 years after termination
        Records Relating to Promotion, Demotion, or Discharge 7 years after termination
        Retirement and Pension Plan Documents Permanent
        Salary Schedules 5 years
        Time Cards 2 years

        Donor and Grant Records

        Donor Records and Acknowledgment Letters 7 years
        Fund/Trust Agreements and Statements Permanentv Grant Applications and Contracts 7 years after completion Grant Applications – Non-awarded 3 Years

        Legal, Insurance, and Safety Records

        Appraisals Permanent
        Copyright Registrations Permanent
        Environmental Studies Permanent
        General Contracts 3 years after termination
        Insurance Policies Permanent
        Leases 6 years after expiration
        OSHA Documents 5 years
        Real Estate Documents Permanent
        Stock and Bond Records Permanent
        Trademark Registrations Permanent

        Student Records

        Academic Advising Files 3 Years
        Academic Integrity Files 5 Years from last incident
        ADA Files 5 Years
        Admission Applications – Non-enrolled Students 1 Year
        Financial Aid Files 4 Years
        Health Files 7 Years
        Perkins Loan Files 3 Years after payoff
        Scholastic Standing Files 5 Years
        Student Life Files 6 Years
        Transcripts Permanent
        Vaccine Records Permanent

        Electronic Documents and Records

        Electronic documents will be retained as if they were paper documents. Therefore, any electronic files, including records of donations made online, that fall into one of the document types on the above schedule will be maintained for the appropriate amount of time. If a user has sufficient reason to keep an e-mail message, the message should be printed in hard copy and kept in the appropriate file or moved to an “archive” computer file folder. Backup and recovery methods will be tested on a regular basis.

        Emergency Planning

        DePauw University’s records will be stored in a safe, secure, and accessible manner. Documents and financial files that are essential to keeping DePauw University operating in an emergency will be duplicated or backed up at least every week and maintained off-site.

        Document Destruction

        DePauw University’s chief financial officer is responsible for the ongoing process of identifying its records, which have met the required retention period, and overseeing their destruction. Destruction of financial and personnel-related documents will be accomplished by shredding.

        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.

        Compliance

        Failure on the part of employees to follow this policy can result in possible civil and criminal sanctions against DePauw University and its employees and possible disciplinary action against responsible individuals. The Chief Financial Officer and the Audit and Risk Management Committee Chair will periodically review these procedures with legal counsel or the University’s Independent Certified Public Accountants to ensure that they are in compliance with new or revised regulations.

        --Endorsed by the Audit and Risk Management Committee, April 17, 2007