APS 2006 - Retention of University Records

PDF Version

Policy Profile

Policy Title: Retention of University Records
APS Number: 2006
Effective: April 1, 20121
Approved by: President Bruce D. Benson
Responsible University Officer: Senior Vice President and Chief of Staff
Responsible Office: Office of Policy and Efficiency
Policy Contact: Office of Policy and Efficiency 303-860-5711
Supersedes: Retention of University Records, December 1, 2007 (with non-substantive edits May 2, 2010)
Last Reviewed/Updated: April 1, 2012
Applies to: This policy is applicable to all university employees and employees of affiliates who create, maintain, and/or dispose of university records, as defined herein.

Policy Snapshot

Brief Description: This policy establishes the principles and processes for the retention and disposal of university records, outlines the roles and responsibilities associated with this process, and provides records retention schedules for the university.

Reason for Policy: This APS establishes a university-wide retention policy and detailed retention schedules to be in compliance with state law and best industry standards.

I.  Introduction

This policy establishes university principles and processes for the retention and disposal of university records and outlines the roles and responsibilities associated with this process, as required by C.R.S. §24-72-201 et seq. (2009).  It includes detailed university-wide records retention schedules.

The University of Colorado is committed to the retention of its records in order to meet legal requirements, optimize use of space, minimize cost, preserve the history of the university and destroy outdated and useless records.  This policy identifies certain records that must be retained for specific periods of time and designates official repositories for their maintenance.

II.  Policy Statement

A.  University records must be managed as outlined herein.

  1. All university records are the property of the University of Colorado regardless of their physical location, even when they are in the possession of individuals, and, as such, may not be permanently removed from the university nor destroyed except in accordance with this policy.
  2. University record means any tangible recording of information, regardless of the means of recording, relating to the conduct of university business that is created, prepared, owned, used, or maintained by an operating unit or employee of the university, including all books, papers, maps, photographs, cards, tapes, recordings, or other documentary materials recorded by handwriting, typewriting, printing, photostating, photographing, photocopying, transmitting by electronic mail or facsimile, and every other means of recording upon any tangible thing any form of communication or representation, including letters, words, pictures, sounds, or symbols, or combination thereof, and any record thereby created, regardless of the manner in which the record has been stored.
    University record does not include:
    1. Materials preserved or appropriate for preservation because of the historical value of the materials;
    2. Library books, pamphlets, newspapers, or museum material made, acquired, or preserved for reference, historical, or exhibition purposes;
    3. Private papers, manuscripts, letters, diaries, pictures, biographies, books, and maps, including materials and collections previously owned by persons other than the state or any political subdivision thereof and transferred by them to the state historical society;
    4. Non-records, as defined herein.  Non-record means a record that is of immediate value only.  Non-records may share some characteristics with university records; however, they are distinguished from university records by their transitory usefulness.  Non-records may include envelopes, routing slips, data entry- and work-sheets, rough drafts, multiple copies of publications, blank forms, unofficial (“informational,” “courtesy” or “convenience”) copies of records, and notes and audio recordings that have been transcribed.  Non-records may also include duplicates which are maintained for convenience by a person or office who is not the originator or recipient (including copied recipient) of the record and electronic mail of temporary value.
  3. University records shall be maintained in a medium owned or controlled by the university.  If the University does not offer a practical solution, (as determined by the campus information resource oversight authority) records may be maintained on outsourced IT services (such as web sites, web-based documents or social media sites), as long as departments seek approval from the campus Information Security Officer to ensure that vendor contracts and/or terms of service meet University standards.  The Chief Information Security Officer will publish a list of outsourced IT services approved by the campus Information Security Officers.  University business conducted, or university records stored, on outsourced IT services, including private electronic mail accounts may constitute a public document subject to disclosure under the Colorado Open Records Act or a litigation discovery request, subpoena, or court order.

B.  Roles and Responsibilities

  1. The senior vice president and chief of staff, or her/his designee, has university responsibility for overseeing the establishment of a records management program that is consistent with this policy.
  2. The senior vice president and chief of staff and the campus chancellors shall designate records management coordinators for their respective units.
  3. The records management coordinators are responsible for the development, coordination, implementation and management of the program at that location.  Implementation includes promulgating campus wide rules and procedures and providing advice, information, and training, as necessary, to local personnel regarding records management.  The campus records management coordinator is appointed by each campus chancellor and is responsible for establishing appropriate records management practices on the campus. Campus questions regarding this program shall be directed to the campus records management coordinator.
  4. The senior vice president and chief of staff, or her/his delegate, shall be the chair of the University Records Management Committee which shall consist of the records management coordinator for each of the campuses.
  5. The Records Management Committee is charged with providing guidance and procedures for implementing this policy, including the development and maintenance of the university-wide retention schedules.
  6. Record keepers, which can be individual persons or organization units, are responsible for maintaining university records.

C.  Retention of university records

  1. University records must be categorized and grouped according to the functional purpose they serve.  
  2. Records management coordinators (see roles and responsibilities in section B), or their delegates, must review all categories of university records under their control as necessary and must assign a retention period in accordance with their campus retention schedule (See IV.B. below), except as set forth herein.
  3. Once the retention period set forth in the retention schedule has expired, university records must be disposed in accordance with Section II.D, herein, unless:
    1. The individual or unit is aware of an applicable state or federal law that requires that the university record in question be retained for a longer period than set forth in the retention schedule;
    2. The university record has been requested pursuant to the Colorado (Public) Open Records Act;
    3. The university record has been requested in any legal proceeding or is deemed likely to be requested in any legal proceeding as determined by legal counsel;
    4. The university record is needed to perform current or future activities in support of the administrative functions for which an operational unit is responsible;
    5. The university record contains evidence of legally enforceable rights or obligations of the University; or
    6. The university record is needed to fulfill statutory and regulatory requirements or a business purpose of a unit.
  4. Absent a controlling law or retention period as set forth by the retention schedule, university units may create their own schedules in accordance with the unit’s needs.  Units may specify retention periods that are longer, but not shorter than, the University Retention Schedule. To the extent practicable, university unit schedules should be maintained in writing.
  5. The retention period is satisfied by retaining an electronic record of the information that accurately reflects the information set forth in the record and remains accessible for later reference.

D.  Disposal Procedures

  1. When the prescribed retention period for the university record has passed, the university record should be disposed of properly.  If there is no prescribed retention period, the university record should be disposed when it has outlived its business purpose usefulness, as determined by the record keeper.  The means of disposal may be determined by the university unit in possession of the university record, but must take into account the nature of the record contents.
  2. Confidential or personal records, e.g., records containing personally identifiable information, trade secrets, personal or sensitive financial information, research results, or records subject to any privilege, such as attorney-client, must be rendered irretrievable and illegible by shredding or by other means.
  3. Non-records may be disposed of at the discretion of the record keeper However, those non-records meeting the definition of Section II.D.2. above, must be rendered irretrievable and illegible by shredding or by other means.

III.  Definitions

Italicized terms used in this Administrative Policy Statement (APS) are defined in the APS Glossary, or are defined below:

  1. Record keeper(s):  Any person(s) or organizational unit(s) responsible for maintaining a university record.
  2. University records:  means any tangible recording of information, regardless of the means of recording, relating to the conduct of university business that is created, prepared, owned, used, or maintained by an operating unit or employee of the university, including all books, papers, maps, photographs, cards, tapes, recordings, or other documentary materials recorded by handwriting, typewriting, printing, photostating, photographing, photocopying, transmitting by electronic mail or facsimile, and every other means of recording upon any tangible thing any form of communication or representation, including letters, words, pictures, sounds, or symbols, or combination thereof, and any record thereby created, regardless of the manner in which the record has been stored. 

    University record does not include:
    1. Materials preserved or appropriate for preservation because of the historical value of the materials;
    2. Library books, pamphlets, newspapers, or museum material made, acquired, or preserved for reference, historical, or exhibition purposes; or
    3. Private papers, manuscripts, letters, diaries, pictures, biographies, books, and maps, including materials and collections previously owned by persons other than the state or any political subdivision thereof and transferred by them to the state historical society.
  3. Non-record:   means a record that is of immediate value only.  Non-records may share some characteristics with university records; however, they are distinguished from university records by their transitory usefulness.  Non-records may include envelopes, routing slips, data entry- and work-sheets, rough drafts, multiple copies of publications, blank forms, unofficial (“informational,” “courtesy” or “convenience”) copies of records, and notes and audio recordings that have been transcribed.  Non-records may also include duplicates which are maintained for convenience by a person or office who is not the originator or recipient (including copied recipient) of the record and electronic mail of temporary value. 

IV.  Related Policies, Procedures, Forms, Guidelines and Other Resources

  1. Frequently Asked Questions (FAQs)
  2. University Retention Schedules:
  3. Records Management Coordinators (By Campus):

V.  History

    • Original policy effective July 1, 2007
    • Revised December 1, 2007
    • Non-substantive edits were made on September 3, 2008, May 2, 2010 and September 15, 2011.
    • Revised April 1, 2012
    • The title of “IT Security Principals” was replaced with the title of “Information Security Officers” effective May 1, 2014.

VI.  Key Words

Archives, storage, documents

  • 1. The title of “IT Security Principals” was replaced with the title of “Information Security Officers” effective May 1, 2014.