Gettysburg College Records Management Policy

Purpose of Policy

A records management policy serves as a resource for College employees informing the systematic care of records throughout their lifecycle promoting maintenance, control, evaluation, and preservation or disposition to support the continuation of College activities and adhere to legal or compliance recommendations. This policy will provide guidance for which records should be destroyed, retained for a limited period of time, or transferred to the College Archives for permanent retention because of their enduring historical or administrative value. It will also provide a definition of College Records that is flexible and adaptive to changing technologies and business practices.

Scope of Policy

This policy applies to all College employees who create records as part of their job functions. Records created by trustees, staff (including administrators and support staff), and faculty are covered by this policy. Records created by student organizations, especially those funded by Student Senate, may also be covered by this policy.

President Charles E. Glassick signed Gettysburg College’s first Records Management Policy on April 7, 1989. It was last updated on March 21, 2013. It established that records generated by administrative offices and by faculty when acting in an administrative capacity (e.g. Department Chair, Faculty Committees or Commissions – both elective and appointive) shall be and remain the property of Gettysburg College.

The College Archives operates as part of Special Collections and College Archives, a department within Musselman Library, and is responsible for the storage, preservation, description, security of, and access to records in any format that have enduring value for Gettysburg College. In the absence of a Records Manager or Administrator, the College Archives will work with College offices, departments, and employees to evaluate College Records, provide records management advice, and determine which records have enduring value and should be retained permanently.

This policy update reinforces the intention of the College’s previous Records Management policy by modernizing the language used to address technology changes and workplace practices. It acknowledges records management as a collaborative practice across campus. A College Record can take any format and includes electronic records like email. A College Record is determined by its content and is owned by Gettysburg College. College Records contain information of administrative, legal, financial, research, or historical value. The retention and disposition of College Records provides continuity for the College's business practices and internal procedures.

College offices, departments, and boards are expected to create, maintain, and adhere to a retention schedule that satisfies legal, financial, and administrative requirements of the College and the laws of local, state, and national laws. Each department or office will make determinations as to where active records are stored and disposal procedures for records not intended for permanent retention in the College Archives. The College Archives should be consulted when creating or revising retention schedules.

Definitions

Active records: Materials/information still being used by an office or individual and referenced regularly.

Appraisal: The process of determining the length of time records should be retained based on legal requirements and on their current and potential usefulness.

Archive: (n.) A physical or digital collection of historical records. (v.) To transfer records of continuing value to a repository and to preserve and manage those records.

Disposition: Materials' final destruction or transfer to archives as determined by their appraisal.

Evaluation: The process of assessing the value of records, especially as regards their destruction.

Evidentiary value: Proof or evidence of the “origins, functions, and activities” of the college and its creators.

Inactive records: Materials/information that are no longer referred to during the day-to-day business of a department and may be stored in a less accessible location.

Informational value: Anything regarding persons, things, and phenomena involving the college.

Life cycle: The distinct phases of a record's existence, from creation to final disposition.

Office of Origin: The corporate body or administrative unit in which a group of records is created or received and accumulated during the course of business.

Permanent or archival records: Materials/information created or received by a person, family, or organization, public or private, in the conduct of their affairs intended to be preserved because of the enduring value of the information they contain or as evidence of the functions and responsibilities of their creators. Permanent or archival records are not defined by medium, type, or material nature.

Record: Any fixed information or data used as an extension of institutional memory or to support accountability regardless of form or characteristics, made or received by Gettysburg College and its employees.

Records Management: The systematic and administrative control of records throughout their life cycle to ensure efficiency and economy in their creation, use, handling, control, maintenance, and disposition.

Retention Period: The length of time records should be kept in a certain location or form for administrative, legal, fiscal, historical, or other purposes.

Retention Schedule: The process of identifying and describing records held by an organization, determining their retention period, and describing disposition actions throughout their life cycle.

Transitory Record: a record of ephemeral value that can be destroyed immediately or after a short time period

Policy Description

Records’ Status

Records eligible to be evaluated for retention under the Records Management Policy are inactive records. These records are no longer used in the day-to-day operations of an office or department. Some offices or departments might find an annual evaluation of records is necessary; others might postpone evaluation until there is a structural or personnel change that naturally lends itself to evaluating record-keeping practices. Examples of records include, but are not limited to, the following:

Active Records	Inactive Records
· current policies and procedures · recent email conversations · current syllabi · handbooks · documents under revision · drafts of flyers or posters	· outdated policies and procedures · completed email conversations · syllabi of past classes · meeting minutes · completed grants or other programs · job advertisements · completed newsletters or advertisements

Retention Factors

Legal
Compliance with laws and regulations that require certain records to be kept for specific periods to mitigate legal risks.

Administrative
Support the operational needs of the College by retaining records essential for day-to-day decision-making, planning, and accountability.

Financial
Ensure accurate financial reporting and compliance with fiscal policies by maintaining records related to financial transactions, audits, and accounting.

Research
Support research activities by retaining records that contain information useful for internal analysis or studies.

Historical
Document the College’s history, legacy, or significant milestones by preserving records of enduring value.

Confidentiality

Records covered by this policy may be considered confidential for a variety of reasons including but not limited to the presence of personally identifiable information (PII), graded student work, records of donations to the College, and salary or hiring information. Special Collections and College Archives respects the privacy of College students and employees and adheres to Gettysburg College’s Privacy Policy and Information Management Policy, in addition to the policies and statutes listed below.

• Family Educational Rights and Privacy Act of 1974 (FERPA)

Student education records retained as part of Gettysburg College’s Records Management Policy or transferred to the College Archives are subject to the same FERPA compliance expectations as practiced by the Registrar’s Office.

• Health Insurance Portability and Accountability Act (HIPPA)

The College Archives does not purposely collect health records or medical information, however there may be legacy information in faculty employment or alumni files that would be subject to the HIPPA Privacy Rule.

• Gettysburg College Network Use Policy

“Gettysburg College endeavors to afford reasonable privacy for users of the Gettysburg College Network and systems, and does not access information created and/or stored by users except when there is a legitimate operational need to do so.”

Access to Records

Access to records retained through this policy is moderated by Special Collections and College Archives staff. Requests for files to be loaned or returned to their office of origin will be handled on a case-by-case basis. Special Collections and College Archives will follow the advice and instruction of the College’s legal counsel and Office of the President in the case of pending litigation that might require the retention or turnover of documents. Records determined to have permanent historical value will be transferred to the College and opened to researchers as described below; access restrictions may be applied.

Records Management and the College Archives

The College Archivist will identify which College Records have enduring historic value and should be retained permanently and transferred to the College Archives. These records will be open to researchers from the College community and beyond after their retention period has been completed and presuming, they contain no information that violates our confidentiality policies. If the office of origin requests restrictions on access to records, for example, records being closed to researchers for 25 years from their creation, these restrictions will be handled on a case-by-case basis in consultation with the College Archivist.

Policy Management

To respond to changes in technology, business practices, and staffing levels, this policy should be reviewed every 3 years by College Archives staff. If updates are needed, College Archives staff will make recommendations to relevant campus partners.

Related Materials

Family Educational Rights and Privacy Act (FERPA) - https://studentprivacy.ed.gov/ferpa Health Insurance Portability and Accountability Act (HIPPA) - https://www.hhs.gov/hipaa/for- professionals/privacy/index.html