Memorandum #313 Records Management and Retention Policy

Revised September 9, 2025
Date Issued: November 15, 2010
Approved by: Board of Trustees
Policyholder: Office of General Counsel

Purpose

The Purpose of this Records Management and Retention Policy (the “Policy”) is to:

• Establish accountability for College Records management and retention;
• Define certain terms relevant to College Records management and retention;
• Strengthen safeguards against the unauthorized or accidental disclosure of Confidential Records;
• Establish the length of time certain categories of College Records are required to be maintaineand stored;
• Establish the time at which certain categories of College Records should be destroyed, absent exceptional circumstances, in order to allow for the preservation of records maintenance space; and
• Establish appropriate College Records destruction practices and processes.

The College’s records management and retention program shall, as appropriate, incorporate existing policies and procedures, as described herein. For the definitions of capitalized terms contained in this Policy, see the “Definitions” section below.

Policy

Community College of Philadelphia (“CCP” or the “College”) is committed to complying with applicable laws and best practices with regard to the College Records it maintains, and to applying those laws and practices consistently across College Offices. This Policy applies to all College employees, both faculty and staff, as well as non-employees (such as contractors and/or volunteers), who conduct business on behalf of the College. Failure to comply with this Policy may result in disciplinary action (up to and including termination) and/or legal action. Known or suspected non-compliance with this Policy (e.g. known or suspected destruction of College Records that are required by this Policy to be retained) should be promptly reported to the General Counsel. Reports can also be made to the College’s hotline at: 1-888-261-1669 or www.ethicspoint.com.

This Policy requires the following: 

• College Records will be retained for as long as required by law and the College’s Records Retention Schedule (Attachment “A”), in a responsible and secure manner;
• College Records will be easily accessible and retrievable in a timely manner throughout their Required Retention Period;
• College Records will be disposed of after expiration of the Required Retention Period in accordance with the College’s destruction procedures; and
• Records with potential historical value to the College, but for which the Required Retention Period has expired, will be determined by General Counsel with approval of the President. General Counsel will perform an appraisal to ensure that records deemed to have enduring historical, administrative, legal, or fiscal value are preserved.   

Questions about this Policy should be directed to the General Counsel, unless otherwise indicated herein.

Definitions

College Business

Any transaction or regularly conducted activity of the College.

College Office

Refers to any academic or administrative unit of the College.

College Record

Information in any medium (paper, electronic, etc.) and in any form (documents, papers, correspondence, plans, photographs or audio or video recordings, etc.) generated at any time, at any location, in connection with College business. Personal papers of an employee that are unrelated to the function of that person’s academic or administrative unit, including scholarly materials produced by faculty and other materials unconnected to College activities, are expressly excluded from the definition of College Records.

Confidential Record

The following types of College Records are considered Confidential Records:

• “Education records” as defined by the Family Educational Rights and Privacy Act of 1974 as amended (“FERPA”);
• Individual personnel or employment records, including records which concern hiring, appointment, promotion, demotion, transfer, tenure, compensation, performance, layoff, termination, or other circumstances of employment;
• “Treatment records” as defined by FERPA and/or records that include "protected health information" as defined by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”);
• Records the use of which has been restricted by contract;
• Records which might expose the College to legal liability if treated as non-confidential; and
• Any records containing personal information or restricted personal information as defined by the College’s Personal Information Privacy and Protection Policy (Policy #320).

Duplicate Record

A copy of a College Record maintained by a College Office other than the Responsible Office.

Electronic Record

Any College Record that is created, received, maintained and/or stored on College local workstations or central servers, regardless of the application used to create that Record. Examples of Electronic Records include, but are not limited to, electronic mail, word processing documents, scanned documents, spreadsheets, and databases. Unless otherwise specifically set forth in this Policy, maintenance and disposition of Electronic Records shall proceed on the same basis as Paper Records.

Originating Office

The College Office where a College Record is first created or received from a sender external to the College.

Paper Record

Any College Record maintained in a hard copy paper format, regardless of whether the record was originally created on paper or as an Electronic Record.

Required Retention Period

The retention period set forth in the College’s Records Retention Schedule (Attachment “A”).

Responsible Office

The College Office responsible for ensuring that a particular College Record is maintained for the Required Retention Period. Where multiple College Offices are responsible for action related to a single College Record, those Offices should agree as to which will be responsible for record retention and destruction in order to minimize the number of copies kept, while ensuring that College Records are retained as required.

Records Management Coordinator

College employee(s) within the Responsible Office who are responsible for:

• developing and/or maintaining practices and procedures to ensure their College Office is meeting its record retention responsibilities under this Policy;
• coordinating retention, preservation, and destruction of records in accordance with this Policy, and secure storage of electronic and physical records in accordance with the Personal Information Privacy and Protection Policy (Policy #320) and other data security policies and practices of the College;
• ensuring employees in their College Office comply with the Policy and reporting any known or suspected non-compliance; and
• logging, tracking, and ensuring compliance with any litigation hold directives or similar (described further below).

The Records Management Coordinator is the head of the Responsible Office or their assigned designee.

Managing and Maintaining College Records

Digitizing Paper Records

With prior approval of the General Counsel, College Records may be scanned and converted to Electronic Records for the purpose of reducing storage costs and/or improving access to the information. It is essential that all significant details of the original Paper Record be included in the new Electronic Record. The reformatting process must be documented and the original Paper Record discarded. Digitization without preservation of the original Paper Record is not permitted if digitization would affect the legal status of the original Paper Record (e.g. wills, and certain legal notices). This is why prior approval of the General Counsel is essential before pursuing digitization projects. Note that simply scanning College Records into an empty drive will not be approved; there must be a system in place to ensure that the now-Electronic Records are organized, and that there are appropriate safeguards in place to prevent unauthorized access to and/or modification of the College Records.

Safeguarding Against Unauthorized or Accidental Disclosure

Until College Records are properly disposed in accordance with the Records Retention Schedule, each College employee is accountable for securing and maintaining the College Records of their College Office, regardless of format or location. Each College Office shall designate a Records Management Coordinator who is accountable for ensuring that employees and others within the College Office are compliant with this Policy, and that individuals are granted access to Confidential Records only when such access is essential to the performance of their duties. Further, each Records Management Coordinator is responsible for ensuring that reasonable safeguards are in place to protect Confidential Records, and ensuring that individuals within the College Office are trained in this Policy and the relevant information security protocols. At all times documents containing personal information or restricted personal information as defined by the Personal Information Privacy and Protection Policy (Policy #320) must be maintained in compliance with that policy and with privacy and data security law, including satisfying all security expectations for storing and transmitting Electronic Records and Paper Records, respectively, which contain personal information. In the event of a breach which could lead to the unauthorized or accidental disclosure of Confidential Records or personal information or restricted personal information more generally, an immediate report must be made to the General Counsel and the Associate Vice President, Information Technology, in accordance with that policy.

Depending on the Records involved, the College’s records storage area may be located off-site, in the “Vault,” or another location on campus. Supervision of the College’s records storage area lies with the Vice President for Business and Finance.

Adhering to the Records Retention Schedule

The Records Retention Schedule sets forth the length of time College Records should be retained by the Responsible Office. See Attachment A.

The General Counsel should be notified of any College Records not encompassed within the Records Retention Schedule. The General Counsel will determine, in consultation with appropriate personnel, whether to destroy the College Records in question, or add those College Records to the Records Retention Schedule.

Recognizing that the Responsible Office must maintain College Records in accordance with the Records Retention Schedule, Duplicate Records should be destroyed and disposed of as early as practical once no longer necessary to the operation of the College Office maintaining the Duplicate Record.

Certain categories of College Records are subject to a “review annually” Required Retention Period. Personnel in the Originating Office, in coordination with the Records Management Coordinator, will review those files annually, disposing of College Records that are no longer necessary for or relevant to the operation of the Originating Office.

Extending the Required Retention Period

College Records which have been retained beyond the Required Retention Period should be destroyed and disposed of, in accordance with this Policy, as early as practical.

Authorizing Destruction of College Records

Destruction of Electronic Records will be a coordinated effort between the Responsible Office and the Office of Information Technology Services. When the Required Retention Period for Electronic Records expires, the Responsible Office will initiate the process for the Records’ destruction and disposal. The destruction of those Electronic Records will be authorized jointly by the head of the Responsible Office and the Chief Information Officer. If those individuals are unable to agree, destruction will be stayed pending review and final determination by the General Counsel.

Paper Records which are no longer needed by the Responsible Office for the day-to-day operation of that Office may be identified by employees within the Responsible Office and transferred to the College’s records storage areas. When the Required Retention Period for those Records expires, the Responsible Office shall initiate the process for the Records’ destruction and disposal. The destruction of those Records shall be authorized jointly by the Vice President for Business and Finance and the head of the Responsible Office. If those individuals are unable to agree, destruction will be stayed pending review and final determination by the General Counsel.

If Paper Records are still located within the Responsible Office as of the expiration of the Required Retention Period applicable to them, the Records Management Coordinator of the Responsible Office will initiate the process for the Records’ destruction and disposal. The destruction of those Records shall be authorized by the head of the Responsible Office.

Safely and Securely Disposing of College Records

All Paper Records covered by the Records Retention Schedule shall be destroyed by shredding. All Electronic Records covered by the Records Retention Schedule shall be destroyed by or under the supervision of the Chief Information Officer or their designee.

Certifying Destruction of College Records

Upon destruction of Electronic or Paper Records, the individual responsible for the destruction must complete a Certificate of Destruction containing an inventory describing and documenting every Record, in any format, that has been authorized for destruction, as well as the date and method of destruction. See Attachment B.

The Certificate of Destruction will also identify the individual who was responsible for the Record’s destruction. The Certificate itself shall not contain confidential information. Two (2) copies of the Certificate of Destruction will be retained permanently: one in the Responsible Office and one stored electronically by the Office of Information Technology. The Responsible Office’s Certificate of Destruction may be retained in paper, digital, or other format.

Suspending the Records Retention Schedule: Litigation Hold Directives

When litigation involving the College or its affiliates is filed or threatened, the law imposes a duty upon the College to preserve all Records that pertain to the issues involved. Once aware that litigation exists or is likely to be commenced, the College’s General Counsel will issue a litigation hold directive to appropriate personnel. The litigation hold directive overrides the Records Retention Schedule. Records that may have otherwise been identified for destruction by the Records Retention Schedule should not be destroyed until the litigation hold directive has been lifted by the General Counsel. The suspension applies equally to Paper and Electronic Records, including Duplicate Records. No College employee who has been notified by the General Counsel of a litigation hold directive may alter or destroy a Record that falls within the scope of that litigation hold directive.

Any College employee who becomes aware of litigation or threatened litigation prior to receiving a litigation hold directive shall inform the General Counsel immediately and shall suspend the Records Retention Schedule until either (a) a litigation hold directive, defining the scope of the suspension, is issued by the General Counsel; or (b) the employee receives confirmation from the General Counsel that no litigation hold directive will be issued.

Related Policies

Personal Information Privacy and Protection Policy (Policy #320)

Right-to-Know Act (Policy #311)