Document Retention and Records Management Policy

Document Retention and Records Management principles are designed to promote sensible storage and management of College records. RISD is committed to managing its records in a way that preserves institutional knowledge, enriches our historical understanding, supports RISD functions, recognizes environmental consciousness, and meets legal standards.

This policy applies to all college records in all forms, including without limitation, paper and electronic files

RISD records management is designed to create sensible management of the College’s academic and administrative/operational records within a system that considers the academic, operational, historic, and research value of records. The Records Retention Schedule addresses the primary records managed across many RISD departments, but is not intended to be comprehensive. RISD recognizes that certain records are unique to each department, and encourages departments to develop department-specific retention schedules to assist with the efficient management of records.

Archival record: Inactive records that have permanent or historical or research value and are not required to be retained in the office in which the record was originally generated.

Disposition: Destruction of a record regardless of the method used to destroy it (i.e., shredding, erasing, deleting, pulverizing, etc.)

Electronic record: A record kept in an electronic format such as a word-processing document, a spreadsheet, a database, a scanned or imaged document, and any other type of file stored on a computer, server, or mainframe storage device or medium, or on any external or off-site storage medium, or with a third-party acting as the college’s agent. Electronic records have the same retention periods as paper and other tangible records.

Historical value: The importance or usefulness of records for understanding the past that justifies continued preservation because of the enduring administrative, legal, fiscal, or evidential information they contain.

Inactive records: Records that are no longer active records but still must be maintained pursuant to the pertinent record retention schedule because of their continued administrative, fiscal, legal, or historical value. These records are typically referred to infrequently but are not yet ready for disposition.

Legal Hold: A written (hard copy, by email, or other electronic means) directive issued by the Office of the General Counsel directing the retention of records related to an investigation or litigation.

Non-record: Informational materials that do not meet the definition of a record (e.g., blank forms; extra copies of documents preserved only for convenience, or reference, of which no action is recorded or taken; or publications or other processed documents that require no action and are not part of a case in which action is being taken).

Office of Record: The department or unit designated as having responsibility for retention and timely destruction of records – the office owns the records. Such responsibility is assigned to the department’s or unit’s head or their designee.

Personal Identifiable Information: A person’s name, personal mark, or other information which can be used on its own to identify the person, together with at least one of the person’s data element: social security number, driver’s license number, identification card number, mother’s maiden name, financial services account codes, bank account codes/numbers, debit card numbers, electronic serial numbers, or other personal identification number.

Record: All recorded information that is created, received, or maintained by RISD in the course of college business and that relates in any way to the functions, operation, or activities of the college. This definition encompasses recorded information in all formats and media including, but not limited to: emails, records stored on computer hard/shared/network drives, notes, working papers and drafts of documents by RISD employees and third parties, and copies as well as original records.

Retention period: The minimum required length of time for which a department/unit is responsible for the maintenance of records. RISD requires that all retention periods be determined based on the fiscal year in which the records were created. For example, applying the fiscal year retention system to records created within FY 2016 (from July 1, 2015 through June 30, 2016), with a retention period of four (4) years, means that the records may be disposed of after June 30, 2020.

Retention schedule: The record retention schedule describes categories of records, providing a length of time they should be kept and includes instructions for disposition. Many of the schedule items are broad and describe the purpose or function of records rather than identifying individual documents and forms.

Records created or received during the normal course of college business are the property of RISD and considered College resources.

Retention Schedule
The retention periods specified are intended to be consistent with applicable legal, regulatory, accreditation, and other standards, including administrative and best practices. The Retention Schedule is not meant to be comprehensive of all records held by RISD, and includes the records required to be held by RISD pursuant to law, as well as records that are commonly used by departments. Departments are encouraged to create their own Retention Schedules for records specific to their areas, using the Retention Schedule as a template.

Records Disposal
Unless records have been defined as “permanent” or “historical,” they will be destroyed according to the Retention Schedule.

• Recycling: Generally appropriate for all non-confidential paper documents, including, but not limited to, public documents of other organizations, magazines, annual reports, newsletters, announcements, and drafts or policies or other memos which do not contain personal identifiable or sensitive/confidential information.

• Shredding: Any hardcopy RISD document containing Personally Identifiable Information or sensitive information must be shredded. For example, if a document contains a student’s RISD identification number, or an employee’s Social Security number, that document must be shredded. When disposing of such RISD records, the disposer must ensure that no unauthorized person will have access to the personal identifying information contained in the record.

Exceptions

There are exceptions which will require documents and records to be kept longer:

• Records being used in legal actions must be retained for one year after the legal action ends, or until their scheduled retention period has passed, whichever is longer.
• Records being kept beyond the established retention periods for audit and other related purposes at the request of state or federal agencies must be retained until the college receives the audit report, or the need is satisfied.

Official Copies and Duplicates
There is only one “official copy” that is kept with the “Office of Record” (creator) which is responsible for its retention. Duplicates may be retained in other departments that are not the “Office of Record” and may be destroyed when no longer needed, but duplicates cannot be retained longer than the official copy. Prior to the destruction of duplicates, consult with the “Office of Record” to ensure that staff have the “official copy.”

Electronic Records
File maintenance of electronic records requires coordination among the places where they are stored. Records that are maintained only in electronic format should be named and labeled in a manner that is consistent with the department’s needs for ease of coordination and cross-referencing. Electronic records should not be saved directly to a desktop or local hard-drive as these are not backed up by RISD. RISD maintains several cloud services that allow for backup storage of electronic records, and its own private network. Departments should determine which storage method provides the best balance of access and security, but must minimally provide a backup.

Email Retention
Email should be treated like any other electronic record. Records in email that need to be retained should be downloaded to Google Drive or other systems/processes the department uses to retain records. Each email user is responsible for retaining email considered to be a record. Non-record emails should be permanently deleted unless they serve an important administrative value to the employee or are subject to a legal hold.

Historical Records
Records that have reached the end of their retention period, but have historical or research value should be retained. RISD’s Archivist will assess the historical value of such records. Records identified as historical will be transferred to the Archives for extended retention. In addition, inactive records deemed to have historical value will also be transferred to the RISD Archives.

Records Related to Websites
Because websites have replaced many publications and other official communications, they are a significant archival record of the college and its operation. Therefore, all measures should be taken to capture, preserve, and make accessible such records as resources allow.

Digitizing Records
Digitizing of records must be done in PDF (mainly for textual content) or TIFF (mainly for graphic content) format to properly preserve them as records. Generally, once a record has been properly digitized, the paper record may be destroyed (see ‘destruction methods’) prior to the end of their retention period. Records that must be maintained in their original form will be indicated on the Record Retention Schedule.

Confidentiality
Many RISD records contain confidential and/or regulated private data protected by federal, state, and local regulations including, but not limited to, GLBA and FERPA, and many are considered “education records” for students. Confidential records must be securely maintained, controlled, and protected to prevent unauthorized access or disclosure. Storage locations must provide appropriate confidentiality and be protected from unauthorized inspection, theft, or physical damage. Confidential records shall be shredded according to the applicable schedule at the end of their appropriate retention period in order to preserve the confidentiality of the documents through their final disposition. Electronic records containing confidential information should be permanently deleted and purged by a means that prohibits reconstruction of the information.

Departments are responsible for the records management in their department/area and should designate the individual(s) responsible for the following:

• The creation of file organization and naming conventions for electronic files held on the RISD network and/or other cloud-based storage systems.
• Identify whether the Records Retention Schedule contains records pertaining to the Department’s activities, and ensure that records are maintained and destroyed consistent with that Schedule.
• If the Records Retention Schedule does not include certain records retained by the Department, then develop a department-specific schedule that assists department members in managing those records.
• Review inactive records for storage or transfer to Archives.

Departments intending to replace paper records with electronic or imaged copies are required to ensure that:

• The images will accurately and completely reproduce all the information in the records being digitized.
• The digitized records will not be rendered unusable due to changing or proprietary technology before their retention and preservation requirements are met.
• The digitizing system will not permit additions, deletions, or changes to the images without leaving a record of such additions, deletions, or changes.
• The digitalized records are maintained in a system that is backed-up on a regular basis.
• Ensure that the originals are maintained in a secure location if the originals must be retained.

Requests for assistance in establishing area/departmental retention schedules should be made to risdlegal@risd.edu.

This policy was approved as of: 2/1/2022

Review annually on the following date or as required by law: February 1st

Issuing Office

Office of the General Counsel

Responsible Officer

General Counsel

Individuals/offices required for review and changes

General Counsel

Senior Vice President of Finance and Administration