Policy: XIII.F.1x (inactive)
Issued: February 17, 1995
Owner: Assistant Vice President for Facilities Management
FACILITIES MANAGEMENT - DISPOSAL OF CONFIDENTIAL
This policy describes the University guidelines for disposing of confidential documents.
2.0 Policy [Top]
The University of Virginia's previous policy on the disposal of confidential documents states that all confidential documents are to be disposed of by shredding or by transporting to the regional landfill. The University's new policy lets each department choose the type of disposal for its confidential documents.
2.2 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 discussed 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.
2.3 Federal Requirements
NOTE: Federal requirements generally apply to only ledger five accounts and federally-funded student load 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 litigation 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 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 above, 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 canceled. The 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.
2.4 Retention Period
A. 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.
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: ORIGINAL RECORDS AND DOCUMENTS MAY BE DESTROYED ONLY AFTER AN APPROVED "RECORDS RETENTION AND DISPOSITION SCHEDULE" HAS BEEN APPROVED. THIS APPROVAL IS NEEDED EVEN IF AN AUDIT HAS BEEN CARRIED OUT, FINDINGS HAVE BEEN RESOLVED, AND THE RECORDS ARE MORE THAN FIVE YEARS OLD. SEE ALSO PROCEDURE 2-32.
Departmental and 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:
B. Nonfinancial Records
Procedure 2-30, "Record Retention: General Requirements."
2.5 Destruction Methods
Once the records retention and disposal schedule has been approved of a series of records, and a certificate of records disposal has been approved, departments may dispose of records by an convenient and economical means. However, confidential records must be completely destroyed by burning, shredding, or pulping under appropriate supervision.
Procedure 2-32, "Preparation of Certificate of Records Disposal."
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 any "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,
- The State requires a number of copies be made from each silver original microfilm, and that the original master microfilm be sent to the State Library.
If the departments obtain permission to microfilm records, no central University funds exist to pay for the microfilming. EACH DEPARTMENT MUST BUDGET FOR THE MICROFILMING. If the University's Records Administrator and the Virginia State Library approve the department's "Record Retention and Disposition Schedule" (University Procedure 2-31), the department may request bids for microfilming through Purchasing. The Virginia State Library's Central Records Management Office maintains a large microfilming operation and will submit bids, is requested.
2.7 Destruction of Confidential Documents
Each department has the responsibility for choosing among the approval methods of disposal. The following information is provided to assist departments in selecting a disposal method:
METHOD 1: Shredding
All confidential documents in a department should be stored in a secure area until a sufficient amount warrants destruction by a shredder. Since shredded paper can not be processed through the University's official Recycling Program, departmental personnel are responsible for the disposal of shredded bags of paper.
METHOD 2: Transportation to the regional landfill
All departmental confidential documents will be stored in a secure area until a sufficient amount warrants transportation to the regional landfill, either by departmental personnel or by personnel contracted by the University.
Call for a pickup of confidential documents at 982-5033.
METHOD 3: Recycling
All confidential documents in the department should be stored in a secure area until a sufficient amount warrants transportation by Environmental Services or Facilities Management Recycling personnel to a secure University-owned paper recycling container.
3.0 Definitions [Top]
4.0 References [Top]
5.0 Approvals and Revisions [Top]