Records Management

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Policy Category and Number: Executive

Effective Date: 5/31/2023

Responsible Officer: Director of Compliance and Risk Management

History: Records Retention and Disposal Policy January 22, 2014

Responsible Office: Office of the General Counsel

Location: Link

Purpose

This policy is intended to assist Wentworth Institute of Technology (university) in effectively identifying, organizing, maintaining, and disposing of university records. This policy will help to ensure that Wentworth is following all applicable laws and regulations governing records retention and eliminating risks and costs associated with unnecessary records storage.

Scope/Applicability

This policy applies to all members of the Wentworth community, students, faculty, staff, and affiliates. It is applicable to all university records, as defined herein.

Legal

N/A

Policy

The university requires that records be retained for specific periods of time in accordance with legal and other university requirements. Once records have been identified as those that are no longer needed, they must be disposed of in the appropriate time and manner.

Definitions

  1. Active Record: University records which are referenced and used on a regular basis. The number of years a record will remain in active use depends on how long the law requires that the record be retained and the purpose for the creation and use of the record. Active Records must either be retained for their full authorized retention period by the office that created them or at a university approved storage vendor.  

  2. Archival Records: Archival records are original university records, which have been deemed to have enduring value to the university. Archival records are usually transferred from the originating department or office to the university archive for permanent preservation. 

  3. Inactive Records: A university record that is no longer actively used or referenced by the department or office that created it (e/g.. the record is no longer in current departmental or office use), but which must be retained pursuant to an approved retention period. 

  4. Legal Hold: An order issued by General Counsel to cease destruction and to preserve all records, regardless of form, related to the nature or subject of the legal hold. 

  5. Official Record: Records are considered ‘official’ when they are in a final form and have been authenticated by an authorized person or business application in the department or office that originates and finalizes them.  Most records that individuals and departments maintain are not official records pursuant to this policy. Documents and materials that are not “official” should be destroyed routinely unless they are subject to a litigation hold or required for a business need. 

  6. Offsite Storage: Inactive records may be stored with a university-approved off-site storage vendor. Offsite storage vendors provide fee-based service for picking up, dropping off, and storing inactive records. 

  7. Personal Information: Massachusetts law defines “personal information” as an individual’s name together with that person’s Social Security Number, driver’s license number or Massachusetts state identification card number, financial account number, or credit or debit card number, with or without any required security code, access code, personal identification number or password that would permit access to an individual’s financial account, or biometric indicator. 

  8. Record Officer: The person(s) identified within the department or office who is responsible for ensuring this policy and any departmental or office procedures concerning records management are observed. Divisions may have multiple record officers. 

  9. Records Preservation/Hold: An internal procedure to ensure that certain information is preserved which may be needed for reasonably anticipated or actual government investigation, audit, or litigation. A records preservation/hold order temporarily sets aside the retention period stated in the records retention and disposition schedule, and suspends destruction for the affected records until the records preservation/hold order is released. 

  10. Record Retention Schedule: A listing of the types of records retained by the department and the amount of time in which the record will be maintained. Recordkeeping requirements identified in the schedule are based on U.S. federal or state statutory, regulatory or other legal requirements as well as university operational requirements. 

  11. University Archive: The official repository for university archival records, as defined above, and the program through which records are acquired, promoted, and made available for use.   

  12. University Record: Any record created or received by a university employee in the course of university business. Records can include paper and electronic documents (including e-mail and text messages), microforms, audio and video recordings, databases, and emails. Some examples of records include, but are not limited to, contracts, minutes, correspondence, memoranda, financial records, published materials, photographs, sound recordings, video recordings, drawings and maps, and computer data. University records, except as otherwise noted in the Intellectual Property Policy, are university property. 

Procedures

Departmental and Office Responsibilities  

  1. Create, implement, and monitor a record retention schedule and related procedures  
  2. Assign a record officer(s)  
  3. Review university records in their possession and determine appropriate steps for accessibility, and destruction as appropriate 
  4. Develop departmental filing and classification systems  
  5. Train staff as appropriate  
  6. Destroy university Records that have met their authorized retention period and are not subject to legal holds.  

Cessation of Record Destruction 

If a lawsuit is filed or imminent, or a legal record request has been made upon the university, all record destruction must cease immediately. The Office of the General Counsel shall notify the appropriate parties when such instance occurs, and they shall ensure that all applicable record destruction is suspended by notifying appropriate staff including but not limiting to the record officer(s)

Off-campus Storage 

The Office of the General Counsel, in consultation with Digital Technology Services (DTS), shall maintain procedures for use of the university’s offsite storage vendor 

Records Disposition Process 

  1. Materials that do not have financial, proprietary, personal, or confidential information can be recycled or discarded by approved means. 
  2. Records that have financial, proprietary, personal, or confidential information must be destroyed by shredding or other approved method. 
  3. Records that have permanent value must be sent to the university archives when an office’s administrative use has ended. 
  4. Records can be shredded by the office or boxed and picked up for on-site shredding by the approved third-party vendor on designated shred. The Office of the General Counsel shall maintain information regarding records disposition procedures. 

Additional Information & Related Documents

Document Retention Schedules

Interpretation & Revision

Any questions of interpretation regarding this policy shall be referred to the Director of Compliance and Risk Management. They will be the final authority regarding the interpretation of this policy.

This policy shall be reviewed every 3 years, however minor changes and updates can be made at any time.

Wentworth will typically apply the policy in place at the time it receives a report concerning the respected policy.

Additionally, in instances where two or more policies are implicated, a case-by-case determination will be made to determine what policy will be used.

Review and Revision History

This policy was drafted by representatives from the Director of Compliance and Risk Management and Academics. It was reviewed by Cabinet and approved by the President on May 31, 2023.

This policy replaces the Records Retention and Disposal Policy that was passed on January 22, 2014