Policy

The Records Management Program includes all records maintained by Colorado College faculty, students, and staff. The program also applies to others who may have access to Colorado College records through affiliation with the college as volunteers, Trustees of the College, third party administrators, contractors, or in other capacities. Record retention and disposition guidance stated in this policy shall apply to all record formats whether paper or electronic (email, spreadsheets, databases, imaged or word-processed documents).  As appropriate, this policy shall incorporate existing policies and procedures related to the management of records on campus.

Authorities Delegated/Administrative Responsibility

The President of the College delegates administration of the college’s Records Management Program to the AVP of Institutional Planning & Effectiveness.  Based on that delegation, the AVP of Institutional Planning & Effectiveness is responsible for overseeing the quality, consistency, and effectiveness of the college’s procedures related to records. This oversight includes (a) remaining current on record retention expectations, especially as related to external requirements (b) communicating those expectations to the appropriate parties (c) establishing and maintaining filing standards for records (d) authorizing and monitoring disposition of records (e) performing other records management duties as assigned.

Ownership of Institutional Records

All records, created, received, or used by Colorado College in the course of its operations and activities, regardless of physical location, are the property of Colorado College.

Accessibility of Records

Records should be easily retrievable by those authorized to access them and they should be in a readable format. For example, electronic records should not become unusable due to changes in technology. As record formats trend toward obsolescence, the college should identify records that could be adversely affected and transition them to a more suitable format. Alternatively, the college could retain the equipment necessary to accommodate the obsolete format.

Electronic records and paper records should not be rendered unusable due to deterioration.

Records procedures should include protocols that ensure that labeling conventions are consistent in order to support timely retrieval by those authorized to retrieve them.

Document Imaging

Any efficiency gained through document imaging should not be realized at the expense of document integrity (legibility). Procedures must ensure adequate indexing, storage, and retrieval of imaged documents.

Variances in Record Retention

In the event a record is subject to more than one retention requirement, the longer retention period shall prevail.

Safeguarding

Records should be stored and safeguarded with a level of security commensurate with the sensitivity of the information contained in the record. This effort to mitigate the risk of inappropriate access should be accompanied by comparable efforts to protect records from physical damage due to fire, water, or natural disaster.

Litigation, Claims, or Other Unforeseen Events

Record disposition shall be suspended (placed on hold) in the event of anticipated or ongoing investigation or legal proceeding conducted by or on behalf of:

- federal, state, or local government agencies (inclusive of tax, regulatory, and law enforcement);

- civil and criminal courts; or

- internal investigation, audit or review.

- or at the instruction of legal counsel

Disposition ­

At the end of the retention period, records that have not been placed on hold should be destroyed. Care should be taken that disposition is aligned in instances where the college has retained the same record in multiple formats: paper and electronic. Also, the method of destruction should be commensurate with the record’s level of sensitivity.    

 Disaster Recovery /Business Continuity

Risks to records include natural disaster (flood, fire); building fault (leaks, faulty sprinkler system); computer threats (viruses, hackers); human error (accidental deletion, destruction, or damage); and crime (theft, vandalism). Identification and implementation of internal controls adequate to address the likelihood and the magnitude of these risks should be identified by the college’s emergency preparedness team in conjunction with the college’s Internal Auditor.

Procedures

None

Definitions

Active Records –   Records needed to support current business activity of a department, division, or other organizational group supporting an institutional purpose. 

Archival Records – Records that provide evidential documentation of the history of the College or that provide information on persons, places, things and events connected with the College.

Data Classification – A methodology through which records are categorized into levels of sensitivity. The categories facilitate appropriate access and use of the records.

• Sensitive: Protection of the record is required by state and/or federal law or by Colorado College policy; classified as Sensitive, but achieving Colorado College’s mission requires that certain, specific and limited, faculty, staff or student workers have access;
• Confidential: Generally not available to the public;
• Public: Available to the general public.

Inactive Records – Records for which the active period has passed, yet they are being retained for the remainder of the specified retention period.

Institutional Records – Institutional records include, but are not limited to: official financial records, employment and payroll records, academic records, medical records, and any other records related to College operations.

Litigation Hold – The law requires the college to place a “hold” on certain documents in the event of threatened or impending litigation, or certain types of investigations or audits. The appropriate cabinet member will notify you when a hold must be implemented and the requirements of the hold.  When that occurs, in compliance with the hold instructions, you must immediately stop the destruction of any records covered by the hold, including such records that may be on an automated destruction schedule.  Be careful to review and understand the scope of any hold, the documents it applies to, and the individuals it may affect.  Please contact the appropriate cabinet member to discuss any questions or concerns you may have in connection with a hold.

Record – Information (in any form) received or created by the college to transact business or to conduct its affairs.

Retention Period – The minimum required length of time that a record is retained by the College in an accessible format.