Records Retention Program – Imperative for Higher Education

Retention of student academic records used to be straightforward.  Student records were typically physical documents.  There was an actual document, either paper, microfiche, or pdf.  Documents were easy to move to a secure location, easy to print when necessary, easy to dispose of, and, because they were “frozen” in time, served as the historic document of record.

Technology flipped the idea of a “record” on its head.  Transcripts that were once paper or pdf are now created on demand using streams of data.  Grade books, advising notes and evaluations sit in various databases across campus and beyond.  Course catalogs and schedules of classes can be updated in real time.

The reasons for accessing student records haven’t changed much over the last fifty or so years.  Requests stemming from federal and state agencies, auditors, law enforcement, lawyers, and university counsel, and FERPA requests are a nearly everyday occurrence.

FERPA and A133 Compliance

A detailed, clearly defined records retention policy allows an institution to respond to inquiries from various agencies and individuals quickly and methodically.  The institution can identify what records are available, where the records are stored, and the responsible office on campus.  A records retention policy can help protect an institution during a FERPA request.  Auditor, both internal and external, are accommodated by a structured records retention program. Meeting external audit compliance for the single source A133 external audit for DOE Title IV funding is a much easier process when a records retention policy has been documented and adhered to in institutional practices.  A detailed policy allows the institution to define what records are not available.

Retaining records is equally important for their historic value.  The institutional archives need this information to preserve the history of the university – courses offered, grades received, students enrolled.

Build a Records Retention Program

The key is to define which records are legally, institutionally, and historically vital.  One university retention of records policy states the “…University requires that university records…regardless of format, be disposed of or retained for specific periods of time in accordance with legal or other institutional requirements, or for historical value.”

Developing a new records retention policy or updating an existing one can be dauting.

• Start by developing an inventory of academic records. Grades are an academic record.  But is a brochure highlighting how to enroll in courses significant?
• Then for each record, determine its retention period. Some are easy.  The catalog of courses is of historical significance and should be retained forever.  But for how long should an add/drop approval form, enrollment verification request, or transfer credit evaluation be retained?
• Next, identify the institutional official and office responsible for implementing and enforcing a records retention policy. Engage the institution’s registrar, archivist, IT director, dean, counsel, auditor, and anyone else who will have a stake in the implementation and/or enforcement of the updated policy.

Implementation and Enforcement of Records Retention

Having a records retention policy is critical.  But, for it to be effective the institution must be able to implement it and enforce it.  Academic records are more than likely electronic, and the format of the record needs to be considered.  It will be critical for the institutional official to partner with IT to develop an implementation and enforcement strategy.