University-wide Records Management Principles
The University Executive Compliance Committee endorsed the University-wide Records Management Principles on February 15, 2017.
The following outlines the University’s principles regarding records management and how the University handles its records. All members of the University community, including faculty, staff, student workers, and all others conducting business on behalf of the University, should understand the importance to the University of properly protecting and managing the records that it needs to keep, while disposing of the records that are no longer legally or operationally required to be maintained.
For the purposes of these Principles, records are defined as recorded information in any format used to conduct the affairs of the University and include, but are not limited to, hard copies, such as paper, and electronically stored information, such as word processed documents, databases, spreadsheets, digitized paper records, and email. Each department or unit is most knowledgeable about the content and use of its own records, and as such, academic and administrative departments and units are responsible for creating, updating, and maintaining department-specific practices for the maintenance, access and retention of their records, thus enabling effective and efficient management of University records. All such practices must comply with applicable law.
Each Central Administrative Office (defined in Section III below) is responsible for creating its own specific guidelines for records retention schedules and destruction procedures and plans that comply with the law and University policy. Academic and administrative departments and units are required to follow the guidelines provided by the Central Administrative Offices.
In developing specific practices, each Office of Record (defined in Section III below), including the Central Administrative Offices, should consult with the Office of the General Counsel (OGC) to ensure the legal appropriateness of the contemplated practices, and with University Records Management for best practices recommendations and additional guidance. Record retention and disposal practices should abide by the following overarching University-wide principles:
- Records will be retained, for as long as required by law and university policies, in a responsible and secure manner ensuring authenticity by utilizing reliable record keeping systems.
- Records will be easily accessible and retrievable in a timely manner from the Office of Record throughout their retention period.
- Records will be classified and protected throughout the life cycle of each record in accordance with the Information Security Policy (see link in Section IV below).
- Records will be retained and disposed of in accordance with records retention schedules and destruction procedures and plans that comply with the law and university polices. Records that are no longer legally or operationally required to be maintained should be destroyed by the Office of Record, unless the University Archivist deems the records deserving of permanent preservation.
- Records with potential historical value to the University will be determined by the University Archivist, who performs an appraisal process to ensure that only archival records are held permanently by the University. Recognizing the practical, fiscal, and space-related concerns associated with maintaining all records indefinitely, the University will permanently preserve only those records determined to have enduring historical, administrative, legal, or fiscal value.
- OGC will determine whether a given set of circumstances legally obligates the University to retain certain records, for example in connection with a threatened, likely, pending, or ongoing legal proceeding, and will notify affected individuals accordingly. Records potentially relevant to such legal proceedings must be retained by the Office of Record, even if those records would normally be destroyed under the Office of Record’s general record retention practices. All disposal of potentially relevant records must cease when a document hold is in place. OGC will notify the Office(s) of Record once it is permissible to resume usual recordkeeping practices.
- To help the University meet its legal record retention obligations, any individual who has reason to believe that the University has become, or is likely to become, a party to a legal proceeding (a lawsuit, administrative proceeding, government investigation, or government audit, for example) will immediately inform OGC.
III. Roles and Responsibilities
Office of Record: The department or unit that is the steward of the record and is responsible for making decisions related to the maintenance, access, and retention of the record, in collaboration with University Records Management and the Office of the General Counsel (OGC). The department or unit that generates a record is the Office of Record for that record unless and until that record is transmitted to, and accepted by, a Central Administrative Office, in accordance with the Central Administrative Office’s guidelines. At that point, the Central Administrative Office becomes the Office of Record.
Central Administrative Office: The distinguishing feature of a Central Administrative Office is that it maintains records generated by other administrative offices or academic departments which are transmitted to it, as well as maintaining its own records. Where the maintenance of such records is the responsibility of such Central Administrative Office, it becomes the Office of Record with respect to those records. Appendix A lists the Central Administrative Offices, the respective categories of records for which each is responsible, and links to the applicable guidelines.
University Records Management: University Records Management provides consultative services to the Office of Record regarding best practices within the context of the University-wide records management program. It is a unit within the University Archives that, prior to destruction of records, will determine the records which are deserving of permanent preservation.
Office of Audit and Compliance (OAC): The OAC serves as a proactive partner with University management and staff to upgrade business processes, internal controls and compliance mechanisms. The Institutional Compliance Program, within the OAC, facilitates compliance with the Records Management Principles through support and oversight. It works with Central Administrative Offices to enable the creation of specific guidelines, and may also perform reviews to provide assurance for adequate adherence to the Principles.
Office of the General Counsel (OGC): OGC provides guidance on legal retention requirements for records and also coordinates document holds when a legal proceeding (a lawsuit, administrative proceeding, government investigation, or government audit, for example) is threatened, likely, pending, or ongoing.
IV. Related Policies, Guidelines, and Resources
- Princeton University Records Management Website: https://records.princeton.edu/
- Information Security Policy: http://www.princeton.edu/oit/it-policies/it-security-policy/
- Protecting Student Records at Princeton (see online mini-MOOC on FERPA for Princeton Employees): http://www.princeton.edu/ogc/resources-1/
- Princeton University Policy Website: https://policy.princeton.edu/
V. Updates or Revisions
The Records Management Principles will be periodically reviewed for any necessary updates or changes.
The University’s Central Administrative Offices (based on offices of the Cabinet) include:
A. Facilities: Records pertaining to the construction and maintenance of University buildings and grounds.
B. Office of Admission: Records pertaining to undergraduate application and admissions records.
C. Office of Audit and Compliance: Records pertaining to audit and compliance projects.
D. Office of Campus Life: Records pertaining to the activities conducted by Campus Life and its affiliated units.
E. Office of the Dean of the College: Current and former undergraduate students’ records, other than application records.
F. Office of the Dean of the Faculty: Personnel records pertaining to current and former Dean of Faculty employees and Dean of Faculty position applicant records.
G. Office of the Dean of the Graduate School: Records pertaining to current and former graduate students and applicants.
H. Office of the Dean for Research: Records pertaining to the University’s research enterprise and/or all research conducted by or on behalf of the University.
I. Office of the Dean of the School of Engineering and Applied Science: Records related to SEAS administration and programs.
J. Office of the Executive Vice President: Records pertaining to the office’s operational and administrative committees as well as University environmental, health and safety practices and regulatory compliance and campus law enforcement and public safety.
K. Office of Finance and Treasury: University financial records [https://finance.princeton.edu/how-to/financial-management/record-retention/understanding-financial-r/index.xml]
L. Office of the General Counsel: University legal records.
M. Office of Human Resources: Records pertaining to current and former HR employees (including their dependents) and applicants [https://www.princeton.edu/hr/secure/record_retention.pdf]
N. Office of Information Technology: Records pertaining to the information technology systems and enterprise.
O. Office of the Provost: Records pertaining to the University budget and long-range planning and records of the functions managed by the Provost, such as institutional equity and diversity and academic programming.
P. Office of the Vice President for Advancement: Records pertaining to alumni affairs, donors, and philanthropic support.
Q. Office of the Vice President and Secretary: Records of the Board of Trustees and records pertaining to University communications, community and regional affairs, government affairs, and public affairs.
R. Princeton University Investment Company: Records pertaining to the University endowment.
S. University Librarian: Records pertaining to the acquisition, development, use, and preservation of, and access to library materials.
T. University Services: Records pertaining to campus dining, parking and transportation, printing and mailing, and other services provided by the units within University Services.
U. Woodrow Wilson School of Public and International Affairs: Records related to the Woodrow Wilson School administration and policies.