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Record Retention and Document Destruction Policy

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