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C22.0 Records Management Policy

  1. Introduction

This Policy seeks to ensure that RIT meets legal standards, preserves RIT's history, and maintains a consistent treatment of Records, Records which document the history of RIT shall be preserved by the RIT Archives. Records required to be maintained for compliance with the law shall be retained for the legally required period of time. All Personnel shall comply with this Policy, as amended from time to time. This Policy is considered part of the conditions of employment for RIT Personnel. It should be read together with the other policies of RIT. RIT Policies are available online at https://www.rit.edu/academicaffairs/policiesmanual/

  1. Defintions

Terms not otherwise defined herein have the meanings listed below.

  1. Record means an original or copy of any document, communication, or similar item generated or received by RIT, by RIT Personnel, or on RIT's behalf, regardless of where that record is physically stored, which must be held for official business or regulatory purposes in accordance with the university's Record Management Retention Schedule. RIT Records do not include records that are not created in the official course of business, serve no legitimate or necessary business purpose, or are created only for personal non-business related purposes.

  2. Active Record means a Record that is currently being used for administrative purposes.  Records remain active for a varying number of years, depending on the purpose for which they were created.

  3. Archival Record means a Record that is inactive, not required to be retained in the office in which it originated or was received, and has permanent or historic value. Archival Records are retained and preserved indefinitely in the University archives.

  4. Confidential Record means a Record that contains information as defined in the Information Access & Protection Standard available online at: https://www.rit.edu/security/content/information-access-protection-standard

  5. Electronic Record means a Record maintained on a RIT network, email server, back-up tape, CD-ROM, optical and flash media, hard drive, or data storage location or device.

  6. General Correspondence means emails, letters, or notes created or received in the course of business that are directly related to the work or mission of the university.

  7. Scope of Employment means all activities related to the employment responsibilities of RIT Personnel.

  8. Personnel means all RIT staff and faculty, full-time and part-time, including student employees acting within their Scope of Employment, non-employee consultants, visitors, adjuncts and others using university resources.

  9. Official Repository means the division, department, or academic unit designated as having responsibility for the retention, timely destruction, or forwarding to RIT Archives, of specific Records. Such responsibility is assigned to the division, department, or academic unit’s vice president, director, dean, or designee.

  10. RIT Archives means a department of the RIT Libraries that collects and makes accessible physical and digital materials relating to the history of RIT.

  11. Hold Notice means a communication issued by the Office of Legal Affairs as a result of a current or anticipated government regulation, investigation, litigation or other matter that warrants the suspension of this Policy. 

III. General Provisions

  1. A. Management of University Records

Divisions, departments, or academic units that are Official Repositories of Records are responsible for establishing appropriate records retention management practices. Each division, department, or academic unit’s vice president, director, dean, or designee must:

  1. Implement their area’s record retention management practices;

  2. Identify a records custodian for their area who has responsibility to ensure that these record retention management practices are consistent with this Policy;

  3. Educate staff within their area to ensure they understand these record retention management practices;

  4. Preserve inactive Records of historic value and transfer those Records to the RIT Archives;

  5. Ensure that access to Confidential Records is restricted; and

  6. Destroy inactive Records, that have no archival value, upon expiration of the applicable retention period identified by the Office of Legal Affairs.

       B. Suspension of Policy/Legal Hold Notice

This Policy may be suspended as required by a consent order, private or governmental contract, pending or anticipated litigation, investigation, or audit requirement. Such suspension supersedes the requirements listed in this Policy and shall be made by the Office of Legal Affairs, which has the authority to suspend and revise any retention schedule. The Office of Legal Affairs will implement such a suspension by sending out a Hold Notice for relevant Records to appropriate divisions, departments, or academic units. This Hold Notice shall be in effect until rescinded in writing by the Office of Legal Affairs.

  1. Implementing Record Management Practices

    1. Retention of Records. In establishing appropriate record management retention practices, each division, department, or academic unit's vice president, director, dean or designee will be responsible for establishing a process for identifying Records and should incorporate the following in doing so;

    2. Archival  Records. Generally, Records which document the history of administration, academic programs, and the social and cultural life of RIT should be preserved. These records include, but are not limited to, correspondence, meeting minutes, administrative and annual reports, as well as publications, newsletters, posters, booklets, books, magazines, catalogs, special bulletins, university directories and faculty/staff rosters. To decide if the RIT records are of historic value, consult the RIT Archivist, who has the authority to designate which records are Archival Records. In cases where specific RIT records are to be sent to the RIT Archivist, the Official Repository shall hold the RIT records for as long as the Official Repository has a legitimate business use for the RIT record. It shall be the responsibility of the Official Repository to deliver the RIT records to the RIT Archivist in accordance with his/her instructions. No Official Repository shall dispose of records not specifically mentioned in this Policy without consulting the RIT Archivist.

    3. Electronic Records. The retention and preservation of electronic records shall be in accordance with this Policy. If an electronic record falls within one of the retention schedule's categories of records, then the record must be treated the same way as a similar hard copy record.

    4. Email. In considering the nature of email for retention purposes, an email and its attachments should be considered as a whole. If one retention period applies to an email and a different retention period applies to the email attachment(s), the entire email with attachment(s) should be retained for the longer of the two retention periods. If a person is merely copied on an email (either listed as a "cc" or "bcc"), he/she should treat the document as a duplicate in accordance with sub section 5 below, i.e., it may be deleted unless this Policy, or a division, department, or academic unit’s record management policy requires keeping it. Personnel may create individual folders and files within his/her email archives for retention of RIT records in accordance with this Policy.

    5. Disaster Recovery.  Electronic records maintained by the Information Technology Services (ITS) for disaster recovery and backup purposes only shall be retained and preserved by ITS in accordance with a uniform rotation schedule. This uniform rotation schedule shall require that no ITS backup of electronic records shall be maintained for longer than thirty (30) days. No other division, department or academic unit shall maintain electronic records for disaster recovery or backup purposes without the specific written approval of the Office of Legal Affairs and without adherence to the ITS uniform rotation schedule. Suspension of the uniform rotation schedule shall be accomplished only with the written approval of the Office of Legal Affairs.

    6. Duplicates.  Generally, only one copy of each record shall be retained. A duplicate is an exact replica of the original and shall be destroyed as soon as it does not serve a legitimate business purpose and as long as is not subject to a Hold Notice indicating otherwise.  Prior drafts, revisions, or original documents that have additional hand written notes are not considered duplicates of the original and shall be subject to the same requirements as an original record.

    7. Personnel no longer in your area. Records maintained by Personnel leaving your area (i.e. retirement, other employment opportunity, etc.) must be preserved and maintained in accordance with this Policy, taking into consideration any Hold Notice that may affect these Records.

  2. Destruction of Records

Records that are neither Active Records, Archival Records or the subject of a Hold Notice, should not be maintained and shall be properly destroyed. When that Record’s required retention period has passed, a determination must be made as to whether to preserve the Record as an Archival Record or to dispose the Record. The division, department, or academic unit’s vice president, director, dean, or designee should make this determination, in consultation with the University Archivist (ritarchive@rit.edu). In addition, the division, department, or academic unit’s vice president, director, dean, or designee shall certify annually, in writing, to the Office of Legal Affairs that compliance with this policy for the prior academic year has been complete.

  1. Using the Retention Management Schedule

The current Records Management Retention Schedule is located on the Office of Legal Affairs website.  Divisions, departments, or academic units are responsible for working with the Office of Legal Affairs to ensure that all Records used in their respective areas are listed on the Records Management Retention Schedule.

  1. If two or more categories with different retention periods are applicable to a Record, the Record shall be retained for the longest applicable retention period.

  2. Records that are subject to a designated retention period requiring destruction shall be destroyed within a reasonable period of time following the expiration of the retention period, but not before that retention period has expired.

  3. The default retention period for Records whose retention period has not been specifically identified shall be six (6) years. 

 

  1. Exceptions

Requests for exceptions to this Policy may be granted rarely, and only with good cause. Requests for exceptions to this Policy should be submitted to the Office of Legal Affairs. 

  1. Training

Each division, department, or academic unit's designee or records custodian will be responsible for ensuring their Personnel are informed of the Policy and procedures established pursuant to their area’s records retention management practices, and shall devise training to ensure appropriate implementation.  The Office of Legal Affairs shall conduct university wide training on this Policy annually.

IV. Records Management Retention Schedules

Please refer to the Office of Legal Affairs website for the current Records Management Retention Schedule. The Records Management Retention Schedule governs Records for all RIT divisions, departments, and academic units.

Responsible Office:
Office of Legal Affairs

Effective Date:
Approved May 13, 2009

Policy History:
Edited August 2010
Edited September 2012 (conversion edit)
Edited September 22, 2014 (ICEC) – sections III.G, H.; IV.B, C; V.A, C, G, I; VI.A, C
Revisions approved by University Council on April 13, 2022 - Sections I, II, III and IV

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