Policy Handbook

technology 3

Record Retention & Destruction


Policy on Record Retention and Destruction

Summary of Policy:  to identify the record retention responsibilities and to document the storage and destruction of the College’s documents and records

Dept. or Position Responsible for Policy:  Finance & Operations Dept.

Date of Last Revision:  October 8, 2008


[Approved by President’s Cabinet on October 8, 2008]


The retention of records by Juniata College is required by many governing agencies, including the Internal Revenue Service, Employee Retirement Income Security Act (ERISA), and the Uniform Commercial Code.  In addition, the Labor Management Reporting and Disclosure Act of 1959 requires all records supporting a filing be kept for five years.  Furthermore, ERISA regulations require all records be kept for seven years. 

Therefore, the following record retention schedule is hereby established for Juniata College. 

Juniata is committed to reduce impacts on the environment in a number of different ways.  Therefore, it is Juniata’s recommendation that efforts be used as much as possible to move records into an electronic format to comply with the record retention requirements.  An excerpt from the Internal Revenue Service website dated August 2008 listing the electronic format guidelines for record retention is attached to this policy.



Five Years After Graduation or Date of Last Attendance

Three Years After Graduation or Date of Last Attendance

Two Years After Graduation or Date of Last Attendance

One Year After Date Submitted or After Graduation or Date of Last Attendance

Permanent While Active

Six Years

Three Years


Five Years After Graduation or Date of Last Attendance

Permanent Records

Six to Seven Years

Two to Three Years

One Year or Less


Five Years

One Year following Maturity

Recordkeeping & Disclosure requirements are governed by Federal regulations as found on the website link referencing the Federal Register that houses specific details:  http://www.ifap.ed.gov/sfahandbooks/attachments/Vol2Ch90809.pdf



Chapter 9 Highlights of those regulations include:

Required records

Record Maintenance

Access to records & personnel

Privacy of student & parent information


Excerpt from IRS website regarding Record Retention Requirements

Electronic Format Guidelines

August 19, 2008

In what format must the records be kept?

All records should be kept in a manner that ensures their complete access to the IRS for so long as they are material. While this is typically accomplished through the maintenance of hard copies, taxpayers may keep their records in an electronic format if certain requirements are satisfied.

Rev. Proc. 97-22, 1997-1 C.B. 652 provides guidance to taxpayers that maintain books and records by using an electronic storage system that either images their hardcopy (paper) books and records, or transfers their computerized books and records, to an electronic storage media. Such a system may also include reasonable data compression or formatting technologies so long as the requirements of the revenue procedure are satisfied. The general requirements for an electronic storage system of taxpayer records are provided in section 4.01 of Rev. Proc. 97-22. A summary of these requirements is as follows:

1.     The system must ensure an accurate and complete transfer of the hardcopy books and records to the electronic storage system and contain a retrieval system that indexes, stores, preserves, retrieves, and reproduces all transferred information.

2.     The system must include reasonable controls and quality assurance programs that (a) ensure the integrity, accuracy, and reliability of the system; (b) prevent and detect the unauthorized creation of, addition to, alteration of, deletion of, or deterioration of electronically stored books and records; (c) institute regular inspections and evaluations; and (d) reproduce hardcopies of electronically stored books and records that exhibit a high degree of legibility and readability.

3.     The information maintained in the system must be cross-referenced with the taxpayer’s books and records in a manner that provides an audit trail to the source document(s).

4.     The taxpayer must maintain, and provide to the Service upon request, a complete description of the electronic storage system including all procedures relating to its use and the indexing system.

5.     During an examination, the taxpayer must retrieve and reproduce hardcopies of all electronically stored books and records requested by the Service and provide the Service with the resources necessary to locate, retrieve, read and reproduce any electronically stored books and records.

6.     The system must not be subject, in whole or in part, to any agreement that would limit the Service’s access to and use of the system.

7.     The taxpayer must retain electronically stored books and records so long as their contents may become material in the administration of federal tax law.


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