Retention Schedule generally expresses retention periods in terms of the number of calendar years to be added to the current calendar year. For example, if a record’s retention period is classified as “7 Years,” a record created any time during the year 2020 must be kept until December 31, 2027. Custodians shall not utilize portable electronic media, such as personal computer folders, CD-ROMS, DVD-ROMS or USB flash drives, as the exclusive means to store original records. All College records that are maintained in electronic format must be stored on servers or other media designated and approved by the College’s Information Technology Services (ITS) Department. The custodian is responsible for disposing of records after the applicable retention period has expired. Disposal of records must occur in a manner to ensure that protected, private or confidential information contained in such records is not obtained or retrieved by unauthorized persons. Such disposal may require actions such as shredding, burning, degaussing and overwriting prior to disposal. Custodians are responsible for ensuring that records which are the subject of a litigation hold, as described below, are preserved regardless of the expiration of any retention period, and that such records can be retrieved and produced upon request by the College’s General Counsel. Failure to maintain records in accordance with this Regulation and the Records Retention Schedule may be cause for disciplinary action, up to and including termination of employment. N ON -C USTODIAN R EQUIREMENTS Individual employees may, from time to time, originate or receive copies of records for which they are not listed as the custodian on the Records Retention Schedule . In such cases, the original of the record in question should be promptly routed to the identified custodian. Non-custodians should dispose of their own personal copies of a record after they no longer have a practical academic, operational or business use for the record, except in the following circumstances: 1. The non-custodian is aware of a compelling academic, operational or business need warranting longer retention of the record; 2. The non-custodian is aware that the record is related to actual or pending litigation; 3. The non-custodian is notified that the record is the subject of a litigation hold; and/or 4. The non-custodian is otherwise advised by the custodian of the record, the Records Management Committee or the College’s General Counsel to retain such record. If any employee has a question regarding the appropriate custodian for a specific record or is unsure whether the identified custodian has the original, he or she should contact the custodian or the College’s General Counsel for clarification. R EQUIREMENTS FOR E LECTRONIC R ECORDS The College’s Information Technology Services Department, in collaboration with the Records Management Committee, will recommend appropriate systems and media for electronically storing records. At a minimum, these systems must: 1. Permit the search and retrieval of stored records in a timely and efficient fashion; 2. Restrict access to only authorized users;
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