(422) Records Retention

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Oct. 20, 2011


Overview The purpose of this Records Retention policy is to inform and provide instruction to Kansas Athletics employees about how long specific types of records should be maintained, to specify the location of the official records, and to set forth other procedures for handling records. Because of the sensitive nature of many Kansas Athletics records, it is unwise to retain confidential documents beyond the period required by law or that is necessary to respond to reasonable business inquiries.

This records retention policy identifies the length of time that a record should be kept (retention) and what action should be taken (disposition). The policy also identifies the department or office that is responsible for the record copy of the document or file. The office responsible for creating the records is considered the “office of record” for those particular records.

In situations where litigation or audit by a governmental regulatory agency is reasonably anticipated, Kansas Athletics has a legal obligation to preserve all existing documents and data that may be relevant to the matter. In these situations, steps must be taken to ensure that the data and documents are not deleted, overwritten, destroyed, or changed in any manner. Destruction of the data should be immediately suspended. Failure to do so could result in penalties against Kansas Athletics. Any questions relating to the retention of records in this context should be directed to the Corporate Counsel.

University of Kansas records retention policies will control should this policy not address a particular document or record. University records retention schedules are found on the Policy Library website at https://documents.ku.edu/policies/Information_Services/RecordsRetentionSchedule.htm. If the records are determined to be of value to the University of Kansas then the records are transferred to the University Archives. Instruction on the transfer process can be found on the University Archives website [http://spencer.lib.ku.edu/ua/].

Each department’s specific retention schedule for records may be found by going to the kuathletics.com website, clicking on Inside Athletics and then clinking on Internal. The direct link is as follows: http://grfx.cstv.com/photos/schools/kan/genrel/auto_pdf/2011-12/misc_non_event/RecordsRetentionSchedules.pdf

Department Responsibility The office responsible for maintaining a record (including its eventual destruction) is identified in this policy. Duplicate copies of the documents described in the policy may be held in offices other than the department designated as being responsible for the official document. Additionally, all departments at Kansas Athletics may produce documents which may not need to be included in this retention policy but which may contain confidential information. These additional “convenience” copies of documents or non-essential documents should be destroyed as soon as possible after the immediate need for them has passed.

Records Format Maintaining records in an electronic format is the preferred form of storing most information. Electronic documents can be more widely available to Kansas Athletics employees or other users of the documents and are more easily managed.

IRS regulations require information that is originally produced in an electronic format must be retained for the appropriate retention period in the same, or equally functionally, electronic format. Certain legal documents must be kept permanently as a paper record.

Records Destruction Paper records should be shredded after the retention period has expired. Placing the documents to be destroyed with the secure shredding service available in the Business Office is an acceptable method of ensuring proper secure destruction.

Electronic records should be deleted from the file server after the retention period has expired. Delete an item by holding down the shift key while hitting the delete key. Using this method will permanently clear an item from the server. Items deleted from the file server will be able to be restored from backup up to 90 days. After this period, items will be unable to be recovered. Electronic records, storage media, and primary storage devices will be destroyed or data wiped by the Information Technology staff in accordance with the retention policy using appropriated methods to ensure the deleted data cannot be recovered.

Of course, the procedure above assumes Kansas Athletics is not under IRS or other governmental entity audit or in litigation in which a given set of records are relevant at the time the set otherwise would be destroyed. In such instances, records should not be destroyed with the written approval of the Corporate Counsel.

Calculating the Record Retention Period The records retention period identified in the following policy was developed to accommodate either fiscal or calendar year documents. Therefore, the retention period should be counted for both fiscal and calendar year documents from the end of the fiscal year to which the documents relate. For example, items relating to fiscal year (FY) 2007 which have a 7 year retention period should be destroyed as soon after July 1, 2014 as practical. Items relating to calendar year 2007 with a 7 year retention period also should be destroyed after July 1, 2014 since the end of calendar year 2007 falls within FY 2007.

Most records, including many Business Office records as well as student records and compliance records, should be calculated on a FY basis.