‫ב"ה‬
MICHIGAN JEWISH INSTITUTE
Policy and Procedure Manual
Functional Area:
Title:
RECORDS MANAGEMENT
Policy No.
RM 1198
Records Retention and Disposal
Effective Date: January 1, 2013
Page No.
1 of 12
GENERAL PURPOSE:
This policy is intended to provide a process and procedure that will insure the uniform
administration of all MJI records retention or disposal. This includes information
contained in both hard copy and electronic media. Hereinafter, all this material will be
referred to simply as “documents” or “records”.
The general purpose of this policy is to provide guidance for:
(a) retention and maintenance of documents necessary for the proper functioning of
MJI;
(b) compliance with applicable legal requirements;
(c) destruction of documents which no longer need to be retained; and,
(d) the Board of Trustees, officers, staff and other MJI constituencies with respect to
their responsibilities concerning document retention and destruction.
GLOSSARY OF SIGNIFICANT TERMS USED:
Destruction: The removal of records or documents from responsibility and oversight
by MJI in a non-recoverable manner. Paper documents are shredded; hard storage
items such as DVDs and CDs are shattered; and electronic records are overwritten in a
manner that they cannot be recalled.
Disposal: The removal of records or documents from responsibility and oversight by
MJI, typically by tossing them in the trash. For purposes of this policy, disposal is
synonymous with “Destruction” when referring to items of a confidential or private
nature.
Records and Documents: Official records and documents consist of all information
and data that are created or received by MJI in the course of performing its daily
activities, whether in physical or electronic form.
BACKGROUND/POLICY:
Revised:
Printed February 14, 2013
‫ב"ה‬
MICHIGAN JEWISH INSTITUTE
Policy and Procedure Manual
Functional Area:
Title:
RECORDS MANAGEMENT
Policy No.
RM 1198
Records Retention and Disposal
Effective Date: January 1, 2013
Page No.
2 of 12
Responsibilities of the Records Administrator:
MJI’s Senior Management shall appoint a “Records Administrator” (RA) from among
the middle management of the school. The named RA shall be in general charge of the
administration of this policy as it is implemented in each of MJI’s business divisions and
departments. The RA will supervise and coordinate the retention or disposal of
documents pursuant to the Document Retention Schedule exhibited below. The RA is
also responsible for reporting to Senior Management actions taken by MJI departments
to maintain or dispose of documents and records for which each department is
responsible. The RA will modify the Document Retention Schedule from time to time as
becomes necessary to comply with changing requirements of law and regulation or as
may be deemed appropriate by MJI Senior Management.
Various MJI divisions and departments may appoint individual members of their work
group to assist the RA in carrying out the responsibilities outlined by this policy.
Further, the RA may be authorized to periodically review this policy with MJI’s legal
counsel to insure that it remains correct and current.
Responsibilities of the MJI Community of Staff, Faculty and others:
All members of the MJI community who create or otherwise have access to MJI
documents and records should be oriented by the RA with respect to the secure and safe
retention or disposal of materials over which they maintain daily control. Once trained
by the RA or otherwise informed by this policy, the responsible members of the MJI
community are expected to routinely act in accordance with it.
The following guidelines will assist MJI staff, faculty and other relevant parties in
identifying those portions of their files that are appropriate for retention, for transfer to
MJI long term archives or for disposal in a safe and secure manner.
Original records and documents should be retained in the MJI office of origin according
Revised:
Printed February 14, 2013
‫ב"ה‬
MICHIGAN JEWISH INSTITUTE
Policy and Procedure Manual
Functional Area:
Title:
RECORDS MANAGEMENT
Policy No.
RM 1198
Records Retention and Disposal
Effective Date: January 1, 2013
Page No.
3 of 12
to the retention schedule shown below. Copies of these originals located elsewhere in
MJI should be disposed of when no longer needed. When certain retained records
become of historical interest only (such as outdated Academic Catalogs), they should be
sent to MJI’s physical or digital archives with an explanation of their long term
importance.
General Staff Responsibilities:
1. It is the responsibility of every employee to comply with this policy.
2. It is the responsibility of any individual who supervisors, manages, or directs a department or
function to ensure their employees are aware of the policy and adhere to it.
3. It is the responsibility of each member of MJI’s Senior Management to ensure their respective
areas are in compliance with this policy so that MJI may meet its operational and legal obligations and
preserve its historical record.
Document Creation and Typing:
The RA will discuss with MJI staff and faculty the ways in which documents are created
or generated. With respect to relevant members of the MJI community and their
functions, the RA will determine whether documents are created which can be easily
typed (categorized) and segregated from others, so that, when it comes time to destroy
(or retain long-term) those documents, they can be easily culled from the others for
disposition.
For example, are individuals e-mails and other documents of a non-sensitive nature so
that they might be deleted from time to time, even in the face of a “hold” with respect to
other, more sensitive, documents? This dialogue may help in achieving a major purpose
of this policy -- to conserve MJI storage resources -- by identifying document streams in
a way that will allow for the routine disposal/destruction of documents. Ideally, MJI
will create and archive documents in a way that can readily identify them and
dispose/destroy documents with similar expiration dates.
Revised:
Printed February 14, 2013
‫ב"ה‬
MICHIGAN JEWISH INSTITUTE
Policy and Procedure Manual
Functional Area:
Title:
RECORDS MANAGEMENT
Policy No.
RM 1198
Records Retention and Disposal
Effective Date: January 1, 2013
Page No.
4 of 12
Retention of Electronic Records and Documents and their Integrity:
Documents in electronic form are maintained just as hard copy or paper documents are,
in accordance with the Document Retention Schedule. Due to the fact that the integrity
of electronic documents, whether with respect to the ease of alteration or deletion, or
otherwise, may come into question, the RA will establish and maintain standards for
document integrity, including guidelines for handling electronic files, backup
procedures, archiving of documents, and regular audits of the reliability of MJI
electronic data systems; provided, that such standards shall only be implemented to the
extent that they are reasonably attainable considering MJI resources and other
priorities.
Emergency Planning:
Documents shall be stored in a safe and accessible manner. Documents which are
necessary for the continued operation of MJI in the case of an emergency shall be
regularly duplicated or backed up and maintained in an off-site location. The RA shall
develop reasonable procedures for document retention in the case of an emergency.
Transfer to Archives:
After the specified retention period (see Process, below) in the office of origin, items of
historical value should be transferred to the MJI Archives.
Records commonly transferred to the Archives:
1. Constitutions and bylaws, minutes and proceedings, transcripts, lists of officers and
committees, offices, and departments
2. Office and department files: correspondence and memoranda (incoming and
outgoing), annual reports, subject files concerning projects, activities, and functions
Revised:
Printed February 14, 2013
‫ב"ה‬
MICHIGAN JEWISH INSTITUTE
Policy and Procedure Manual
Functional Area:
Title:
RECORDS MANAGEMENT
Policy No.
RM 1198
Records Retention and Disposal
Effective Date: January 1, 2013
Page No.
5 of 12
3. Historical files documenting policies, decisions, committee and task force reports,
questionnaires
4. Publications: six record copies and 3 circulating copies of all monographs,
newsletters, journals, brochures, programs, and posters issued by MJI
5. Audiovisuals: photographs, films, and sound and video recordings
6. Personal papers of students, faculty, and staff that relate to MJI work.
When materials are transferred to long term storage they should be kept in the order in
which they were created and maintained in the campus office. A cover letter or memo
briefly identifying the material and describing the activity to which it relates should
accompany the transferred records anddocuments.
In the absence of specific restrictions, all materials transferred to MJI’s long term
storage will be opened to researchers on a nondiscriminatory basis, except those records
that contain individually identifiable information, the disclosure of which is prohibited
by the Family Educational Rights and Privacy Act of 1974. Records preserved in the
Archives may be borrowed by MJI office personnel on an as-needed basis and then
returned to storage.
Personnel responsible for long term storage should retain electronic records of
permanent or enduring value in formats and with migration schedules to maximize the
future accessibility of their content. Routine data backup is not a substitute for placing
electronic records with permanent value in electronically based long term storage.
The lists provided in this policy are intended as a general guide. If questions arise about
records and documents not listed here or questions about the retention or disposal of
specific records series, or whether particular records have permanent or enduring value,
you should consult with your immediate supervisor.
Note: All information formats (e.g., printed, published, typescript, audiovisual, and
electronic data such as computer drives, disks and files) are appropriate for
consideration for transfer to long term storage. Documents in formats requiring any
Revised:
Printed February 14, 2013
‫ב"ה‬
MICHIGAN JEWISH INSTITUTE
Policy and Procedure Manual
Functional Area:
Title:
RECORDS MANAGEMENT
Policy No.
RM 1198
Records Retention and Disposal
Effective Date: January 1, 2013
Page No.
6 of 12
form of machine intervention, such as videotapes and all computer files, should be
converted to a format anticipated to be accessible into the foreseeable future. Early
consultation with the MJI IT Department is strongly encouraged for such materials.
Disposal:
Disposal of records which have been maintained pursuant to this policy and which need
not be archived or kept should be destroyed. Current regulations require that any
sensitive or identifying personal information existing in such records (such as social
security number, driver's license number, mother's maiden name, account number or
code, or personal financial information) be disposed of in a manner that will prevent
unauthorized individuals from accessing the information.
Suspension of Document Disposal/Destruction:
MJI becomes subject to a duty to preserve and halt the disposal/destruction of
documents and records once litigation, an audit or a government investigation is
reasonably anticipated. The RA will insure the protection of documents and records
once they are so encumbered.
Whenever the RA becomes aware that litigation, a governmental audit or a government
investigation has been instituted, or is reasonably anticipated or contemplated, s/he will
immediately order a halt to all document disposal or destruction under this policy,
communicating the order to all affected members of the MJI community in writing.
If any board member, Senior Manager or staff member becomes aware that litigation, a
governmental audit or a government investigation has been instituted, or is reasonably
anticipated or contemplated, with respect to MJI, and they are not sure whether the RA
is aware of it, they shall immediately make the RA aware of it so that a timely
communication to staff may ensue.
Senior Management may thereafter amend or rescind the order only after conferring
with legal counsel.
Revised:
Printed February 14, 2013
‫ב"ה‬
MICHIGAN JEWISH INSTITUTE
Policy and Procedure Manual
Functional Area:
Title:
RECORDS MANAGEMENT
Policy No.
RM 1198
Records Retention and Disposal
Effective Date: January 1, 2013
Page No.
7 of 12
Failure to comply with this policy, including, particularly, disobeying any destruction
halt order, could result in possible civil or criminal sanctions. In addition, for staff,
faculty and students, it could lead to disciplinary action including possible termination.
PROCESS:
Document Retention Schedule. Periods are suggested but are not necessarily a substitute
for counsel’s own research and determination as to appropriate periods.]
Document Type
Retention Period
Accounting and Finance:
Accounts Payable
Accounts Receivable
Annual Financial Statements and Audit Reports
Bank Statements, Reconciliations & Deposit Slips
Canceled Checks – routine
Canceled Checks – special, such as loan repayment
Credit Card Receipts
Employee/Business Expense Reports/Documents
General Ledger
Interim Financial Statements
7 years
7 years
Permanent
7 years
7 years
Permanent
3 years
7 years
Permanent
7 years
Contributions/Gifts/Grants:
Contribution Records
Documents Evidencing Terms of Gifts
Grant Records
Permanent
Permanent
7 yrs. after end of grant period
Corporate and Exemption:
Articles of Incorporation and Amendments
Bylaws and Amendments
Minute Books, including Board & Committee Minutes
Annual Reports to Attorney General & Secretary of State
Other Corporate Filings
IRS Exemption Application (Form 1023 or 1024)
Permanent
Permanent
Permanent
Permanent
Permanent
Permanent
Revised:
Printed February 14, 2013
‫ב"ה‬
MICHIGAN JEWISH INSTITUTE
Policy and Procedure Manual
Functional Area:
Title:
RECORDS MANAGEMENT
Policy No.
RM 1198
Records Retention and Disposal
Effective Date: January 1, 2013
IRS Exemption Determination Letter
State Exemption Application (if applicable)
State Exemption Determination Letter (if applicable)
Licenses and Permits
Employer Identification (EIN) Designation
Page No.
8 of 12
Permanent
Permanent
Permanent
Permanent
Permanent
Correspondence and Internal Memoranda:
Hard copy correspondence and internal memoranda relating to a particular document otherwise
addressed in this Schedule should be retained for the same period as the document to which they relate.
Hard copy correspondence and internal memoranda
relating to routine matters with no lasting significance
Two years
Correspondence and internal memoranda important to
MJI or having lasting significance
Permanent
Electronic Mail (E-mail) to or from MJI:
Electronic mail (e-mails) relating to a particular document otherwise addressed in this Schedule should be
retained for the same period as the document to which they relate, but may be retained in hard copy form
with the document to which they relate.
E-mails considered important to MJI or of lasting significance should be printed and stored
in a central repository .
Permanent, subject to review
E-mails not included in either of the above categories
12 months
Electronically Stored Documents:
Electronically stored documents (e.g., in pdf, text or other electronic format) comprising or relating to a
particular document otherwise addressed in this Schedule should be retained for the same period as the
document which they comprise or to which they relate, but may be retained in hard copy form (unless the
electronic aspect is of significance).
Electronically stored documents considered important
to MJI or of lasting significance should
be printed and stored in a central repository (unless
the electronic aspect is of significance).
Permanent, subject to review
Electronic Accounting Records, all
Permanent
Revised:
Printed February 14, 2013
‫ב"ה‬
MICHIGAN JEWISH INSTITUTE
Policy and Procedure Manual
Functional Area:
Title:
RECORDS MANAGEMENT
Policy No.
RM 1198
Records Retention and Disposal
Effective Date: January 1, 2013
Page No.
9 of 12
Electronically stored documents not included in either
of the above categories
Two years
Employment, Personnel and Pension:
Personnel Records
Employee contracts
Retirement and pension records
Employment tax records
10 yrs after employment ends
10 yrs after termination
Permanent
4 yrs after due or paid, whichever later
Insurance
Property, D&O, Workers’ Compensation and
General Liability Insurance Policies
Insurance Claims Records
Permanent
Permanent
Legal and Contracts:
Contracts, related correspondence and other
supporting documentation
Legal correspondence
10 yrs after termination
Permanent
Management and Miscellaneous:
Strategic Plans
Disaster Recovery Plan
Policies and Procedures Manual
7 years after expiration
7 years after replacement
Current version with revision history
Property – Real, Personal and Intellectual:
Property deeds and purchase/sale agreements
Property Tax
Real Property Leases
Personal Property Leases
Trademarks, Copyrights and Patents
Permanent
Permanent
Permanent
10 years after termination
Permanent
Tax:
Tax exemption documents & correspondance
IRS Rulings
Annual information returns – federal & state
Tax returns
Permanent
Permanent
Permanent
Permanent
Business Office:
Revised:
Printed February 14, 2013
‫ב"ה‬
MICHIGAN JEWISH INSTITUTE
Policy and Procedure Manual
Functional Area:
Title:
RECORDS MANAGEMENT
Policy No.
RM 1198
Records Retention and Disposal
Effective Date: January 1, 2013
Page No.
10 of 12
Student Tuition Accounts
Student Tuition Account File
Financial Aid Documents, all
Correspondence
Withdrawals Notices
7 years
7 years
4 years after last date of attendance
7 years
7 years
Outside Scholarship Information
Financial Aid Transmittal Reports
Billing Records
Cash Receipts
Accounts Receivable Subsidiary Ledger
FISAP
7 years
7 years
7 years
7 years
7 years
Permanent
Student Loan Accounts:
Student Loan File
Original Promissory Notes
Repayment Schedules
Personal & Confidential Information
Correspondence
Deferment Forms
Account Summaries
Bank Reconciliations
Account Reconciliations
AFSA Reports
4 years after last date of attendance
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Academic Administration:
Harassment/Sexual Misconduct Records
The Chair shall keep only such Records
as are needed for the Board's SemiAnnual Report. MJI’s President shall
keep all information for 6 Years
Judicial Files
Cases of suspension or expulsion are
kept indefinitely. Cases reported to the
Department of Education are kept for 7
years; all others are retained until
student graduates.
Honor Court
Cases involving suspension or expulsion
are retained indefinitely. All others are
Revised:
Printed February 14, 2013
‫ב"ה‬
MICHIGAN JEWISH INSTITUTE
Policy and Procedure Manual
Functional Area:
Title:
RECORDS MANAGEMENT
Policy No.
RM 1198
Records Retention and Disposal
Effective Date: January 1, 2013
Page No.
11 of 12
destroyed one year after the student's
graduation.
File on every Current Student, which Contains Application, SAT Scores, HS Transcripts, Notes about the
Student, Academic Warnings, other Important Information
4 Years after graduation
Campus Safety Incident Reports
7 years
Dean of Faculty:
Annual Reports
Permanent
Tenure and Promotion Files:
Recommendations, Evaluations, Materials submitted for Promotion or Tenure (Approval or
Recommendations, Tenure Appeals and Pertinent Correspondence)
Permanent
Committee Files: Agenda, Minutes, Correspondence,
Reports for Committees that are not Institute-Wide
Standing Committees
Department Files
Conference Files
Correspondence dealing w/Policy and/or Programs
Correspondence dealing with Fiscal Matters
Correspondence that is not Policy, but Informative
Records that Document Policies
Permanent
Legal Cases
Budget Information: Budget Requests and
Budget Worksheets and Files
Faculty Meeting Minutes
Department Reviews
Faculty Fellowships/Leaves
Foundation Files/Endowment Funds
Non-Hires Faculty: Applications, Resumes, Etc.
Copies of Teaching Evaluations
6 Years after Final Settlement
Personnel Files of Terminated/Retired Faculty
Personnel Files of Administrators
Numeric evaluations
Affirmative Action Position Applicant Files
Revised:
Permanent
Permanent
3 Years
Permanent
3 Years
3 Years
Permanent
3 Years
Permanent in Archives
Permanent
Kept until Faculty Leaves
10 Years
3 Years
Retain until Full Professor status
is granted. Full Professor - 3 Years
Permanent
While active plus 5 Years
Permanent
6 Years
Printed February 14, 2013
‫ב"ה‬
MICHIGAN JEWISH INSTITUTE
Policy and Procedure Manual
Functional Area:
Title:
RECORDS MANAGEMENT
Policy No.
RM 1198
Records Retention and Disposal
Effective Date: January 1, 2013
Search Committees
Page No.
12 of 12
3 Years
AUTHORIZATIONS: (at least one signature is necessary to enact this
policy/procedure)
_______________________________
President
Revised:
______________________________
Dean Of Academic Administration
Printed February 14, 2013