Record Retention and Destruction Guidelines

Disposing of University Records

The following guidance is recommended for departments disposing of university records:

1. Check eligibility.
   1. Consult the Record Retention and Destruction Schedule to see if record retention period has expired.
   2. Records for which the record retention period is described as permanent may be eligible for archiving at University Archives.
2. Determine data classification.
   1. Consult UA’s Information Classification Policy determine if documents contain public, sensitive, or restricted/PHI data.
3. Dispose of information appropriately.
   1. Consult the Record Retention and Destruction Policy for guidance or contact CERA for assistance.
4. Complete the Record Destruction Report to verify destruction.

Storage of Physical Records

To transfer records to University Archives, fill out the Records Transfer Form (RTF) and the accompanying Box Inventory. Contact records@ua.edu for assistance if you have any questions.

For more information about storage and retrieval requirements, see the University Archives Records Management Program.

Litigation Hold

The Office of Counsel shall be responsible for interpreting any portions of the Policy statement as they may apply to specific situations. In the event of any actual or reasonably anticipated litigation, audit, governmental investigation, or similar proceeding (collectively, “litigation”), records and non-records potentially related to the litigation may not be destroyed and must be preserved until the litigation is closed and the retention period has otherwise expired. Accordingly, the destruction of all records and non-records under this policy potentially related to the litigation will be suspended upon commencement of the litigation, or when litigation is reasonably anticipated, so that appropriate steps can be taken to identify and preserve those records or non-records reasonably related to the litigation (a “litigation hold” or “lit hold”).

After the litigation hold is implemented, the prior suspension of this policy as to any affected records or non-records determined not to be subject to the litigation hold will be lifted, and the retention periods specified herein will apply thereafter.  The suspension of destruction and preservation of records and non-records potentially related to litigation as described above shall apply to all records and non-records, regardless of the form in which they are maintained, including without limitation e-mail, documents or files stored on computers, databases, any other electronically stored information, as well as hard copy documents and files.  Records for which the legal, fiscal, administrative, and archival requirements have been satisfied may be destroyed in accordance with the recommended minimum record retention schedules. When in doubt, confer with legal counsel before disposing of any record.

Recycling

Recycling is the preferred method to destroy records.  The designated recycling/shredder company must guarantee that the records were destroyed and are no longer recognizable as records.  The recycling/shredder company shall maintain a log or certificate of destruction indicating the types and quantities of records destroyed, the method of destruction, the destruction date, and agreeing to maintain the confidentiality of the documents it destroys. Any recycling/shredder company handling Protected Health Information (PHI) shall execute a Business Associate Agreement in conformance with the HIPAA privacy laws and regulations in a form satisfactory to UA.