The objective of this Record Retention Policy (“Policy”) is to ensure that Lesley University complies with all applicable laws and regulations governing the management, retention, and destruction of the university’s records. Because the university does not have a centralized records management function, each department is responsible for the retention and disposal of the records it generates.
In certain cases, it is a crime to destroy records.
For purposes of this Policy, the term “record” refers to any recorded information, wherever such information is or may be stored, that has been created by or for the university, or received by the university in connection with the transaction of the university’s business that is in any format (including, without limitation, paper, electronic, and audiovisual materials).
The university has determined that for statute of limitations or other reasons, certain records must be retained for specific periods of time. The attached record retention schedule provides the minimum retention periods under this Policy for a variety of categories of documents.
Document types that are not listed, but are substantially similar to those listed on the schedule should also be retained for the appropriate minimum retention periods. Records may be retained in print or electronic form. Portable document format (“pdf”), faxed or scanned documents satisfy record retention requirements, provided that the authenticity of the original is not reasonably expected to be called in to question.
Email that needs to be retained should be either (a) printed in hard copy and kept in the appropriate file, or (b) downloaded to a computer file and kept electronically or on disk as a separate file.
The university’s General Counsel serves as the university’s Records Management Officer. The Records Management Officer is responsible for overseeing the implementation of, and compliance with, this Policy. Each department may adopt additional record retention policies so long as the Records Management Officer approves of the additional policies and the minimum retention periods are at least as long as the retention periods set forth on the attached schedule.
Each employee is responsible for maintaining the records that he or she originates or receives in accordance with this Policy. Employees who are unsure about the need to keep a particular document should consult with the Records Management Officer.
The Records Management Officer shall make periodic reviews of the document retention mechanisms and storage capabilities of the university to ensure the proper maintenance, storage and back-up of the university’s records.
No records of any type that may be related to an ongoing or imminent university investigation or disciplinary process, lawsuit, or government investigation shall be destroyed and all ordinary disposal or alteration of records pertaining to the subjects of the litigation or investigation shall be immediately suspended.
In certain cases, the Records Management Officer will instruct employees to retain records indefinitely pending an investigation, disciplinary process, or lawsuit. Employees who become aware of a legal matter (whether pending or threatened) involving the university should promptly notify the Records Management Officer so that the university can ensure the preservation of all records relating to that matter. If an employee is uncertain whether documents under his or her control should be preserved because they might relate to a university investigation or disciplinary process, lawsuit, or government investigation, he or she should contact the Records Management Officer
Failure to comply with this Policy, including interference with the retention or destruction of the university’s records, may result in civil and criminal liability, as well as disciplinary action, up to and including termination.
Failure to maintain certain records may subject the university and/or individuals to penalties and fines and may compromise the university’s position in litigation or an investigation.
It is also a federal crime, punishable by a fine and up to 20 years in prison, to knowingly alter, destroy, mutilate, conceal, cover up, falsify or make a false entry in any record with the intent to impede, obstruct or influence the investigation or proper administration of a government investigation or proceeding.
The Registrar's Office maintains academic records both on and off premise in fire-resistant cabinets. Beginning in 1986, all academic records were put on microfilm and this security measure continues annually as students graduate or discontinue study. Microfilm records are maintained both on campus in the Registrar's Office and in duplicate with a microfilm vendor.
In the event Lesley University discontinues operations, arrangements would be made with the Massachusetts Department of Higher Education, One Ashburton Place, Room 1401, Boston, MA 02108-1696, (617) 994-6950, www.mass.edu, for the filing and maintenance of academic records. The university would take reasonable steps to notify current and former students about the arrangements for the filing and maintenance of academic records.
Employee files, including employment applications for individuals hired
While active plus 7 years
Employment applications, if not hired
3 years
Employment tax records
7 years
Gift records, agreements, award letters, fundraising campaign literature
Permanently
Governance: minute books, bylaws, charters, articles of organization, and policies
Permanently
Insurance policies (expired)
3 years
Insurance records, current accident reports, claims, policies
Permanently
Internal audit reports
3 years
Internal Revenue Service exemption application and determination letter, examination rulings, and comments
Permanently
Litigation-related documents
Permanently
Retirement and pension records
Permanently
State tax exemptions
Permanently
Student Counseling Center records
Permanently
Tax returns, worksheets, information returns, and related records
Permanently
Trademark registrations
Permanently
Notwithstanding the above, for purposes of the form PC, books and records that:
Are sufficient to substantiate all information required on the Form PC (including records or inventories).
Support each individual transaction for items of gross support, revenue, and expenses.
Reflect a functional breakdown of expenses such that fundraising expenses can be distinguished from all other expenses.
Disclose the sources of revenue and expenses related to the special events and show specifically the items of the revenue and expenses from the special events.
Permanently
Lesley Department
Required Retention Period
Finance Department
See policy mandated by the Controller
Financial Aid Office
See policy mandated by Director of Student Financial Services
Student Accounts Office
See policy mandated by Director of Student Accounts
Registrar
See Student Record Security section
Questions?
Contact Shirin Philipp, Vice President and General Counsel, with any questions.