Everyone. Due to legal requirements, anyone who conducts business for or on behalf of the University must comply with the Record Management Policy. Failure to comply with the policy may result in disciplinary action (including dismissal). In addition, anyone who intentionally destroys or tampers with records in violation of the policy may face civil or criminal liability, which could include serious fines, debarment from governmental programs, or imprisonment. Department Heads have additional responsibilities and should refer to the policy (and the on-line training material) for more information. The Custodian of Record is the department specifically responsible for retaining a specified original University Record as designated under the policy’s Record Retention Schedules.

Only University Records are subject to the policy. The policy defines University Records are any records that are created or received in the ordinary course of University business. Any records not related to University business should be immediate destroyed. In addition, only certain University Records are required to be retained for a longer period once it is no longer needed to conduct University business – these records are listed under the Record Retention Schedules. If a University Record is not listed in the schedules, then it must be destroyed once it is no longer needed for business purposes unless (1) another University policy requires further retention (e.g. Litigation Discovery policy) or (2) it holds historical value (consult University Archives or the College of Medicine’s Legacy Center).

Note that copies of University Records should be destroyed once they are no longer needed for business purposes provided further retention is not required under another University policy (e.g. Litigation Discovery policy), or that they are not the only copy available if they have historic value).

Look up the University Record in the Record Retention Schedules. If the University Record is not listed on the schedules, departments must destroy the record once it is no longer needed for business purposes unless (1) another University policy requires further retention (e.g. Litigation Discovery policy) or (2) it holds historical value (consult University Archives or the College of Medicine’s Legacy Center). If the University Record is listed on the schedule, determine if your department is listed as the Custodian of Record. If so, your department must retain the Universtiy Record for the length of time designated under the schedule. If not, the University Record should be forwarded to the Custodian of Record. Note that the Custodian of Record is responsible for retaining the original University Record and not copies of such record. Copies should be destroyed once they are no longer needed for business purposes provided further retention is not required under another University policy (e.g. Litigation Discovery policy), or that they are not the only copy available if they have historic value. .

Assess the subject matter of the University Record. Determine which of the 15 schedules would be relevant to the University record. Review the relevant schedule(s) then, either (1) scan the “Specific Category” column and narrow down to the Type of Record or (2) use the Find function (press Ctrl+F) and search the schedule using key words.

If a University Record is not listed in the schedules, then it must be destroyed once it is no longer needed for business purposes unless (1) another University policy requires further retention (e.g. Litigation Discovery policy) or (2) it holds historical value (consult University Archives). However, if you believe that the record should be retained for any of the following reasons do not destroy the record and contact the Office of the General Counsel:

• Existing regulatory or other legal requirements or guidelines require further retention
• Other business need requires further retention
• The record is relevant or may be relevant to any actual or potential lawsuit or other government action.
• Any other reason.

When in doubt, contact the Office of the General Counsel before destroying the University Record.

Keep it and contact the Office of the General Counsel immediately. The University and its members have a legal obligation to preserve and produce evidence, which includes relevant University Records, of any actual or potential lawsuit or other governmental action. This legal obligation applies to any and all legal actions. It does not matter whether the University is a plaintiff or defendant. It does not matter if the University is even a named party. It also applies to any governmental investigations, including agencies (e.g. SEC, HHS, OHRP, FDA, OIG).

If the records have not been destroyed, attempt to retain and protect the records and notify the Office of the General Counsel immediately. If the records have already been destroyed, notify the Office of the General Counsel immediately.

You may also use the Drexel University Compliance Hotline or College of Medicine Hotline if you wish to report confidentially.

Yes. The retention schedules cover all University Records regardless of format(e.g. hardcopy, electronic format). Determining whether a record should be retained depends on its content and subject matter, not its medium.

Yes. However, if a department that serves as the Custodian of Record of a University Record wishes to change the format of that record from hardcopy to electronic form, the department must first obtain approval from the University Records Management Archivist and the Office of Information Resources & Technology. Note that simply scanning University Records and retaining in a share drive will not be approved. Electronic scanning and storage of hardcopy records require systems that contain proper safeguards to ensure unauthorized access and/or modification of the University Record.

Steps in the approval process as well as guidance for developing imaging procedures can be found on the University Archives Website.

For more information about obtaining approval, please contact:
Alexis A. Antracoli
Records Management Archivist
University Archives
215.895.6472
aaa366@drexel.edu

Yes. The Custodian of Record may maintain an electronic copy of the University Record and retain the official copy in storage so long as the stored original copy can be readily identified and retrieved from storage. Be aware that when the hardcopy is destroyed, the electronic copy should be destroyed as well.

Yes. However, you must first obtain approval from the University Records Management Archivist and the Office of Information Resources & Technology. You also must use a centrally managed system to retain the scanned documents and adhere to the overall Document Management Policy.

Digitized documents are legally valid and courts allow their use, particularly when the documents are stored in a centrally managed system. There are some exceptions, though, such as wills, family law documents (including adoption and divorce documents), and certain legal notices (including health or life insurance termination and dangerous-product recalls). So, always check with the Office of the General Counsel.

We further recommend adding a disclaimer to paper documents that are going to be signed indicating the signed document may be digitized. Here is an example: "Disclaimer: This document may be stored electronically. By signing this document you acknowledge that your signature is equally valid whether in original paper or electronic form."

If the documents relate to Pennsylvania real estate, the above requirements apply. Pennsylvania law allows digital documents to be used in real estate transactions. If the real estate is located in another state, the Office of the General Counsel should be contacted.

Yes, subject to the same requirements above.

Yes, subject to the same requirements above.

No. Scanning a document does not change how long it must be retained.

The IT Department is responsible for maintenance and security of the University’s electronic environments. This includes the University’s centrally managed databases (e.g. Banner, AllScripts, IDX). With regard to compliance with the policy, the IT Department is not responsible for the University Records contained in the University’s electronic environment and these databases. The department that serves as the Custodian of Record for such University Records is responsible for ensuring that such records are retained in compliance with the Policy. If necessary, it is the Custodian of Record’s responsibility to contact the IT Department to ensure that electronic databases are programmed to retain and destroy their University Records in compliance with this policy.

Each University Member (e.g. any person conducting business for on behalf of the University) is responsible for his/her own email account. This means that email content should be evaluated to determine proper retention or destruction based on the record retention schedules. The IT Department is responsible for maintenance and security of the University’s email infrastructure. The IT Department is not responsible for reviewing content of such email.

Yes. E-mail should be treated the same as letter correspondence. Determining whether a record is required to be retained is based on the content of each individual email. Using the record retention schedule, University members should review the content of an email and determine whether it is required to be retained under the record retention schedules.

Since most e-mails are transitory in nature, most will not be required to be retained and can be destroyed. However, it is the responsibility of the University member to determine the retention or destruction of his/her own e-mail in compliance with the policy as well as other University policies (e.g. Litigation Discovery policy). Remember, both the University Archives and the College of Medicine’s Legacy Center also collect electronic records, such as email, as well as hardcopy records, for their historical value.

Drexel University Archives and the College of Medicine’s Legacy Center specializes in the retention of historical records. In addition, some historical University Records have been maintained by various departments throughout the University. The current schedules list these departments as the Custodian of Record. Plans to move these historical University Records to the Archives are underway. If you believe that your department holds University Records that hold historical value, do not destroy them until you have consulted University Archives of the Legacy Center.

No. Department’s on-campus storage facility must meet certain minimum record management standards. If your department’s current on-campus storage space does not meet these policy requirements, you must use the University’s designated off-campus storage facilities, DocuVault. Contact DocuVault to assess and determine your department’s storage needs.

Compliance with the updated Record Management policy is required. In most circumstances, departments should already be in compliance with the policy. If a department determines that it is not compliant with certain aspects of the updated policy, it should assess what is needed to become compliant. If off-site storage is needed, DocuVault should be contacted to assess those storage needs. Upon request, DocuVault will provide an estimated annual budget.

Departments may choose to use any of DocuVault’s cradle-to-the-grave record management services. DocuVault provides the following services:

• Off-site storage
  • On-line account management (at box level and indexed-records level)
  • Indexing services provided when sending records off-site. Indexed records listed on-line for easier maintenance, retrieval, and destruction.
  • Retrieval, electronic scanning services (for indexed records only), and destruction services
• Daily record destruction services upon request (shredding and recycling) by providing HIPAA-compliant shredding receptacles
• Off-site record destruction services upon request (shredding and recycling)

Please refer to the on-line DocuVault presentation found on the policy’s webpage or the University Procurement page or contact DocuVault directly.(kcowles@docuvaultdv.com)

Non-confidential records should be recycled. Confidential records should be shredded in a manner that renders them unreadable and that would prevent them from being reconstructed. Security should be maintained until proper destruction is performed.

Members should simply delete e-mails and electronic documents.

The Custodian of Record for the Universtiy Record is responsible for ensuring proper destruction. If programming of the database system is needed, the IT Department should be consulted.

In order to facilitate manageable destruction practices, the record retention policy allows you to extend the expiration date of any University Record that expires during a calendar year to December 31st of that year. This way, all University Records expiring in a given calendar year can be properly destroyed at the same time.

For example, if a department’s records expire on February 1st, June 26th and November 30th, the department may choose to extend all expiration dates to December 31st and conduct proper destruction of all these University Records at the same time. In addition, a department may also choose to index and collectively store inactive University Records by the year of expiration. This will make it easier to identify and retrieve University Records that expire on the same date. Note that University’s designated off-site storage facility, DocuVault, offers indexing services.

The short answer is that any time you are about to destroy a University Record, ask yourself whether the record has historic value. If it holds historic value, contact University Archives or the College of Medicine Legacy Center. According to the Record Management policy, University Records are usually destroyed under one of the following circumstances:

• The University Record is no longer needed for business purposes and it is not required to be further retained since it is not listed under a Record Retention Schedule.
• The University Record is required to be retained permanently under a Record Retention Schedule because it has historic value.
• The University Record has been retained in accordance with a Record Retention Schedule and now the retention period has expired and the record is not required to be retained by any other University policies (e.g. Litigation Discovery policy).

Not at all! University Archives and the College of Medicine’s Legacy Center collect records created yesterday as well as 100 years ago.

For detailed descriptions of what we collect, see:

• University Archives site, and
• College of Medicine Legacy Center site.