Step 5: Dispose of Records at the End of Their Retention Period and Document Their Disposal
All University records – hard-copy and electronic – should be disposed of when the retention period is over. Records destruction requires the approval of your unit head or the information custodian delegated that responsibility, and is documented using a records destruction form. Completed records destruction forms have a retention period of 7 years and are evidence that we are following the retention rules in WatClass.
The disposal actions for a records class are described in the “Disposition” section of the records retention schedule. There are four possible actions:
- Secure destruction: Records whose information confidentiality classification is Confidential, Restricted, or Highly Restricted are to be securely destroyed. This means they are to be protected against theft, loss and unauthorized use or disclosure prior to destruction, and then they are destroyed or erased by methods recommended by the University’s Information Security Officer or the University Records Manager, in an irreversible manner which ensures that the information cannot be recovered or reconstructed.
- For paper records, follow the university’s Confidential Shredding Procedures.
- Electronic records are deleted or overwritten. Additional actions (e.g., purging) may be required to completely remove deleted records from an information system. Information custodians should work with their information service providers to ensure that all necessary actions are taken to destroy electronic records.
- Follow the Electronic Media Disposal Guidelines when repurposing or disposing of computers and other electronic storage devices.
- Destruction: Records whose information confidentiality classification is Public may be discarded or destroyed using non-secure methods. For example, public paper records can be disposed of in office recycling bins.
- Archives: All records in the records class become part of the University archives at the end of their retention period.
- Archives Selection: Some of the records in the records class are eligible for addition to the University archives. The retention schedule may include a description of the records most likely to become University archives, but the final selection of these records will be made by the Library Special Collections & Archives department.
Units should establish a regular routine for disposing of official records as suits their work schedule, typically at the end of the fiscal or academic year.
Documenting the Destruction of Records
A fillable PDF records destruction form and instructions for completing the form are available on the records destruction form page. If your unit uses an alternate means of documenting records destruction, your documentation should include the same information as the records destruction form. Completed records destruction forms have a retention period of 7 years, and belong to the records class IM60 – Information Collections Management, in the Information Management & Technology (IM) section of WatClass.
The Freedom of Information and Protection of Privacy Act (FIPPA) requires that disposal records not contain any personal information. For example, when documenting the destruction of student records or employment files, the names or other personal information of the students or employees cannot be included on the destruction form.
Completed destruction forms are to be printed, signed by the person approving the destruction, and kept on file in your unit. Why print and retain a hard-copy of the form? The records destruction form should reliably document our disposal actions at the time they occur. Since the content and date created/modified properties of an electronic file can be easily altered at any time (unless it’s stored in a document management system designed to monitor or prevent this), then an electronic copy of the destruction form isn’t trustworthy documentation of records disposal.
A small percentage of University records are of enduring historical value as the University’s corporate memory, and therefore become part of the University archives when their retention ends. As noted above, the disposition action for these records is either “Archives” of “Archives Selection.” The University Librarian is the information steward for the University archives, with responsibility for identifying and selecting archival records delegated to the Library Special Collections & Archives department.
Please contact the University Records Manager for further assistance with these records at the end of their retention period.
University Records, FIPPA, & Legal Holds
Legal requirements supersede University policy, the University records retention schedules, and their authorization of records destruction at the end of the retention period. University records are subject to the FIPPA and legal discovery. When a FIPPA access request is received, any records that are responsive to the request must not be destroyed until the request has been processed and any appeal period has elapsed. Similarly, records related to actual or pending litigation or government investigation must not be destroyed without the expressed permission of the University Secretary or delegate. This restriction begins from the moment any employee gains knowledge that legal action or a government investigation is reasonably foreseeable, and remains in effect until removed by the University Secretary or his/her delegate.