RECORDS RETENTION, RELEASE AND DISPOSAL POLICYPOLICY STATEMENT

RECORDS RETENTION, RELEASE AND DISPOSAL POLICYPOLICY STATEMENT

AIUE Records Retention, Release and Disposal Policy (“Records Policy”) is drafted to comply with AIUE requirement to retain financial aid applications and supporting awarding and payment documentation for a specified period of time after the student receives the aid. In addition, AIUE must retain academic transcripts indefinitely, and retain other records as required by federal or state law or in accordance with AIUE policy.

AIUE is also drafted to comply with various federal and state regulations for the release and disposal of covered records, including under FERPA and GLBA.

This Records Policy outlines the various records retention and release requirements AIUE personnel must be aware of and follow in order to be in compliance with federal and state law and AIUE policy.

These records must be maintained and disposed of according to procedures that are outlined in this Records Policy.

ADMINISTRATION

The Chief Technology Officer is responsible for developing and implementing policies governing the retention and disposal of UAT’s records.

The Chief Technology Officer will designate others, on an as needed basis, to assist in implementing the record retention policy, including the following:

• Identify and evaluate which records should be retained;
• Publish a retention and disposal schedule that is in compliance with applicable laws;
• Monitor applicable laws affecting record retention;
• Annually review the record retention and disposal program;
• Develop a training program for personnel responsible for record storage and disposal;
• Monitor for compliance with the record retention and disposal program.

Every designated working team will scrutinize the documents outlined in the Records Retention Policy relevant to their departmental role. The objective is to verify whether the records specified accurately reflect the records of that particular department.

For alterations to retention durations or deviations from the stipulated periods, and requests to amend the documented records, kindly submit your requests to the Chief Technology Officer. Any adjustments will be implemented only upon approval by Senior Leadership.

If a governmental audit, investigation, or pending litigation arises, the Chief Technology Officer, COO, or CEO may instruct the suspension of record disposal. RETENTION PERIODS

RECORDS

Click HERE to Examine the complete inventory of record categories along with their corresponding retention durations (link opens a PDF in a new window). RETENTION FORMAT

Typically, records can be stored in either electronic or paper form, retaining the original format upon reception or creation. It is essential to maintain records in a well-organized and easily retrievable structure, facilitating efficient and organized retrieval when needed.

Any special requirements, as listed herein, must be followed.

SPECIAL REQUIREMENTS FOR FSA RECORDS1. FSA Formats for Record Retention

A school must maintain all required records in a systematically organized and retrievable manner. Unless a specific format is required, a school may keep required records in hard copy, microform, computer file, optical disk, CD-ROM, or other media formats. Regardless of the format used to keep a record, all records (except ISIRs) must be retrievable in a coherent hard copy format. A coherent hard copy format includes, for example, an easily understandable printout of a computer file.

Any document incorporating a signature, seal, certification, or any validating image or mark must be preserved either in its original hard copy or in an imaged media format. This encompasses tax returns, verification statements, certifications, and SARs utilized for eligibility assessment. A school is permitted to retain a record in an imaged media format, provided the format can reproduce a precise, legible, and comprehensive copy of the original document. The printed copy must closely match the size of the original document..zzz

The SAR or ISIR must be kept in the format in which it was received by the school, except that a paper SAR may be maintained in either a hard copy or imaged media format. CUNY has the ability to preserve the ISIR data that it has maintained during the award year by archiving the data to a disk or other computer format.

Schools that participate in FSA programs must cooperate with the agencies and individuals involved in conducting any audit, program review, or investigation authorized by law by providing timely access to the requested records for examination and/or copying.2. Special requirements for SARs and ISIRs 

Special maintenance and availability requirements apply for SARs and ISIRs used to determine eligibility. It is essential that these basic eligibility records be available in a consistent, comprehensive, and verifiable format for program review and audit purposes.

Hard copies of SARs that students submit to schools must be maintained and made available in their original format or in an imaged media format. The ISIR, an electronic record, must be maintained and made available in its original format (e.g., as it was archived using EDExpress software supplied to the school). A school that uses EDExpress has the ability to preserve the ISIR data that it has maintained during the applicable award year by archiving the data to a disk or other computer format.

STUDENT RECORD REQUESTS

Record requests can be made in writing to the University Registrar at registrar@uat.edu, or if made by the student or authorized party on the FERPA release form, identity is verified by asking the caller to confirm the name and address on the FERPA release form. Academic records include course schedules, grades, transcripts, enrollment dates and earned awards. Financial records include cost of attendance, ledger card, award letters and financial estimates. RELEASE OF RECORDS

Records may only be released in accordance with UAT’s FERPA policy, with the permission of the student. With written request, records may also be released in response to a legally issued subpoena and, under other limited exceptions, without obtaining the student’s consent. If a verbal request for records is made by the student or an authorized party on the FERPA release form, identity is verified by asking the caller to confirm their name and home address on the form.

DISPOSAL OF RECORDS 

1. Paper Records

Documents should be retained for the duration of the retention period, and longer is required as a result of a litigation hold or other extension. If, after consulting with the Chief Operating Officer or CEO, it is timely and appropriate to dispose of any records, they should be destroyed by depositing the paper in a locked receptacle to be disposed of via shredding or otherwise destroying it in an approved manner that will prevent access to confidential paper information.2. Electronic Records

Electronic records, including emails, must be treated in the same way as paper records. Retention and disposition of electronic records depend on the function and content of the individual record.

Electronic records that are created electronically, or converted to electronic records, should be maintained as electronic records. University email is considered a University record, except for personal email. Emails should be kept in electronic format.

Individuals who keep records in electronic format must maintain those records in electronic format, which can be transferred, as directed by the individual’s department head, to SharePoint or another cloud-based system put in place and approved by AZ Information Technology Department Head.

Electronic records may be disposed of by erasing or deleting the record or otherwise destroying electronically stored data as approved by AZ Information Technology Department Head.

In some cases, electronic data may not be disposed of without affecting other data, in which case the record retention period will be waived to allow for the preservation of any related data that would otherwise be affected and disposed of prior to the end of the applicable data retention period.

In some cases, electronic data is not able to be erased or deleted, based on the requirements or limitations of the software or hardware used. In this case, the record retention period will be waived to account for the limitations on the disposal of data.

REVISED SEPTEMBER 2023