RECORDS RETENTION, RELEASE AND DISPOSAL POLICYPOLICY STATEMENT
UAT’s Records Retention, Release and Disposal Policy (“Records Policy”) is drafted to comply with UAT’s requirement to retain financial aid applications and supporting awarding and payment documentation for a specified period of time after the student receives the aid. In addition, UAT must retain academic transcripts indefinitely, and retain other records as required by federal or state law or in accordance with UAT policy.
UAT’s Records Policy is also drafted to comply with various federal and state regulations for the release and disposal of covered records, including under FERPA and GLBA.
This Records Policy outlines the various records retention and release requirements UAT personnel must be aware of and follow in order to be in compliance with federal and state law and UAT policy. These records must be maintained and disposed of according to procedures that are outlined in this Records Policy.
The Chief Technology Officer is responsible for developing and implementing policies governing the retention and disposal of UAT’s records. The Chief Technology Officer will designate others, on an as needed basis, to assist in implementing the record retention policy, including the following:
- Identify and evaluate which records should be retained;
- Publish a retention and disposal schedule that is in compliance with applicable laws;
- Monitor applicable laws affecting record retention;
- Annually review the record retention and disposal program;
- Develop a training program for personnel responsible for record storage and disposal;
- Monitor for compliance with the record retention and disposal program.
Each identified working group will examine the documents listed in the Records Retention Policy for their departmental function to determine whether the records described are an accurate representation of that department’s records. Requests for changes in retention periods or deviations from specified retention periods, or requests to modify the listed documents, should be made to the Chief Technology Officer, and may be implemented only after approval by Senior Leadership.
In the event of a governmental audit, investigation, or pending litigation, record disposal may be suspended at the direction of the Chief Technology Officer, or COO, or CEO.
ACT = while active, employed, or enrolled
LIFE = life of affected employee
ENROL = term of enrollment
STND = standard period, 15 years from date document was created
PERM = permanent
Click HERE to review the full list of record types and their respective retention periods (link opens PDF in new window).
Generally, records may be maintained in electronic or paper format and may be maintained in the original format the document was received or created in. Records should be kept in a systematically organized and retrievable manner to allow for retrieval in an organized and efficient manner.
Any special requirements, as listed herein, must be followed.
SPECIAL REQUIREMENTS FOR FSA RECORDS1. FSA Formats for Record Retention
A school must maintain all required records in a systematically organized and retrievable manner. Unless a specific format is required, a school may keep required records in hard copy, microform, computer file, optical disk, CD-ROM, or other media formats. Regardless of the format used to keep a record, all records (except ISIRs) must be retrievable in a coherent hard copy format. A coherent hard copy format includes, for example, an easily understandable printout of a computer file.
Any document that contains a signature, seal, certification, or any other image or mark required to validate the authenticity of its information must be maintained in its original hard copy or in an imaged media format. This includes tax returns, verification statements, certifications, and SARs used to determine eligibility. A school may maintain a record in an imaged media format only if the format is capable of reproducing an accurate, legible, and complete copy of the original document. When printed, the copy must be approximately the same size as the original document.
The SAR or ISIR must be kept in the format in which it was received by the school, except that a paper SAR may be maintained in either a hard copy or imaged media format. CUNY has the ability to preserve the ISIR data that it has maintained during the award year by archiving the data to a disk or other computer format.
Schools that participate in FSA programs must cooperate with the agencies and individuals involved in conducting any audit, program review, or investigation authorized by law by providing timely access to the requested records for examination and/or copying.2. Special requirements for SARs and ISIRs
Special maintenance and availability requirements apply for SARs and ISIRs used to determine eligibility. It is essential that these basic eligibility records be available in a consistent, comprehensive, and verifiable format for program review and audit purposes.
Hard copies of SARs that students submit to schools must be maintained and made available in their original format or in an imaged media format. The ISIR, an electronic record, must be maintained and made available in its original format (e.g., as it was archived using EDExpress software supplied to the school). A school that uses EDExpress has the ability to preserve the ISIR data that it has maintained during the applicable award year by archiving the data to a disk or other computer format.
RELEASE OF RECORDS
Records may only be released in accordance with UAT’s FERPA policy, with the permission of the student. With written request, records may also be released in response to a legally issued subpoena and, under other limited exceptions, without obtaining the student’s consent. If a verbal request for records is made by the student or an authorized party on the FERPA release form, identity is verified by asking the caller to confirm their name and home address on the form.
DISPOSAL OF RECORDS
1. Paper Records
Documents should be retained for the duration of the retention period, and longer is required as a result of a litigation hold or other extension. If, after consulting with the Chief Operating Officer or CEO, it is timely and appropriate to dispose of any records, they should be destroyed by depositing the paper in a locked receptacle to be disposed of via shredding or otherwise destroying it in an approved manner that will prevent access to confidential paper information.
Electronic records, including emails, must be treated in the same way as paper records. Retention and disposition of electronic records depend on the function and content of the individual record.
Electronic records that are created electronically, or converted to electronic records, should be maintained as electronic records. University email is considered a University record, except for personal email. Emails should be kept in electronic format.
Individuals who keep records in electronic format must maintain those records in electronic format, which can be transferred, as directed by the individual's department head, to SharePoint or another cloud-based system put in place and approved by UAT’s Information Technology Department Head.
Electronic records may be disposed of by erasing or deleting the record or otherwise destroying electronically stored data as approved by UAT’s Information Technology Department Head.
In some cases, electronic data may not be disposed of without affecting other data, in which case the record retention period will be waived to allow for the preservation of any related data that would otherwise be affected and disposed of prior to the end of the applicable data retention period.
In some cases, electronic data is not able to be erased or deleted, based on the requirements or limitations of the software or hardware used. In this case, the record retention period will be waived to account for the limitations on the disposal of data.
REVISED APRIL 2023