AD35 - UNIVERSITY RECORDS FAQs

PURPOSE:  This FAQ provides answers to frequently asked questions related to the management of University records at Penn State University. Depending on the document type in question, an FAQ example may also direct users to the appropriate retention schedule for guidance (see the General Records Retention Schedule or the Financial Record Retention Schedule, as applicable).

Please refer to Penn State Policy AD35, University Archives and Records Management for full details. If you still have questions, contact University Archives or the Office of Records Management.

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• General Records
• Archival Records
• Human Resources Records
• Faculty Records
• Student Records
• Records Management Liaisons & Assistants
• Resources

A. GENERAL Records

1. Who is required to adhere to this policy? All University faculty, staff, and students as well as all University-related businesses and vendors. Failure to comply with the policy will be considered a violation of an employee’s service agreement and subject to discipline by the employee’s administrative area budget executive.




2. What is the retention schedule for? Retention schedules define how long a University Record must be kept, and provides guidelines for the final disposition of the record. Retention schedules for specific types of records can be found in the General Records Retention Schedule and the Financial Records Retention Schedule.
   
   1. What if I cannot find a retention schedule for a specific document? Contact the Office of Records Management and request assistance. Retention schedule additions, changes and subtractions are reviewed quarterly by the Records Management Advisory Committee.
   2. My document is just a copy, do I need to follow the retention schedule? The creator of the original is responsible for the full length of the retention schedules. All versions, copies, drafts, and formats of University records are transactional copies and may be destroyed earlier than the full retention period.
   3. Can I keep records for longer than the retention period? University records are only maintained beyond documented retention periods if they are designated as part of a litigation hold.
   4. Can I keep records for a shorter period than the documented retention period? If you are the Responsible Party of the record, no. If you are holding a transactional copy, yes.




3. Who do I contact with questions about which items are “University Records?” The Office of Records Management will help you determine which records are University Records and reviews all questions related to compliance with Policy AD35.




4. Who appoints a Records Management Liaison/Records Management Assistant for my Administrative area? The Financial Officer (FO) or Director of Business Services (DBS) appoints a Records Management Liaison for each administrative area. Large administrative areas may choose to create a Records Management Liaison Committee with Records Management Assistants assigned to specific tasks. See definitions section of AD35. Recommended duties and skill sets for Records Management Liaisons and Records Management Assistants are viewable here.




5. How can I organize my office records? Use the four-step protocol:

   STEP ONE: Determine the record retention schedule for the types of paper files, documents, records, databases, and reports that you manage.

   STEP TWO: Organize and purge the electronic files, documents, records, databases, and reports that you manage.

   STEP THREE: Organize and purge your physical office areas following the retention schedules.

   STEP FOUR:  Establish a pattern of using records retention schedules, make it a habit to organize and de-clutter, purge on a routine basis and maintain procedures to comply with AD35.

   For additional advice, contact the Office of Records Management.




6. How can I participate in the University’s Blue/White Shredding Program?  If you participate in the University’s Recycling Program, you are eligible to be scheduled for blue and white bag pick-ups. Blue bags contain confidential University records with Personally Identifiable Information (PII). White bags contain media such as CDs, DVDs, and microfilm. Contact the Office of Physical Plant, Recycling Office to schedule routine program participation or one-time clean-out assistance.




7. Are training resources and tools available to help individuals understand the policy? Monthly in-person and online training sessions are offered by the Office of Records Management. On-demand individual, office training sessions can be scheduled on an as-needed basis. Contact the Office of Records Management directly to schedule a training. Individual questions about the policy or retention schedules can be submitted via email for direct response.




8. How long does voicemail need to be retained? The University voicemail system stores voicemail for 90 days after accessed. The majority of voicemails will either fall under the definition of “non-record” or transitory. Non-records do not have a retention time due to a lack of content about University business and may be deleted immediately. Transitory records are only required to be retained for as long as they are needed for administrative purposes. There may be times when voicemail needs to be retained longer according to the retention schedule. Due to this, employees are encouraged to use other methods of communication to document business decisions that need to be retained longer than 90 days. In cases where voicemail is a longer-term record, employees must save the content by downloading and storing the voicemail, or transcribing the message.  If transcribing, employees need to include the caller, person contacted, transcriber (if different from person the contacted), date and time of call, and the general content of the message. If a business record is created on a personal device, employees must forward the record to a University system or transcribe the voicemail if retention is warranted.

B. ARCHIVAL Records

1. What is University Archives? University Archives serves as the institutional memory of Penn State. University Archives identifies, acquires, and maintains records of enduring historical value regardless of format.




2. What is an Archival Record? See Definition of Terms – Policy AD35 University Archives and Records Management.




3. How do I know if my office's records should be sent to University Archives? University Records that must be sent to University Archives will have met the scheduled retention period and will have “review by Archives” or “transfer to Archives” listed on the Records Retention Schedules. When in doubt, use the University Archives Transfer Request form to have your question answered by the University Archivist. For details on records that University Archives collects, please consult the Guidelines for University Office Records.




4. What does "review by Archives" mean on the retention schedule? Once University Records have met the scheduled retention period, the University Archivist needs to review the records to confirm it should be transferred to University Archives.




5. How many backup copies of archived information should be retained? Only the original or official copy of the record (listed in the “Responsible Party/System of Record” column on retention schedules) should be reviewed by or transferred to University Archives. All other copies of such records are transitory and must be securely destroyed once meeting the schedules retention period. Records identified on retention schedules as “review by Archives” or “transfer to Archives” must be transferred to University Archives via the University Archives Transfer Request form.




6. How do campuses and/or administrative areas send their records to University Archives? Contact University Archives via the University Archives Transfer Request form. The scheduled retention period must be met before any records can transfer to University Archives. Special arrangements can be made for Commonwealth Campuses to preserve archival records within their library, with appropriate approval.




7. How do I access records that have been transferred to University Archives? When records are sent to University Archives, the responsible party or office is transferring custody of the records to the Special Collections Library. The records are then managed under the Special Collections Library policies for preservation and access. University Records maintained in University Archives are closed to public access until twenty (20) years after their date of creation. Access to records at University Archives must be requested via the online catalog or by contacting the Special Collections Library.




8. What types of faculty papers or records are considered archival? University Archives collects papers of distinguished faculty members who have demonstrated significant contributions to their respective field. See the Guidelines for Faculty Papers for more information regarding donating faculty personal papers to University Archives.




9. What types of student records are considered archival? For privacy reasons, University Archives does not collect student records*. Student records often contain Personally Identifiable Information (PII), as well as financial information, grades, and other sensitive information that cannot be made available to researchers. While student records are not collected, University Archives seeks to document student life and experiences at Penn State; further information can be found on the Guidelines for Student Organization Records.
   • *University Archives provides restricted access and permanent preservation services for certain transcript records for the Office of the University Registrar and in accordance with AD11: University Policy on Confidentiality of Student Records.

C. HUMAN RESOURCES Records

NOTE: In some units using DocFinity, the Budget Executive's office manages the archive process. In order for this process to be successful, departments must ensure that all files with the status of ‘terminated’, ‘retired’, or ‘deceased’ have a termination date entered.

1. Since I send all full-time employee I-9s to Central OHR, do I need to keep copies? Records sent to or scanned into a centralized database/repository should NOT be retained locally.




2. What is the retention schedule for SRDPs, performance evaluations, and goal setting information? The retention schedule for performance evaluations in both formats is until separation of employment plus six (6) years.




3. What is the procedure for disposal of paper and electronic records when a current employee retires? Or dies? Prior to retirement, a current employee should create a directory for paper records or develop a shared drive for all electronic records (including e-mail) that will be utilized by their administrative unit upon their retirement. Within thirty (30) days of said retirement, the employee’s computer can be scrubbed and put back into use, unless subject to a litigation hold (then contact the Office of General Counsel).

   If a current employee dies prior to creating such a records use plan, the budget executive for the administrative unit, in consultation with local Human Resources, will assign an individual to work with the area’s Records Management Liaison or Records Management Assistant to review and manage paper records according to AD35 retention schedules and to coordinate efforts between local and central IT to identify and transfer electronic records.




4. Personnel Files for Faculty Employees-- How long should we keep the personnel files of faculty members? All faculty personnel files are to follow the same retention schedules and requirements of staff and wage payroll files. This includes fixed term faculty, standing faculty, department heads and administrators.




5. Personnel Files for Faculty, Staff and Wage Payroll Employees -- How long should we keep faculty, staff, and wage payroll personnel files? Faculty, staff, and wage payroll files must be destroyed (shredded, deleted or purged) six (6) years after the employee leaves the University (resignation, retirement, etc.). Central Human Resource files for retirees are maintained for six (6) years after benefits are closed.




6. Do we need to keep unit personnel files of staff or wage payroll employees now working in other units at the University? You should retain these files for six (6) years. After six (6) years you must shred or purge them. Personnel files of staff and wage payroll employees do not follow employees from one unit to another.




7. Search Committee materials
   
   1. To comply with Affirmative Action requirements, search committee materials for those not requiring visa or immigration sponsorship (including letters of recommendation, rankings, scorecards, resumes, cover letters, and email correspondence about, to and from the candidate) are maintained for three (3) years after the search is concluded or the application deadline. After three (3) years you must shred or purge them.
   2. To comply with Global Program requirements and federal regulations, search materials (including all materials for the person that was hired as well as all applicants) for a search that resulted in a candidate being hired that required visa or immigration sponsorship must be retained for five (5) years after the search is concluded or the application deadline.
   3. Personal notes about a candidate or taken during a search that are not part of an official ranking matrix or scorecard document as required by your Unit HR is unofficial and must be destroyed as soon as the search concludes. These notes are personal and can be subjective and do not reflect the opinion or position of the University.
   4. There are current Faculty Search COVID-19 Guidelines provided by the Office of the Vice Provost fo Faculty Affairs related to managing the process as well as any recording or documentation that are created via the Search process or Search Committee.




8. Visa and Immigration Paperwork – What happens to the paperwork that is housed in I-Start? The Office of Global Programs is required to adhere to numerous retention schedules because of the different Visa types, government departments, and issuing authorities. Global Programs follows the schedules closely and all their documentation is housed securely on a stand-alone server. Therefore, departments do NOT need to keep copies of immigration and visa paperwork. Transactional copies, outside of Global Programs, must be shredded or purged. Offices may keep a ‘working file’ for a short period of time, but must shred copies of the documentation as soon as possible.

D. FACULTY Records

1. Who is responsible for ensuring that faculty members are compliant with the policy? The Budget Executive will be responsible for documenting compliance for all faculty, staff and students within their administrative area.




2. The following documents are considered Faculty Personal Papers. They are NOT subject to retention periods NOR will they be maintained or managed in central administrative offices. (see the General Retention Schedule)
   • Articles or reprints are not permanent records and may be destroyed (shredded, deleted, or purged) three (3) years after the publication date. Faculty members are encouraged to deposit articles in ScholarSphere if they own the copyright or the article is open access.
   • Books and manuscripts are not permanent records, and retention is at the faculty member’s personal discretion and management.
   • Class syllabi are University Records and may be destroyed (shredded, deleted or purged) three (3) years after the course end date. Retention for longer periods of time is at the faculty member's personal discretion and management.
   • Class lists are not permanent records and may be destroyed (shredded, deleted or purged) three (3) years after the course end date. Retention for longer periods of time is at the faculty member’s personal discretion and management. However, all Personally Identifiable Information (PII), such as Social Security and student ID numbers MUST be redacted if faculty choose to keep copies for their personal use.
   • Letters of recommendation – Retain for three (3) years. After three (3) years they can be shredded or purged. Faculty who choose to retain these letters for longer periods of time do so as personal records.
   • Theses and dissertations are not the responsibility of faculty members; retention is at the faculty member's personal discretion and management. Note that University Libraries maintain one (1) electronic copy.




3. Can faculty members’ scholarly files be kept on University property after they have exceeded the retention period? Scholarly files are not considered University records so there is no retention period for them. They are the personal property of the faculty member. Faculty members are encouraged to utilize storage resources such as ScholarSphere for retention of scholarly files if they wish.




4. The following documents are considered University Records and are often in the possession of faculty, therefore, they are subject to retention periods and destruction afterwards is required:
   • Advisor files (3 years after graduation or 7 years after last student activity)
   • Correspondence, including email, that pertains directly to University business activities and decisions (3 years)
   • Correspondence not related to University or mass email announcements (destroy when no longer needed/useful)
   • Examinations and answer sheets (1 year after administered)
   • Class Recordings, including those in Teaching and Learning with Technology (TLT) systems, other learning management systems (3 years after last viewed; review by Archives)
   • Grade books, grade sheets, grade appeals (5 years after course completion)
   • Non-disclosure agreements (3 years after grant ends, unless otherwise mandated)
   • Search committee files, meeting minutes, correspondence with candidates (3 years after search concluded)
   • Conference, seminar, or workshop agendas that were hosted and/or grand-sponsored at Penn State (3 years after program completion; send one copy of program to University Archives)
   • University-related publications such as annual reports, bibliographies, biographies, vitas, newsletters, promotional literature, speeches, presentations, talks (submit one (1) copy to University Archives)




5. The following documents may or may not be in the possession of faculty members but are the responsibility of other units in the University for retention:
   • Class lists (maintained permanently by the Registrar’s Office)
   • Federal and non-federal grant applications (including rejected), interim publications, publications, products and final reports [NOTE: Publications and final reports can be submitted to the University Archives for permanent retention. Many funding agencies archive these documents electronically and are the record keeper for long-term retention.]
   • Licenses (including software) agreements
   • Research clearance forms (3 years after submission)
   • SRTEs (see Question 6)
   • Textbook orders (3 years after order completed)
   • Theses and dissertations (University Libraries maintain one (1) electronic copy; all other copies are transactional and considered faculty personal records)
   • Travel itineraries, expense forms and reservations (current +7 years)
   • Written candidacy and comprehensive examinations (7 years after last activity)




6. Retention of paper SRTEs (numerical and discursive forms) – The official SRTE record is centrally maintained in Penn State’s online instrument for gathering feedback from students at the end of the course. Summarized instructor reports are maintained in the SRTE tool per the Records Management Advisory Committee’s approved retention schedule. The retention time for the official record is ten years from the date of creation. SRTEs are used for various purposes, including but not limited to, promotion and tenure and annual performance reviews. If units utilize SRTEs for such purposes and file the copy in an official record such as a dossier, the retention time for that record series governs retention of that copy of the SRTEs. If a copy of an SRTE summary is not filed with another record series, it should be destroyed by shredding as soon as it is no longer needed because the records are accessible electronically in the SRTE tool. Due to the sensitive nature of SRTEs, confidential storage is required. Confidential storage in this instance means that access is limited to those in need of the information to perform their job duties.




7. Retention of paper ‘Instructional Activities Data Reports’ – The data contained in these reports is summarized and held elsewhere at the University, so these reports only need to be kept in the department for Promotion and Tenure processes. Shred reports that are older than five (5) years.  If older copies are offered back to faculty, be sure to inform them that they are responsible for confidential storage off-campus.




8. How long should I keep transactional emails (emails between students, faculty, colleagues, etc) that do not reach a conclusion or document a University decision? Should they be dealt with on a case by case basis, or can faculty simply delete all transactional emails? Faculty can choose to delete all transactional emails one (1) year after receipt, unless notified of cause for litigation hold.




9. How long should I keep an initial email from a student about a grade dispute that was then forwarded to the appropriate director and adjudicated through an official process? Retain for one (1) year after dispute has been settled or transferred.




10. Are the retention periods listed for each category of document the minimum retention periods or the maximum retention periods? Retention periods refer to the recommended time period after which records can be destroyed, must be transferred to the Archives, or revert to management as personal records. Minimum retention periods require destruction. Permanent record designations require transfer to the Archives. Records that will be maintained beyond retention recommendations as personal papers are no longer treated as University records.

E. STUDENT Records

1. Retention of documentation about a case of a student being terminated for unsatisfactory scholarship and intimidating behavior. How should we handle the retention on these documents?  These files are currently being maintained for review purposes in case of reapplication or employment. These records will be maintained for ten (10) years after the case is closed. 

   NOTE: Judicial Affairs records are maintained centrally.




2. Retention of paper copies of enrollment data (i.e. student credit by hour data reports) – The data contained in these reports is summarized and held elsewhere. Administrative area copies are retained for five (5) years.




3. Undergraduate Student Files – The official student record according to the Family Educational Rights and Privacy Act (FERPA) is the transcript. Transcripts are permanent records held within the University Registrar’s Office and the University Archives (depending on their age). All other undergraduate student records are not considered permanent files.

   NOTE 1: The five (5) year retention schedule for the complete undergraduate student record (containing multiple documents) supersedes the retention schedule for the individual documents contained within the file, unless otherwise mandated.

   NOTE 2: In some units using DocFinity, the Budget Executive's office manages the archive process. In order for this process to be successful, departments must ensure that all files with the status of ‘graduated or ‘withdrawn’ have a file close date entered.




4. Graduate Student Files – The retention schedule for the complete graduate student record (containing multiple documents) supersedes the retention schedule for the individual documents contained within the file.




5. Graduate Student Transcripts – Graduate student transcripts received from other institutions are filed and maintained by the Graduate School. If you wish to keep a copy for your own unit’s reference, you can scan or copy the transcript and retain it in the unit. If the transcript is an original, offer it back to the student. If the student does not want it, you should shred it. The Office of the University Registrar processes all requests for official transcripts for Penn State students. The Office of the University Registrar can also access student information via the student information system.

F. Records Management Liaisons & Assistants

1. Records Management Liaison (RML)– University employees assigned by a Financial Officer or Director of Business Services to serve as a conduit for policy, procedure, and information between the University Archives/Records Management Program and their respective administrative area. 




2. Records Management Assistant (RMA) – University employees designated to support the Records Management Liaison with specific responsibility for a unit or units within the administrative area.




3. What is the appropriate number of RMLs and RMAs per Campus, College, or Unit? There should be (1) RML per Campus/College/Unit, and the RML should assign (1) RMA for each sub-unit as needed. We recommend that an RMA represent the following areas of your Campus/College/Unit, when applicable:
   • Finance/Business Staff
   • Administration/Dean/Leadership Team (recommended RMAs include staff members in support roles, such as executive assistants and admin support coordinators)
   • Human Resources/Faculty Affairs Staff
   • Academic Affairs/Student Support Staff
   • Facilities Team
   • Grants and Contracts Staff
   • Research Team
   • Development Staff




4. Who appoints the RML? If you are located at University Park, the RML is appointed by your Financial Officer (FO), whereas the Director of Business Services (DBS) appoints RMLs at Commonwealth Campus locations.




5. Who appoints the RMAs? The RML appoints RMAs for every Department/Office/Program within their Campus/College/Unit. The FO or DBS should provide direction, support and assistance when appropriate.




6. How do I relinquish my duties as an RML or RMA? Please reach out to your RML and senior leadership, including your FO or DBS to make the proper notification. The Office of Records Management should also be notified when there is a change in roles.




7. Is there a list of the current RMLs? Yes. The current list of RMLs is located on the Records Management Liaison (RML) Description page.




8. Do I receive credit for being an RML or RMA? To receive credit for taking on these additional tasks, the duties and responsibilities of an RML or RMA can be added to the employee’s Job Responsibilities Worksheet (JRW).




9. Why are RMLs and RMAs needed? RMLs and RMAs help ensure the proper handling, retention, and destruction of University Records. These liaisons and assistants play a key role in maintaining compliance with Penn State policies along with state/federal laws and regulations.




10. Is specific training available for RMLs and RMAs? Yes. The Office of Records Management offers on-demand, in-person, and scheduled training. We can meet individually with an RML, conduct a group training with your Unit RM Team, or provide an info session to your Unit leadership. We are developing recorded trainings and handouts.

G. RESOURCES:

General Records Retention Schedule

Financial Records Retention Schedule

Office of Records Management

Records Center (IRC)

University Archives

Blue/White Shredding Program

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Most recent changes:

• May 12, 2020 - Added Archival Records section. Added links for the University Archives Transfer Request form as well as collecting guidelines for University Archives.
• April 6, 2020 - Added questions and answers for Records Management Liaisons & Assistants. Added links for Financial Officer (FO) and Director of Business Services (DBS).
• October 9, 2018 - Updated links to the Records Management and University Archives websites.

Revision History (and effective dates):

• June 12, 2018 - Added question on voicemail retention, and updated SRTE guidance.

• May 4, 2016 - New FAQ to summarize and support Policy AD35.