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Procurement Document Images as Document of Record Policy

Effective Date: May 2011

Revision: July 2016


Policy Statement

Pursuant to Columbia University’s Records Retention policy, this policy establishes electronic images of documents provided as supporting documentation for Accounts Payable, Purchasing and Vendor Management transactions as documents of record for Procurement Services and the University.

Reason(s) for the Policy

This policy is intended to provide guidance regarding which University records can be officially retained in a digital/electronic format.  This policy also provides guidance for disposal of their paper counterparts in accordance with the schedule provided in Appendix A to this policy. 

Primary Guidance to Which This Policy Responds

This policy responds to IRS Revenue Procedure 97-22 and IRS Revenue Procedure 98-25.  This policy is also guided by and in accordance with Columbia University’s Records Retention policy.

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.

Responsible University Office

Procurement Services 

Who 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


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.