Records Retention Policy

This policy articulates the responsibility for Records retention and disposal in all units of Earlham, including the School of Religion, and provides guidance for compliance with Earlham’s Records Retention and Disposal Schedule.

1. Records management is the systematic control of Records throughout their lifecycle – from their creation or receipt to their disposal or transfer to the Earlham College Archives. Being mindful of the Records we create and how we manage them ensures that Records of enduring archival, historical, administrative, legal, or fiscal value are captured and preserved. It also allows for the timely destruction of Records that are non-essential so that we minimize litigation risks, reduce operating costs, and improve organization.
2. This policy, along with the Records Retention and Disposal Schedule, ensures Earlham is in compliance with legal, regulatory, fiscal, administrative, and contractual obligations and, with regard to appropriate Records, archived to preserve Earlham’s history.
3. This Policy is intended to ensure that Earlham meets legal standards; properly retains and disposes of Physical and Electronic Records; preserves Archival and Historical Records; and standardizes Record-keeping practices across the institution.

1. 1. Earlham College is committed to managing the Records that are necessary to preserve its historical legacy; to ensuring continuity of operations and effective administration; to the responsible and timely destruction of Records; to meeting legal, regulatory, and fiscal responsibilities; and to optimizing its use of space and time.
   2. Earlham requires that Records be retained for specific periods of time, taking into account legal or other institutional requirements. These requirements are determined based on the ethical and federal/state guidelines of the Record’s originating office and Records retention and archival best practices.
   3. No one person or unit can be directly responsible for all Earlham Records. Therefore, every area on campus managing Earlham Records is responsible for:
      • Implementing Records management practices consistent with this Policy in partnership with their Records Liaison(s), the Records Manager, and the Records Advisory Council (RAC).
      • Educating employees in their areas about Records management best practices.
      • Preserving Records as required under this policy.
      • Properly disposing of or transferring Inactive Records at the end of the applicable retention period.
      • Protecting Records against misuse, misplacement, damage, destruction, or theft.
      • Monitoring compliance with this Policy.
   4. Community members should direct questions about a specific Record not named in the Records Retention and Disposal Schedule to the Records Manager.

1. Record: Any information stored on a fixed medium (including, but not limited to, paper, email, any type of electronic file or data, still photographs, motion pictures, drawings, plans/blueprints, and audio/video Recordings, etc.) prepared or received in the course of business that documents the organization, functions, policies, decisions, procedures, operations, or other activities of Earlham College and Earlham School of Religion.
   • A.1. Active Record: Any Record currently in use by the department or office that created it. Active Records are maintained and retained in the originating office/department. The lifespan of Active Records may vary by office, department, and Record type. These lifespans are defined in the Schedule.
   • A.2. Archival Record: A Record that has permanent or historic value and is not required to be retained in the office in which it was originally generated. Archival Records are retained in the Archives.
   • A.3. Electronic Record: A Record that contains machine-readable rather than human-readable information. Examples include: a word processing document, spreadsheet, database, scanned document or photo, e-mail, static and dynamic websites, and computer files. Electronic Records have the same retention periods as paper and other tangible Records.
   • A.4. Inactive Record: A Record that no longer meets the definition of an Active Record but still must be maintained pursuant to the Schedule. Inactive Records are typically maintained in their originating office until the Schedule dictates that they should either be destroyed or transferred to the College Archives. The lifespan of Inactive Records may vary by office, department, and Record type. These lifespans are defined in the Schedule.
   • A.5. Restricted Record: A Record that contains information requiring a high level of oversight and control due to potential institutional risk and where an individual or the institution could be harmed if disclosed improperly. Examples include but are not limited to Records protected by FERPA or HIPAA, personally identifiable information, alumni and donor Records, college financial data, personnel Records. For additional information, consult the Data Classification Policy.
2. Records Liaisons: Trained individuals who are responsible for ensuring areas or departments of the institution comply with this policy and follow the Records Retention and Disposal Schedule.
3. Records Manager: Provides leadership for Earlham-wide Records management programs and initiatives and gives Recordkeeping advice to Records Liaisons, departments, offices, programs, committees, and individuals. The College Archivist serves as Earlham’s Records Manager and convenes the Records Advisory Council.
4. Records Advisory Council: The Council is responsible for the administration and review of Earlham’s Records Management Program. The role of this body is defined in Part VI: Administration of this Policy.
5. Records Retention and Disposal Schedule: The Schedule instructs offices on how to maintain specific types of Records throughout their life cycle according to the legal, fiscal, administrative, and historical needs of the institution. It may be referred to simply as “Schedule” in this policy.

1. The Records Retention and Disposal Schedule lists different types of Records and the length of time those Records must be retained. Because no document list can cover all situations, questions regarding the retention period for a specific Record or class of Records not included in the Records Retention and Disposal Schedule should be addressed to the Records Manager and/or Liaison as needed.
2. The retention periods set forth in the Records Retention and Disposal Schedule are the minimum retention periods required by Earlham. At the conclusion of the retention period, the Records should either be properly disposed of in accordance with legal or Earlham’s requirements, or they become Archival/Historical Records.
3. All Records pertaining to ongoing or pending audits or lawsuits (including reasonably anticipated lawsuits) should not be destroyed, damaged, or altered, even if the Records retention date has expired, until the matter has been resolved and you have been specifically advised in writing by the Office of the President, Chief Operating Officer, or Chief Financial Officer.
4. Inactive Records cannot be disposed of or transferred until the time listed in the Schedule specifies it is time to do so. Requests to deviate from or modify the Schedule or these retention periods must be made to and approved by the Records Manager and/or Records Advisory Council (RAC).
5. The Records Manager and Records Advisory Council (RAC) work with the Records Liaisons of each area to make sure the Records Retention and Disposal Schedule is up-to-date and is in compliance with this Policy.
6. Electronic Records:
   Earlham employees must use Earlham-approved resources to create and store their Electronic Records, particularly if the Records contain confidential information. Records Liaisons will work with the Records Manager and Records Advisory Council (RAC) to make sure appropriate resources are being used.
7. Archival and Historical Records:
   • G.1. Archival and Historical Records are Records deemed to have long-term, enduring value. The College Archivist should be consulted on whether such documents are to be transferred to the College Archives.
   • G.2. Donated Records or purchased Records, including Historical Records (examples: slides, photos, programs) and original artwork (example: student artwork purchased for a campus office), should be reported to your Records Liaison and the College Archivist or Art Curator to ensure Earlham obtains all appropriate documentation (such as signatures and information related to intellectual property rights) for all such objects.
   • G.3. Institutional Advancement must also be notified of any donations, especially if the donor requires documentation for taxes.

1. The Records Advisory Council (RAC), in partnership with the College Archives, is responsible for the administration and review of Earlham’s Records Management Program, including the maintenance of the general and unit-specific Records Retention and Disposal Schedule. Membership of the Records Advisory Council (RAC) is as follows:
   • Records Manager (College Archivist); convener
   • A senior member in Information Technology
   • A senior member in Institutional Effectiveness
   • Data Privacy Officer
   • Two Records Liaisons who work in different areas or departments
2. The Records Manager and Records Advisory Council (RAC) facilitate Records management training as needed and by request. This includes but is not limited to training on basic Records management best practices, working with s (example: Records that fall under FERPA or HIPAA, contain social security numbers, etc.), and working with Electronic Records.
3. The Records Advisory Council shall, in consultation with departments and offices, periodically review and update the Records Retention and Disposal Schedule. The schedule may include automated disposal timelines.
4. The Records Advisory Council (RAC) will consult with Nominating Committee, Staff Engagement and Advisory Committee, and the Earlham School of Religion to select experienced Records Liaisons for roles on the council. These people are appointed to the role for three years.
5. It is the responsibility of the campus office or department to inform the Records Manager when someone serving as Liaison leaves Earlham or moves to a new area on campus. The Records Manager and Records Advisory Council (RAC) will help the area choose and train a new person for the Liaison role.
6. All Records Liaisons are required to go through training that will teach them basic best practices for working with Restricted Records. Offices that work with s must be compliant with the legal, federal, and state guidelines for their respective fields and may be required to go through additional mandatory Records management training.
7. Concerns related to adherence to this policy should be reported to a member of Records Advisory Council (RAC).

Earlham College will address reports of the mishandling of Earlham Records in accordance with applicable policies, procedures, and employee handbooks. Depending on the individual and circumstances involved, resolution could be managed by the offices of the President, Provost, Chief Financial Officer, or Human Resources.

The Records Advisory Council (RAC) will annually review this policy and the Records Retention Policy and Schedule. Amendments will be approved by the President.