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 |
| Electronic 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