TAP No. 39: Records Retention

Scope

This Policy applies to students, faculty, and staff.  It applies to all University records, whether maintained in hard (paper) copy, electronically, or in some other manner. 

Purpose

The Duquesne University Records Retention Policy identifies the retention periods for different types of records and the process for disposal of records. 

I. Overview

Duquesne University is committed to effective record retention to meet legal standards, minimize the cost of record retention, optimize the use of space, and ensure that outdated records are properly disposed of.  This Policy addresses the retention and disposal of Duquesne University’s Records as defined in Section II below. As more fully described in this Policy, the University requires that records be retained for retention periods, consistent with legal, regulatory, and institutional requirements.  The retention periods set forth in the attached Records Retention and Disposal Schedule are the minimum retention periods required by the University. At the conclusion of the retention period, the Records must be properly disposed of in accordance with the requirements set forth in this Policy. Requests to deviate from or modify this Policy or these retention periods must be approved in writing by the University Data Governance Committee.

Every office and department managing University records is responsible for:

  • Implementing records management practices consistent with this Policy;
  • Ensuring that staff is knowledgeable about records management practices;
  • Maintaining records as required under this Policy;
  • Properly disposing of inactive records at the end of the applicable retention period;
  • Protecting records against misuse, misplacement, damage, destruction, or theft; and
  • Monitoring compliance with this Policy. 

II. University Archives

The University Archives shall be the official repository for all Archival Records of the University, as defined below. The University Archivist, through standard archival theories, practices, and procedures, shall be responsible for the administration, organization, determination of value, use, preservation, storage, and disposal of Archival Records.  

III. Types of University Records

A Record is any type of record created or received in the course of University business, including, but not limited to, paper, email, any type of electronic file or data, still photographs, motion pictures, drawings, plans/blueprints, and audio/video recordings, etc. The term “Record” includes all digital and physical forms and all versions and drafts of Records, not just the most recent or final version.  Some, but not all Records, may be Education Records under the Family Education Rights and Privacy Act.  TAP No. 28 addresses requirements related to Education Records.

  • An Active Record is any Record that is currently in active use by an office or function of the University.
  • An Archival Record is an Inactive Record that has permanent or historic value and is not required to be retained in the office in which it was originally generated. Archival Records are retained in the University Archivist.
  • An Electronic Record is a Record kept in an electronic format, such as a word processing document, a spreadsheet, a database, a scanned or imaged document, and any other type of file stored on a computer, server or mainframe storage device or medium, or on any external or off-site storage medium, or with a third party acting as the University’s agent. Electronic Records have the same retention periods as paper and other tangible Records.
  • A Paper Record is a physical Record in tangible form, such as a printed document, handwritten note, form, photograph, or any other type of information recorded on paper or similar physical medium. Paper Records can be original documents or printed copies of Electronic Records. Paper Records have the same retention periods as Electronic.
  • An Inactive Record is a Record that is no longer an Active Record but still must be maintained pursuant to the Records Retention Schedule set forth below. Inactive Records are typically maintained at an off-site storage facility or at other locations on campus; however, Inactive Records with permanent or historical value are maintained by the University Archivist.
  • Personal Information is information that includes an individual’s name or personal mark together with that individual’s social security number; driver’s license number or other government identification card number; financial account number, credit or debit card number, or any number or code which may be used alone or in conjunction with another piece of information to assume the identity of another person, access financial resources, or obtain credit information. Personal Information is highly sensitive and must be safeguarded and secured at all times. Records containing Personal Information may have other regulatory requirements that must be followed regarding data protection. Please see the CTS Data Governance Service Requirements or contact the CTS Information Security Office for data handling guidance.  

IV. Data Governance Committee

The University has established a Data Governance Committee to guide the University in the implementation, monitoring, and periodic review of this Policy and answer questions about compliance with this Policy. The Committee shall include a Chair and representatives from various schools, departments, programs, and other areas deemed appropriate by the Committee, each of whom shall be designated by the Committee Chair. The Committee reports to the Executive Vice President and Provost and the Vice President and Chief Information Officer. The Committee will meet at least quarterly. 

V. Retention of Records

The attached Records Retention Schedule lists different types of Records and the length of time those Records must be retained. Certain Records, including those identified in this Policy and in the attached Records Retention and Disposal Schedule, may be governed by various legal and regulatory requirements in addition to the requirements listed here.  Since no document list can cover all situations, questions regarding retention and disposal for a specific Record or class of Records not included in the Records Retention and Disposal Schedule should be addressed to the Data Governance Committee, which will consult with the Office of Legal Affairs as appropriate.  

All Records pertaining to ongoing or pending audits or lawsuits (including reasonably anticipated lawsuits) should not be destroyed, damaged, or altered, even if the records retention date has expired, until the matter has been resolved and you have been specifically advised in writing by the Office of Legal Affairs that such Records may be destroyed. If you have reason to believe that a Record scheduled for destruction may pertain to any of these matters, do not destroy the Record and contact the Office of Legal Affairs.

VI. Disposal of Records

If the record retention period has expired, the Record is not appropriate for the University Archives, and the Record does not pertain to ongoing or pending audits or lawsuits, the Record should be recycled or destroyed.  If there is a question about whether a Record is appropriate for the University Archives, the University’s Archivist should be consulted.

Disposal of Records without Personal Information may be made by any appropriate means, including recycling of paper Records. Disposal of electronic Records, including emails, should be made in a manner consistent with Computing and Technology Services (CTS) requirements. Formats that hold electronic media such as hard disks and portable drives may be overwritten or physically destroyed, but not placed in the trash.

Storing or disposing of Records that contain Personal Information requires special consideration. Regulation requires the University to take appropriate measures when disposing of Personal Information, such as: (a) shredding the Record; (b) destroying the Personal Information contained in the Record; (c) modifying the Record to make the Personal Information unreadable.

VII. Other Retention and Disposal Information 

  • Archives
    The University Archives, located in the University Library, is the repository for Archival Records and includes such items as commencement programs, yearbooks, college catalogs, blueprints, photographs, correspondence, and office files relevant to the history of the University.
  • Electronic Records
    Electronic records have the same retention periods as tangible records. Further inquiries should be directed to either the Office of Legal Affairs or Computing and Technology Services (CTS).
  • Physical Records
    Physical records are to be maintained in a safe and secure location while being preserved. When disposed of, they must be properly shredded or discarded as to maintain security and privacy of the data and materials.
  • Recycling
    Duquesne University complies with all existing rules and regulations regarding recycling.
  • Shredding
    Departments within Duquesne University utilize external vendors for the disposal of records through designated pick-up dates, times, and locations.
  • Storage Facilities, Campus and Off-Site
    Departments use their own discretion when determining where to maintain their respective records. Records are typically maintained on-site, but others may be housed at alternative locations.

VIII. Related Informatio

AACRAO Retention Schedule

Records Retention and Disposal Schedule  

University Procurement Office Vendor Risk Management Service Requirement 

University Procurement Office Policies and Procedures 

CTS Policies and Service Requirements 

CTS Data Governance Service Requirement

CTS Information Security Service Requirements

IX. Violations

Violations of this Policy will be reviewed on a case-by-case basis and are subject to formal disciplinary action up to and including termination of employment.

X. History

This policy was last updated in February 2025

XI. Ownership of Policy

Computing and Technology Services