Records Document Retention Policy

Introduction

This policy establishes guidelines for the retention, protection, and appropriate disposal of records and information at Maryville University (“University”). The purpose is to ensure that records are maintained as long as necessary for legal, operational, and historical reasons, and are disposed of securely when no longer required. All University employees are expected to comply with these guidelines.

Administration and Responsibility

Each office or department is responsible for implementing and maintaining compliance with this policy. Departments may adapt these guidelines to address specific legal or operational requirements relevant to their functions. Questions regarding records retention should be directed to the designated records management contact within each office or department or the Office of Compliance and Legal Affairs.

Forms of Records

This policy is media-neutral: retention requirements apply equally to records regardless of format (e.g., paper, electronic, audio, video). The policy does not require creating records that already exist.

Records in Multiple Categories

If a record falls under more than one category, retain it for the longest applicable retention period.

Electronic Back-Up

Each department is responsible for understanding and following University procedures regarding electronic data backup. This includes ensuring that records stored or backed up on servers, cloud storage, or other electronic systems are managed in accordance with this policy. Note: Data stored on individual users’ computers may not be backed up centrally; users are responsible for compliance with this policy for their own files.

Confidential Records

Confidential records must be disposed of securely at the end of their retention period, such as by shredding or using secure electronic deletion methods, to ensure confidentiality is maintained.

Exception – Permanent Retention

Notwithstanding the standard retention periods set forth in these guidelines, the University retains in perpetuity official, summary-level student enrollment and attendance records that form part of the student’s official academic record or are required to document historical enrollment, academic participation, degree verification, accreditation, or other legitimate institutional, legal, or regulatory purposes, provided such records are maintained in the University’s designated system(s) of record.

This exception does not apply to detailed, transactional, or system-generated attendance data (including but not limited to daily or course-level attendance logs, learning management system activity, access or card-swipe data, or faculty tracking notes), which shall be retained and disposed of in accordance with the applicable retention period unless subject to an investigation, audit, program review, accreditation review, legal action, or litigation hold as described in Section X of this Policy.

Investigation and Litigation Holds

Do not dispose of any records if you are aware of or have been notified about an investigation, legal action, audit, program review, or accreditation review involving the University. Employees must immediately notify their department’s records management contact if they become aware of any of the following:

• The University has been served with a subpoena or document request.

• There is a governmental investigation or audit.

• Litigation is pending or anticipated.

The Office of Compliance and Legal Affairs will then issue a hold on the disposal of relevant records until further notice, in consultation with legal counsel as needed.

Policy Review and Updates

This policy will be reviewed every two years or as needed to ensure continued compliance with legal, regulatory, and operational requirements. Updates will be communicated to all affected employees, and acknowledgment of receipt may be required.

Records Retention Schedule:

Table 1 Record Retention Schedule