**INACTIVE POLICY**

For Current Policies:
Policy Table of Contents

 

                       UNIVERSITY OF VIRGINIA
           FINANCIAL AND ADMINISTRATIVE POLICIES MANUAL



TITLE:  RECORDS RETENTION AND DISPOSITION            POLICY: II.C.1x

                                                                  
Records retention and disposition at the University is important
for many reasons.  Some major considerations in records retention
are:

      Preservation of historical and research information:  Data on
      the University of Virginia, as a major institution of higher
      education, are of considerable interest to researchers and
      scholars.

      Fulfillment of legal requirements:  The University must
      maintain documentation required by various federal and state
      statutes.

           Note:  If litigation is pending, threatened, or
           possible, DO NOT destroy any record or file until
           permission is granted by the University's General
           Counsel.

      Fulfillment of audit requirements:  The University is subject
      to audit by its own Audit Department, the State Auditor of
      Public Accounts, and agencies of the federal government.

      Limitations of storage space:  Limited storage space
      restricts many departments in both the volume of records and
      duration they may be stored.


Definitions


Public records, as used in this policy and as defined in the
Virginia Public Records Act (Code of Virginia, Sections 42.1-76
through 42.1-90), are "all written books, papers, letters,
documents, photographs, tapes, microfiche, microfilm, photostats,
sound recordings, maps, or other documentary materials or
information in any recording medium regardless of physical form or
characteristics" including computer-produced materials or
information, made or received under the law or in connection with
public business conducted by the University.

Public records do NOT include:

      Reference books, or

      Exhibit materials made or acquired and used solely for those
      purposes, or EXTRA COPIES KEPT SOLELY FOR CONVENIENCE OR
      REFERENCE PURPOSES, or Stack copies of publications.


Original Documents

As used in this policy, the original document (or the original
copy) usually means the top copy or document having the actual
typed, handwritten, or computer-generated print and signature on
it.  Therefore, photocopy or multiple-form copies are not originals
as defined in this policy.  The University's record retention
program is primarily directed toward the preservation of original
documents.  Where the original has been sent outside the
University, we retain the "institutional copy," i.e., that copy
designated as the record copy, even though not the original.  Most
institutional copies are held in central offices, although many
original payroll documents are retained in the originating
departments.

Authorization

State law and University policy prohibit individuals and
departments from destroying, discarding, selling, or giving away
public records without proper authorization.  Departments wishing
to destroy records that are no longer needed should first search
the State's General Records Schedules (available electronically on
PUBLIC, or in hard copy from an Agency Records Administrator) to
see if an applicable series description in one of the schedules can
be located.  If there is an applicable series, and the unwanted
records are older than the state-mandated retention period given in
the schedule, the office should call an Agency Records
Administrator (in Alderman Library and Medical Center Clinical
Services) to obtain a blank RM-3 form, a Certificate of Records
Destruction.  See Procedure 2-32 for instructions for completing
this form.  If no series can be found that exactly fits the
unwanted records, the department should consult the appropriate
Agency Records Administrator; there is a procedure for preparing a
records schedule for unique records that are not covered in the
General Records Schedules.

Once the department has received an approved record retention
schedule, the next step is to file the companion RM-3 form with the
Agency Records Administrator and receive an approved copy
authorizing destruction, before any records may be destroyed.

See also Procedures 2-32, "Preparation of Certificate of Records
Disposal."


Organization

Virginia Public Records Act authorizes the Virginia State Library
and Archives to conduct a program of "public records management and
preservation" that is "applicable to all public officers and
employees."  The University's records management program is part of
this state-wide program.

The Archives and Records Division of the Virginia State Library and
Archives is responsible for the operation of the program; it is
directed by the State Archivist.  At the University, the Agency
Records Administrator for Agency 207 is the Director, Special
Collections Department, Alderman Library and for Agency 209 is the
Assistant Director of Clinical Services.

                 
Confidentiality of Records

Financial Policy XV.C.1, "Disclosure of University Records," is the
University's statement on releasing University records and
information.  This policy defines relevant terms, identifies those
records not subject to public release the procedures to be used in
disclosing University records and information, and other related
matters.  "Disclosure of University Records" includes all official
material except two categories-student and medical records.

Policy XV.D.1, "Protecting Privacy Rights of Students" covers the
area of student records confidentiality and release.  This policy
discusses student rights, the applicable education records, the
custodians and locations of such records, procedures for
disclosure, enforcement and sanctions, and the annual notice of
student rights.

Federal Requirements

Note:  Federal requirements generally apply to only ledger five
accounts and federally-funded student loan accounts.

The University is required to retain all contract-related records
(federal and non-federal) until audited.  As a federal grantee, the
University is required to retain all grant-related records for
three years or until audited, whichever is longer, except for the
following items:

                                                                   
      Grants involved with litigations or claims,

      Grants under audit,

      Records for nonexpendable property acquired with federal
      funds,

      Records transferred to or maintained by the federal
      sponsoring agency, and

      Federally-funded student loans.  (See also paragraph below.)

Note:  Often, only the Office of Sponsored Programs (OSP) knows
when particular grants or contracts were audited.  Departments must
verify a grant's or contract's audit status with OSP before
destroying any related documents.

For the items in the OSP list immediately preceding, the retention
period is dated from submission of the final expenditure report;
for grants renewed annually, the retention period dates from
submission of the annual financial status report.                  
 
For records under audit, such records should be retained not only
until audits of such records are completed, but until all audit
findings are fully resolved or negotiated.

The University is required to retain federal student loan fund
records for five years after the loan has been assigned, fully
repaid, or cancelled.  This requirement applies to Health
Professional Student Loans, Nursing Student Loans and National
Direct/Defense Student Loans (Perkins).  For specific retention
requirements see also Procedure 2-30.


Retention Period

      Financial Records

      The following retention requirements generally apply to all
      financial accounting system ledgers, except ledger five and
      federally-funded student loan accounts.  Included are
      payroll, fringe benefit, leave transaction source documents,
      and the reports resulting from processing such documents. 
      For specifics, see also Procedure 2-30.


Retention Period

      Financial Records, cont'd.

      Original records or documents:  Current fiscal year, plus
      five previous years or until audited, whichever is longer. 
      This is a requirement of both central offices and
      departments, if original documents are held.  NOTE:  THESE
      RECORDS MAY NOT BE DESTROYED, EVEN AFTER AN AUDIT HAS BEEN
      CARRIED OUT, FINDINGS HAVE BEEN RESOLVED,AND THEY ARE MORE
      THAN FIVE YEARS OLD, UNTIL AN APPROVED "RECORDS RETENTION AND
      DISPOSITION SCHEDULE" HAS BEEN OBTAINED.  SEE ALSO PROCEDURE
      2-32.

      Departmental or convenience copies:  Current year plus one
      previous year.

      Certain financial and accounting reports (year-end master
      general ledger, subsidiary ledger, and open commitment file
      tapes):  Permanent retention.

      Nonfinancial Records

      See also Procedure 2-30.


Destruction Methods

Once a records retention and disposition schedule has been approved
for a series of records, and a certificate of records disposal has
been approved, departments may dispose of records by any convenient
and economical means, preferably by recycling.  However,
confidential records must be completely destroyed by burning,
shredding, or pulping under appropriate supervision.  The State
Library has also authorized destruction of confidential records
through the University's bonded recycler.

See also Procedure 2-32, "Preparation of Certificate of Records
Disposal."

Microfilming

It is much less expensive to store records for many years than to
microfilm them.  The State will not allow the microfilming of
records merely for convenience.  To address this issue, the State
Library Board has issued "Standards for the Microfilming of Public 
                                                                   

Records for Archival Retention."  Only records of "sufficient
administrative, legal, fiscal, and historical value to warrant
their permanent preservation shall be designated permanent
records," and only "permanent records" will be approved for
microfilming.

Most departments should not microfilm because:

 It is difficult to have records declared "of permanent value,"

 Microfilming is very expensive, and


 The state requires a number of copies be made from each silver
 original microfilm, and that the original master microfilmm be
 sent to the State Library.

If departments obtain permission to microfilm records, no central
University funds exist to pay for the microfilming; EACH DEPARTMENT
MUST BUDGET FOR ITS OWN FILMING.  If the University's Records
Administrator and the Virginia State Library approve the
department's record retention schedulle, the department may request
bids for microfilming through Purchasing and Materials Services. 
The Virginia State Library's Central Records Management Office
maintains a large microfilming operation and will submit bids, if
asked.


ISSUED BY:                                                 06/24/94

Agency Records
Administrator                2.3.1.1