POL 1.060 Document Retention
I. Purpose
To establish principles, responsibilities, and requirements for managing the College’s public records to ensure compliance with federal and state laws and regulations, policies, and best practices for managing records. This policy applies to all public records, regardless of whether they are maintained as hard copy (paper), digital, or some other format.
II. General
A. Definitions
Public Records: Recorded information prepared, owned, used, in the possession of, or retained by a public body in performing an official function from the time it was created. (Michigan Freedom of Information Act (FOIA) (MCL 15.231- 15.232, as amended)
Retention and Disposal Schedule: A legal document that defines how long each record should be retained, regardless of its physical format.
Confidential Records: Records containing sensitive or confidential student, patient, and client or employee data should have limited access and be protected from inadvertent disclosure. Confidential data is information protected by statutes, regulations, college policies, or contractual language.
B. Retention and Disposal
The Human Resources Department shall develop Records Retention and Disposal Schedules and make such schedules available to employees.
All employees are responsible for the appropriate disposal of records and other materials that have reached their approved retention period (as outlined in schedules to be developed by administration and included in Procedure 1.060) and are no longer required to operate the College effectively. Disposal shall be by a method that ensures the privacy of sensitive or confidential information.
Departments maintaining public records shall develop a records management plan consistent with this policy and applicable law. Employees shall organize the public records for which they are responsible for maintaining. Appropriate and cost-
effective office equipment, indexes, and tools shall be used to maintain public records.
C. Separation from Employment
Employees shall not take public records with them when their employment with the College is terminated. They shall only destroy records that have reached the end of their approved retention period (MCL 750.491, as amended).
D. Litigation, Investigations, and Freedom of Information Act Requests
No records that are the subject of litigation; pending, threatened, or imminent litigation providing a legal hold order has been issued by the Office of Risk Management and Legal Services (ORMLS); a pending investigation request; an imminent or scheduled audit; or a pending Freedom of Information Act (FOIA) request shall be destroyed until the legal action or activity has ended pursuant to a notice from ORMLS, even if the records are otherwise scheduled for destruction pursuant to this policy.
III. Responsibility
Responsibility for interpreting and administrating this policy is delegated to the Vice President of Business Operations or designee.
June 15, 2023
