UNIVERSITY OF THE VIRGIN ISLANDS BOARD OF TRUSTEES RESOLUTION ON POLICY FOR RETENTION, ARCHIVAL AND DISPOSAL OF DOCUMENTS OF THE BOARD OF TRUSTEES OFFICE Purpose: Approval of Policy for Retention, Archival and Disposal of Documents of the Office of the Board of Trustees WHEREAS, at its meeting on January 29, 2013, the Committee on Trustees of the Board of Trustees of the University of the Virgin Islands (the University) reviewed a draft Policy for Retention, Archival and Disposal of Documents for the Office of the Board of Trustees, the purpose of which is to establish a standard for documents-retention to ensure that the Office retains documents in compliance with applicable laws, minimizes the cost of retaining important documents, protects the organization against potential allegations of self-serving destruction of documents, and to provide for routine destruction of superfluous and outdated documents; and WHEREAS, The Committee unanimously voted to submit the Policy to the Board of Trustees with the Committee’s recommendation that the proposed policy be approved by the Board; NOW, THEREFORE, BE IT RESOLVED BY THE BOARD OF TRUSTEES OF THE UNIVERSITY THAT: The Policy for Retention, Archival and Disposal of Documents for the Office of the Board of Trustees, submitted by the Committee on Trustees to the Board of Trustees, a copy of which is attached as Exhibit A, is hereby approved. CERTIFICATION The undersigned hereby certifies that the foregoing is a true and exact copy of a resolution of the Board of Trustees of the University of the Virgin Islands adopted at its meeting on Saturday, March 9, 2013, as recorded in the Minutes of the said meeting. March 9, 2013 Secretary of the Board Date EXHIBIT A UVI Board of Trustees Office DOCUMENT RETENTION, ARCHIVAL and DISPOSAL POLICY PURPOSE To provide a system for complying with document retention laws; to ensure that the Office of the Board of Trustees (BOT) retains important documents in a systemic way and minimizes the cost of retaining such documents; to protect the organization against allegations of selective document destruction; and to provide for routine destruction of non-business related, superfluous and outdated documents. This policy applies to printed and electronic documents housed in the office of the BOT. If a document exists in both forms, only versions shared must be retained according to the schedule below. The Office of the BOT is committed to effective record management to meet legal standards, preserve its history, optimize the use of space, and minimize the cost of record retention. RETENTION It is prohibited for any employee of the University to knowingly destroy a document in the custody of the Board of Trustees, or remove it from the Office of the Board of Trustees with the intent to obstruct or influence the investigation or proper administration of any matter within the jurisdiction of any university department or in relation to or contemplation of any such matter. Employees in the Office of the BOT are required to comply with the documentation standards outlined in this policy. Failure to comply may result in disciplinary action, up to and including termination of employment. Employees with questions about this policy should consult with management or seek legal advice. Documents that shall be retained for the period of time specified in the table below. Notwithstanding the retention period specified in the table below, no document shall be destroyed while it is the subject of a subpoena or a Demand for the Production of Document. In general, documents that are not subject to a retention requirement should be kept only long enough to accomplish the task for which they were generated. All employees in the Office of the BOT are responsible for adhering to this policy. Questions about specific documents or types of documents should be addressed to the staff member’s supervisor. The following table provides the minimum requirements. Type of Document Minimum Requirements External Audit Reports commissioned by the BOT 7 years Contracts, mortgages, and leases The effective period thereof plus 7 years Correspondence (general) 2 years Correspondence ( legal matters) 7 years beyond the statute of limitations for litigation on the subject covered in the correspondence Correspondence ( routine requests, vendors, customers) 2 years Email and any files attached ( unless other provisions to this policy apply) 2 years Internal Audit Reports 3 years Minutes of Board meetings and attached documents Permanently Minutes – Committees 1 year after approval by committee and distribution for Board’s approval Bylaws and Charter and amendments adopted thereto Permanently Expense reports – Check requisitions 3 years Year-end Financial statements 3 years Audiotapes of meetings of the Board and its Committees Until Minutes are approved. ARCHIVAL Restricted information, executive session materials, in paper or electronic format, which is not being actively used, may be stored in a secured location outside the Office of the BOT until the retention period has expired. Printed documents may be converted into an electronic format for further storage. a. Primary records of the Board of Trustees will be archived. b. All records that contain restricted information must be stored in physically secured areas that are protected from unauthorized access, damage, (e.g., by fire, water, insects, and other pests), that are environmentally controlled for temperature and humidity. c. Records should be organized and store to facilitate easy retrieval by authorized BOT staff members. d. No one shall remove records from the custody of the BOT without the authorization of the liaison to the Board of Trustees. DISPOSAL Primary records containing restricted information shall only be destroyed during scheduled destruction periods; no record shall be destroyed on an individual basis. Disposing of Non- Primary Records containing restricted information (i.e., duplicate, extra, or obsolete individual reports or data) a. Destruction: paper records and records stored on electronic media must be either shredded, pulverized, or electronically purged, or placed in locked or otherwise secured storage pending such destruction. See Record Destruction Chart below. b. Recycling: Papers containing restricted information may be placed in secured bins pending recycling. Destroying Primary Records, containing restricted information, whose retention period has expired. a. Maintain records that are scheduled for destruction in a secure location to guard against unauthorized or inappropriate access. b. Follow the record destruction protocol for carrying out the actual destruction. c. Maintain a log of record of destruction for the life of the institution. Appropriate Record Destruction Methods Medium Recommendation Paper Records Shred (preferably cross-shred), burn, or pulverize Audiotapes Recycle by recording over by the original user, or pulverize the tape and cassette Computerized Data / Hard Disks/ Magnetic Media/ Memory Sticks, and other memory devices Professionally purge by a certified, licensed, and bonded vendor and pulverize Computer Diskettes Reformat and overwrite all data, pulverize, or magnetically degauss Laser Diskettes / Compact Disks Shred or pulverize in appropriate equipment, OR break, using layers of newspaper and a hammer, OR thoroughly scratch both sides with knife or key Acknowledgements and Credits This proposed document retention policy draws on storage, retention, archiving and disposal policies and guidelines developed by various colleges and universities to the extent that research identified those policies as best practice. The institutions from which policy guidance was drawn include the following: • The George Washington University • The University of North Carolina – Chapel Hill • University of Michigan • University of Florida • Clark Atlanta University • Pennsylvania State University • Delaware State University • Cornell University • Rutgers University Submitted by: Gail T. Steele Liaison to the Board of Trustees Approved by Committee on Trustees January 29, 2013 Microfilm / Microfiche Shred or pulverize only