DISPOSITION OF RECORDS When the retention requirement has been met for records, the department (with assistance from the RMLO) will determine how to dispose of those records. A decision will be made as to whether a disposition approval form is required. Shredding is a requirement for all records that contain sensitive and/or confidential information, see list below. A Disposition Approval Form is NOT required for: 1) Record copies with a retention designation of OSA (obsolete, superseded or administrative value is lost) such as: 1. Administrative Support Records – GS1 – SL #3 2. Drafts and Working Papers – GS1 – SL #242 3. Mailing Lists – GS1 – SL # 29 4. Operational and Statistical Report Records – GS1‐ SL#124 5. Staff Administration Records – GS1 – SL #371 6. Transitory Messages – GS1 – SL #146 7. Course and Program Records – GS5 #50 8. ID records : No fee Paid ‐ GS 5 #67 9. Procedures Manual – GS 5 #22 10. Student Profile Analysis – GS5 #32 2) Duplicate copies with a retention period of OSA (obsolete, superseded or administrative value is lost) Please note this lists only the most common records. Refer to the applicable state retention schedule or the University RMLO for more detailed information. If documents do not need a disposition form, you may recycle or shred those documents, but if the documents contain confidential or sensitive information they must be shredded. This is a partial list of sensitive and/or confidential information: •
•
Sensitive information: o UIN numbers o Payroll information o ID Records o Evaluations Confidential information: o Social Security numbers o Medical information o Legal information o FERPA (Ref. FGCU Policy 3.006) student education records o Financial, loan info o Bank account numbers, includes checks (original & copies) o Credit card information o Security and Emergency plans The University RMLO will provide shredding services as needed. For disposition of all records that aren’t designated as OSA, a Records Disposition Approval Form must be completed. See the form on our web page along with instructions for completing the form: http://www.fgcu.edu/crrm/records.html After the records disposition form has been completed, forward to the University RMLO for review and approval. The RMLO will provide assistance in determining the best method of disposal. Calculating Records Disposition Eligibility Dates Calendar year – Jan. 1 thru Dec. 31
If a record has “3 calendar years” retention, the disposition eligibility date would be 3 years after the end of the
calendar year of the last record in the series. Example: You have records dated Apr 2006 – Oct 2010, with 3
calendar years retention period, at end of calendar year 2009 destroy Apr thru Dec 2006 records only.
Fiscal year
FGCU’s fiscal year is from July 1 – June 30
If a record has “3 fiscal years” retention, the disposition date would be 3 years after the end of the fiscal year of the
last record in the series. Example: You have records dated Apr 2006 – Oct 2010, with 3 fiscal years retention period,
on July 1, 2009, destroy Apr 2006 thru June 2006 records only.
If your department follows a different fiscal year, please notify RMLO the fiscal year and governing authority.
Months or days
Examples: 3 months; 90 days: Last date in record series is April 15, 2009, add 90 days or 3 months, so destruction
eligibility date would be on July 15, 2009. No need to wait until end of month or end of year.
OSA – Retain until obsolete, superseded, or administrative value is lost.
With this retention, a record is eligible for disposition whenever it is no longer of any use or value to the agency. The
retention could vary from less than one day to any length of time thereafter.
Triggering event – Records become eligible for disposition upon or after a specific triggering event. Examples:
•
5 yrs after student transfers or withdraws
•
Retain for life of the structure.
•
3 anniversary years after final action.
Calculating Eligibility Dates
Example: Let’s say that the ending date for a specific record series is 7/31/2007. When are these records eligible for
disposition under different retention period types?
Retention Period
Date to start
Add # of years
Date eligible for
disposition
counting
3 anniversary years
7/31/2007
+3
= 7/31/2010
3 fiscal years (FGCU)
7/1/2008
+3
= 7/1/2011
3 calendar years
1/1/2008
+3
= 1/1/2011
Remember that even though your records may be filed according to one type of “year” – the state retention
schedule “year” is what must be followed.
Example: Admissions keeps a file by academic year for
administrative purposes. However, the retention period is by calendar year. Disposition and/or destruction
must be based on calendar year.