Policy No. 544-A - Records Retention

This policy sets forth the standards and requirements for the retention of the records of the Research Foundation of the City University of New York. It is intended to ensure the organized retention of records for retrieval, to guard against premature destruction of records, and to mitigate the risk of retaining unnecessary records.

This policy is applicable to all Research Foundation Central Office employees and their records.

The Research Foundation requires that records be maintained in a consistent and logical manner. Maintenance, retention, and disposal procedures for Foundation records must be followed systematically by staff members in each department or office. This policy is intended for the Research Foundation to:

• Ensure that records are retained as long as needed for administrative, legal, and fiscal purposes.
• Ensure that requirements for federal, state, city, and private sponsor’s records retention are met.
• Ensure that records with enduring historical and other value are identified and retained permanently.
• Encourage and facilitate the systematic disposal of unnecessary records.

Definition of a Foundation Record

A Foundation record is the original or copy of any writing, regardless of physical form or characteristic, that contains information determined by the Research Foundation Departments to be official records of the Research Foundation.

Electronic Records

Electronic record means any Foundation record defined above that is created, received, or stored on a local workstation or a central server (e.g., emails, word processing documents, spreadsheets, and databases). Record retention periods apply to Foundation records regardless of their physical format. Electronic records are to be managed in the same manner as paper records to ensure compliance with this Policy and retained in accordance with the retention requirements, regardless of whether the electronic records are the original or copy.

Employee Responsibilities

All Foundation records are the property of the Research Foundation. Employees shall not alter, destroy, misplace, or render useless any official document, record, or file that is intended to be kept as the Foundation record. Records created by employees for personal uses shall not be commingled with the Foundation records. The Research Foundation does not have any obligations to ensure the controls implemented by management will cover records created for personal use by employees. Research Foundation reserves the right not to permit employees to access any records (including records for personal use) subsequent to the termination of their services.

Records Retention Schedule

Records Retention Schedule provides a detailed list of Foundation records for each Department and prescribes the period for retention. A Foundation record, regardless of the format in which it is created, must be retained for designated periods of time, and may only be disposed of in accordance with the Records Retention Schedule. As a permanent record is to be kept for an indefinite period, criteria shall be developed to assist Departments in determining if a record should be permanent or current. If a record is not listed on the schedule, it does not mean that it can or should be destroyed without first considering the general requirements of this policy and consulting with the Research Foundation's Counsel and Chief Operating Officer.

Disposal and Destruction of Records

To mitigate the risk of retaining unnecessary records and increase operational efficiency in identifying necessary records, those Foundation records designated by Departments for destruction after fulfilling their retention requirement must be disposed of in an appropriate method in accordance with the Records Destruction Procedure. The Research Foundation’s Counsel and Chief Operating Officer shall have access to the current Records Destruction Schedule to determine the applicable records to be provided when such records are requested.

Litigation Holds

When litigation against the Research Foundation or its employees is filed or threatened, the law imposes a duty upon the Research Foundation to preserve records that pertain to the subject of the litigation. Litigation holds will be sent to the appropriate persons and departments. The litigation hold overrides the Record Retention Policy. Destruction of documents related to the litigation would be suspended and records would be held until released by Research Foundation's Counsel.

Review

The Record Retention Schedule will be reviewed at least annually by management to include additional records, to change retention periods, to address records no longer useful or obsolete, and to determine the most effective and technologically appropriate manner of retention.

Records Management

The Chief Operating Officer (COO) shall be responsible for establishing Standard Operating Procedures, including the design of record-keeping systems and procedures for the management of the records and archives of the Research Foundation including their use, storage, retention, disposition, and access rights. The COO shall also establish standards for the structure, content, and context of electronic records, in order to ensure that they are accurately created, captured in their integrity, preserved without alteration, and remain accessible for as long as the electronic record is retained. Such procedures shall be developed to facilitate the appropriate identification, handling, and management of sensitive records to prevent unauthorized use and/or disclosure of sensitive information and to control authorized disclosure and handling of sensitive information.