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Columbia University Records Retention Policy

Effective Date: May 2011

Revision: July 2015

Policy Statement

Columbia University’s Records Retention policy establishes the Records Retention Schedule (the “RRS”).  The RRS lists the types of University records and their retention period for records for which each department is the Office of Record.  It is based upon legal and operational requirements and provides a framework for the life cycle management of University records.

Reason(s) for the Policy

This policy is intended to assist the University in properly protecting and managing the records it needs to maintain, while eliminating the records that are no longer legally or operationally required. This will help to ensure that the University is following all applicable laws and regulations governing records retention and eliminating unnecessary records storage costs.

Primary Guidance to Which This Policy Responds

This policy responds to the various local, state, and federal statutes and regulations and internal policies that apply to records retention. 

Roles and Responsibilities

Office of Record

The Office of Record is responsible for identifying the records to be retained and determining, in collaboration with OGC, the period of retention.  The Office of Record must also make arrangements for the proper storage of the records and coordinate with outside vendors for that purpose, where appropriate. Finally, the Office of Record arranges for the handling of the disposal of records whose retention period has expired.

Office of the General Counsel

The Office of the General Counsel (OGC) is responsible for providing guidance regarding the legal retention requirements for documents and coordinating document holds when litigation is ongoing, pending, threatened, or likely.  The University’s General Counsel will designate one or more individuals to serve as the point of contact. 

Revision History

This policy revises an earlier version, dated May 2011.  The May 2011 policy codified existing retention policies and procedures under the University’s standard policy format. 

What Is Governed By This Policy

The specific records covered by this policy are listed in the RRS. Any record not listed on the RRS is not covered by this policy and should be retained in a manner consistent with existing practice and procedure.  Please note that the University has separate policies and procedures for records containing personal health information available at: http://www.cumc.columbia.edu/hipaa/.

Who Should Know This Policy

All University employees, including student workers and temporary workers

All contractors who create, use, or store University records

All consultants who create, use, or store University records

All vendors who create, use, or store University records

Exclusions & Special Situations (Document Holds)

Any records relevant to pending or ongoing litigation, government investigation, or audit MUST BE RETAINED until such matters have been resolved, all appeals are exhausted, and the retention period has expired.  All disposal of relevant records must cease, including the disposal of records according to approved retention periods, when such a document hold is in place.  In cases where litigation is threatened or likely, consult the Office of the General Counsel to determine whether a litigation hold is required.

Full Policy Text

Please see the Full Policy Text link to the right for a complete text of this policy.