Records Retention Policy

May 14, 2009

I. Introduction

Records created in the course of Hamilton College's academic and administrative operations support current administrative needs, meet legal requirements, and provide a rich source for historical research. Because the College does not have a centralized records management office, each department is responsible for the retention, disposal, and transfer of the records it generates.

The following guidelines will assist faculty and staff in identifying those portions of their files that are appropriate for retention and for transfer to the Archives. Original materials (see Sections III and IV below for details) should be retained in the office of origin according to office retention schedules (see attached). When the retained records become of historical interest only, they should be sent to the College Archives with an explanation of their importance.

II. Definition of Records

Official records consist of recorded information that is created or received by College employees in the course of performing official functions on behalf of the College. These may include items related to policies, decisions, procedures, operations, and external or internal transactions. These records are the property of Hamilton College. See Section III for items that are not official records.

Official records can be recorded on any physical form or medium, including paper or electronic. Examples of official records include memoranda, letters, reports, books, plans, maps, diagrams, pictorial or graphic works, photographs, film, recordings, e-mail, word-processed documents, spreadsheets, databases, and imaging systems.

III. Retention Schedules

Documents should be retained according to the attached Records Retention Schedule. Each office that generates official records must develop, update, and adhere to the official retention schedule pertinent to the responsibilities carried out in that office. These schedules include:

Description of Official Record
Recommended minimal retention period (Note that guidance on retention times for many types of official records are provided by law and/or professional associations.)
Retention period at Hamilton (which may be longer than mandated by law)
Where records are maintained
Method of disposal or records transfer
Departmental responsibility for maintenance and destruction of records
Whether these records should be transferred to the College Archives at the end of the retention period
Whether these records are confidential, and, if not restricted under FERPA, how long the restriction should last.

It is important to retain critical documents, but many items do not need to be retained. Records that should be disposed of at the end of their retention period include:

Records of specific financial transactions
Routine letters of transmittal and acknowledgment
Memoranda that are not personally addressed—except for one record copy from the issuing senior staff member
Requests for publications or information after the requests have been filled
Replies to questionnaires if the results are recorded and preserved either in the Archives or in a published report (which also should come to the Archives).

Items without a retention period, which may be discarded directly from the office when they are no longer needed for administrative purposes, include:

All blank forms and unused printed or duplicated materials
All other duplicate material, including received e-mail messages from other offices on campus: the originating office should keep only the original; keep annotated copies
Papers, reports, working papers, and drafts that have been published
Artifacts and memorabilia. The Archives does not collect non-paper objects except in cases of great importance to the history of the College and manageable physical size and condition. Please contact the Archivist to discuss options for preservation of such objects.

Where a record may fit into one or more categories with different retention periods, the record should be maintained for the longer retention period.

IV. Transfer to Archives

After the specified retention period in the office of origin, items of historical value should be transferred to the Archives. Space may not be immediately available; please consult with the Archivist about retaining these documents in the office of origin for an additional period.

Records commonly transferred to the Archives:

Constitutions and bylaws, minutes and proceedings, transcripts, lists of officers of the College and college committees, offices, and departments
Office and department files: correspondence and memoranda (incoming and outgoing), annual reports, subject files concerning projects, activities, and functions
Historical files documenting policies, decisions, committee and task force reports, questionnaires
Publications: one record copy and 3 circulating copies of all monographs, newsletters, journals, brochures, programs, and posters issued by the College or its subdivisions; the Archives should be placed on college, department, and office mailing lists to receive all future publications
Audiovisuals: photographs, films, and sound and video recordings
Personal papers of students, faculty, and staff that relate to the College's work.

Note: All information formats (e.g., published, typescript, audiovisual, and electronic data such as computer disks and files) are appropriate for consideration for transfer. Documents in formats requiring any form of machine intervention, such as videotapes and all computer files, should be converted to a format accessible to the Archives' users. Early consultation with the Archivist is strongly encouraged for such materials.

When materials are transferred, they should be kept in the order in which they were created and maintained in the campus office. A letter briefly identifying the material and describing the activity to which it relates should accompany the transfer.

In the absence of specific restrictions, all materials transferred to the College Archives will be opened to researchers on a nondiscriminatory basis, except those records that contain individually identifiable information, the disclosure of which is prohibited by the Family Educational Rights and Privacy Act of 1974. Records preserved in the Archives may be borrowed by the office of origin for its own use.

The Archives will retain electronic records of permanent or enduring value in formats and with migration schedules to maximize the future accessibility of their content. Routine data backup is not a substitute for placing electronic records with permanent value in the Archives.

The list is intended as a general guide. If questions arise about records not listed here or questions about the retention or disposal of specific records series, or whether particular records have permanent or enduring value, please e-mail the Archives at askarch@hamilton.edu.

V. Disposal

Disposal of records which have been maintained pursuant to this Policy and which need not be archived or kept should be destroyed. New York law requires that any sensitive or identifying personal information existing in such records (such as social security number, driver's license number, mother's maiden name, account number or code, or personal financial information) be disposed of in a manner that will prevent unauthorized individuals from accessing the information.

VI. Responsibility

It is the responsibility of every employee to comply with this policy.
It is the responsibility of any individual who supervisors, manages, or directs a department or function to ensure their employees are aware of the policy and adhere to it.
It is the responsibility of each Dean and Vice President to ensure their respective areas are in compliance with this policy so that the College may meet its operational and legal obligations and preserve its historical record.

Adapted from CNY Library Resources Council form, Mount Holyoke College Records Retention Policy, Wellesley College Records Management Policy, and Hamilton College Records Retention Policy draft 3.

Data Retention Schedule

Download Records Retention Schedule

Contact

Human Resources

Office Location

Philip Spencer House

Phone

315-859-4302