Carnegie Mellon University

 Financial Records Retention Policy

POLICY TITLE: Carnegie Mellon University Financial Records Retention Policy
POLICY OWNER AND RESPONSIBLE OFFICE: Office of the Vice President for Finance and Chief Financial Officer
CONTACT INFORMATION: Questions about this Policy should be directed to the Controller’s Office at x8-5158 or fin-recordsretention@andrew.cmu.edu
DATE OF ISSUANCE: This Policy was approved by the president on April 23, 2019.

ENTITIES AFFECTED BY THIS POLICY:

All academic or administrative departments, divisions and other business units of the university creating or receiving University Financial Records.
WHO NEEDS TO KNOW ABOUT THIS POLICY: Faculty, staff, temporary workers, student employees, consultants and agents of the university creating and/or receiving University Financial Records by or on behalf of the university.
DEFINITIONS: See Section III
FORMS/INSTRUCTIONS: Appendix A — Financial Records Retention Schedule [pdf]
RELATED INFORMATION:
RELEVANT DOCUMENTS:
REASON FOR POLICY/PURPOSE: The university is required to retain financial records as necessary to meet business needs and to comply with legal standards. The university also has an interest in setting appropriate retention periods for financial records to preserve university history, optimize the use of university space and minimize the cost of record retention for the university.
ABSTRACT:

This Policy outlines the requirements for the retention of financial records of Carnegie Mellon University (the “university”).

This Policy does not address the retention of records beyond University Financial Records, such as student academic records. Individuals should consult with the appropriate University Office for further information about the retention of other records.


I. Policy Statement

The university is required to retain University Financial Records as necessary to meet business needs and to comply with legal standards. The university also has an interest in setting appropriate retention periods for financial records to preserve university history, optimize the use of university space and minimize the cost of financial record retention for the university.

II. Applicability

The Policy applies to all academic and administrative departments, divisions and other business units of the university creating or receiving University Financial Records, including faculty, staff, temporary workers, student employees, consultants and agents of the university creating and/or receiving University Financial Records by or on behalf of the university. This Policy does not address the retention records beyond University Financial Records, such as student academic records. Individuals should consult with the appropriate University Office for further information about the retention of these other records.


III. Definitions

Official Repository

The University Office primarily responsible for maintaining the relevant University Financial Records as identified in the Records Retention Schedule in Appendix A.

Records Retention Schedule

The schedule appended to this Policy as Appendix A that identifies the material categories of University Financial Records, the Official Repository and the minimum Retention Period for those records.

Responsible Official

A knowledgeable employee within a University Office designated by that University Office as the individual responsible for the effective implementation of this Policy in their assigned area of responsibility.

Retention Period

The length of time for which the Official Repository is required to retain the related University Financial Records.

University Financial Records

Official records of university financial transactions. These records typically evidence the existence of the financial transaction or otherwise support or document the financial transaction’s accuracy, amount or other important information about the transaction. University Financial Records include documents, papers and other media, in physical or electronic form, created or received by or on behalf of the university, including by any university employee, consultant or agent for the university, and involving the financial transaction of university business, including copies of any of the foregoing.

University Office

An academic or administrative department, division or other business unit that creates or receives University Financial Records.

IV. Administration of Records Retention

Ownership of Institutional Records

All University Financial Records are the property of the university, and not the property of the individuals who create and/or receive such records.

Administrative Responsibility

The Finance Division is responsible for developing financial records retention processes and standards for monitoring compliance with this Policy.

The Office of the General Counsel provides guidance regarding the legal retention requirements for documents and issues Litigation Holds (as described herein) to preserve records, including University Financial Records, that are potentially relevant to actual or anticipated litigation. 

Computing Services provides technical guidance for the retention and destruction of records stored in electronic form.

Each University Office must designate a Responsible Official within that University Office that is responsible for the effective implementation of this Policy in the assigned areas of responsibility. The Responsible Official should have appropriate knowledge of and access to the University Office’s financial records. In addition to the Responsible Officials, all university employees are responsible for managing and maintaining the University Financial Records they create and/or receive in accordance with university policies, including this Policy.

Retention Periods

The Records Retention Schedule specifies the Retention Periods (including relevant exceptions) for the material categories of University Financial Records. Any material category or categories of University Financial Records that appear to have been omitted or not addressed adequately in the Records Retention Schedule should be brought to the attention of the Controller’s Office. As a default, unless the Records Retention Schedule for the relevant University Financial Record provides or contemplates otherwise, University Financial Records must be retained for a minimum of seven years from the end of the fiscal year in which the relevant financial record was created.

In the event a University Financial Record falls within multiple categories in the Records Retention Schedule, the University Financial Record is required to be retained for the longest Retention Period identified for those categories.

A University Office is only responsible for retaining a University Financial Record if designated as the Official Repository primarily responsible for maintaining the record.

A University Office that is not primarily responsible for maintaining the relevant University Financial Record (typically, as the Official Repository), but possesses copies of one or more of the relevant financial records is not responsible for retaining the records for the related Retention Period (excepted as noted below under Litigation Holds) and may dispose of the relevant records when they are no longer needed by that University Office.

Accessibility and Storage

University Financial Records that support the current business activities of the university should be organized, indexed and kept in a location where they are readily retrievable and accessible to the university and where they are reasonably secure from inadvertent destruction. University Financial Records that require retention in accordance with this Policy and are not in current use by a University Office and/or the university should be labeled and stored for the balance of the minimum Retention Period required by this Policy. University Financial Records may be stored with the Official Repository if suitable space is available, or by professional records management service vendors. All records, regardless of media, should be stored in containers capable of surviving the storage period while maintaining the physical integrity of the records. Records should be clearly labeled with a description of the contents, the responsible University Office, the origination date and the destruction date, if applicable. The university has negotiated agreements with several suppliers of professional records management services for off-site storage. For more information on off-site storage suppliers, contact Procurement Services.

Electronic Documents and Email

This Policy applies to University Financial Records whether existing in electronic or paper form. University Offices should retain or dispose of electronic records according to the requirements of the Retention Period for the relevant financial records, just as they are required to do for paper records.

University computing and/or financial systems may contain University Financial Records. Examples may include financial transactions in the Oracle Financial System (e.g., journal entries). The University Offices designated as Official Repositories for University Financial Records in such systems are responsible for retaining the financial records for the Retention Period required by this Policy. The following should be noted regarding journal entries:

  • Journal entries in Oracle that include attachments will be retained for the required Retention Period by Financial Reporting.
  • Journal entries in Oracle that do not include attachments will be retained for the required Retention Period by the originating University Office.

University Financial Records should not be retained solely in email, as the university’s email system is not intended for financial recordkeeping. If an email is part of a financial record (e.g., an email communication regarding an authorization of a financial transaction), the email should be saved outside of the email system in the same location as other records comprising the financial transaction at issue (e.g., emails authorizing a vendor invoice for payment should be saved with the Accounts Payable official record).


V. Disposal

Disposition of Records

University Financial Records for which there is a retention requirement in the Records Retention Schedule may be disposed of by the Official Repository (and/or deleted if retained in electronic form) following the conclusion of the related Retention Period for that record unless there is a business or other reason to retain the record, or unless directed otherwise to preserve the financial record.

University Offices other than the Official Repository need not retain any financial records for which there is no retention requirement (typically, duplicate records), unless there is a business or other reason to retain the record, or unless directed otherwise to preserve the financial record.

University Financial Records should be disposed of in ways that are appropriate and commensurate with the information contained within the records and with methods that do not permit recovery, reconstruction or future use of confidential or proprietary information contained within the financial records.

Paper University Financial Records may be disposed of via recycling in accordance with the university's recycling policy, except for paper records containing confidential or proprietary information (i.e., personally identifiable information). These records should be shredded in a manner that renders them unreadable and that would prevent them from being reconstructed.

Computing Services should be consulted for technical guidance on securely and appropriately deleting financial records in electronic form.

Suspension of Record Disposal for Litigation Holds

The Office of the General Counsel issues Litigation Holds, as needed, in response to actual or potential litigation, as well as subpoenas, document requests and government investigations or audits involving the university. Litigation Holds are typically directed to specific employees and identify the categories of potentially relevant records and documents (in both paper and electronic form) that must be preserved.

When an employee receives a Litigation Hold that covers University Financial Records, or other records within that employee’s custody or control, the employee shall inform the Responsible Official within the employee’s University Office and disposal of such potentially relevant records and documents subject to the Litigation Hold must be suspended until further notice from the Office of the General Counsel. Litigation Holds may apply to University Financial Records covered by this Policy, as well as duplicate documents, draft documents and other records not covered by this Policy.

The Responsible Official shall promptly inform all relevant staff of any suspension in the further disposal of relevant records and documents.

Record Retention Periods may be extended by government regulation, judicial or administrative consent order, private or governmental contract, pending litigation or audit requirements. The retention periods for these orders, contracts, litigation and other requirements supersede the requirements stated in this Policy.

VI. Archiving

Most University Financial Records are non-archival. However, University Financial Records designated as permanent or records of long-term historic value may be transferred to the University Archives. The transfer of archival University Financial Records to the University Archives shall be made in the manner and form prescribed by the Controller’s Office working with the University Archives.

VII. Exceptions

Exceptions to this Policy must be approved by the associate vice president for Finance and controller or the vice president for Finance and chief financial officer and, in the case of university legal-related matters, the vice president and general counsel.


Appendix A — Financial Records Retention Schedule [pdf]