Records Retention Guidelines
There are three primary reasons for retaining records: They contain useful information for administrative and operational purposes; they meet legal requirement and related audit purposes; and/or they have historical value.
1. Does the department use the document currently, or will it have future usefulness?
Many records kept in departmental files may be discarded as soon as they have outlived their usefulness for immediate reference purposes. Examples of reports that are important to review when they are issued but have limited usefulness once they are two years old are telephone logs, monthly budget reports, and copies of documents provided to Accounts Payable for processing. If needed at a later time, these records are often maintained in original form or microfiche for longer periods by the central office responsible for generating the report. Routine correspondence and announcements may be purged frequently from files, whereas documents related to the creation of a program or new account are likely to be useful for reference purposes many years later and should be retained.
2. Is the document needed for audit purposes?
The University is subject to audit by the internal Revenue Service, various regulatory agencies of the federal and state government, agencies and organizations that provide funding to the University, and certified public accountants engaged by the University to audit the institution's financial statements and expenditures of federal funds. Departments and functions within the University are also subject to Internal Audit's review, but internal auditors work with whatever records are available. They do not have separate or additional requirements for departments' records retention but may make recommendations I specific cases for departments to maintain certain documentary evidence of compliance with regulations and University policies for at least a year.
Books on record-keeping requirements, including "Record Retention and Disposal - A Manual for College Decision Makers" and "Guide to Record Retention Requirements in the Code of the Federal Regulations" (which outlines various federal agencies' requirements) are available for reference from the University Auditor's office. Unfortunately, different agencies require different retention periods for the same type of document. Blanket rules such as ""keep current year plus three years' records" or "discard after seven years" are not valid.
Special record-keeping requirements apply to sponsored programs. See the Brown University Sponsored Projects Handbook for further guidance as to when records related to grant administration may be discarded.
Another source of guidance are "the voices of experience"-long-term Brown employees in comparable positions or in offices that have previously been subject to external audit. If another office at Brown maintains the original document or the information will be available electronically or on microfilm or fiche for the required period of time for audit purposes, the department copy may be discarded. However, it should be noted that the central offices' filing systems are not perfect; on more than one occasion, a department's back-up copy has saved the day when the original couldn't be located or didn't have sufficient information attached to it to answer an auditor's questions.
3. Does the record have intrinsic, historical value?
Check with the University's Archivist before discarding documents you think might fall into this category. Presidential papers, original correspondence from famous people, and University publications are examples of documents that can be relayed to the Archivist for evaluation and retention rather than keeping them in departmental files.
Partial list of records that should always be maintained by departments:
- The most current version of University policy statements and operating handbooks
- Purchasing documents and manuals for all computers and software used in the department
- Personnel Action Forms and records of current employees' sick and vacation time
- Supporting documentation for sponsored project expenditures (until three years after the project's end date and final audit)
- Results of departmental self-studies, peer reviews, or accreditation visits
Partial list of records to be maintained on a permanent basis by designated offices:
- University Charter, Corporation minutes and reports, annual audited financial statements and University publications (President's Office or Archivist)
- Endowment and restricted gift correspondence (Development)
- Leases, institutional agreements, and contracts (Purchasing or General Counsel)
- Financial records related to restricted accounts, building, endowment, and other long-term assets (Accounting)
- Original and updated building blueprints and system diagrams (Facilities Management)
- Records related to hazardous waste handling (Risk Management)