Responsible Office(s): Academic Affairs; University Administration; Student and Community Affairs; Admissions and Financial Aid; Human Resources
Purpose: This Policy addresses the retention and disposal of Ashesi University’s Records. The University requires that Records be retained for specific periods of time (up to 7 years) taking into account legal or other institutional requirements.

The Provost and the Chief Operating Officer of the University, have the general responsibility for ensuring that appropriate policies and procedures are in place to ensure compliance with best practices in record keeping standards and legislative requirements. In addition, duplicate or multiple copies of these records, retained in locations other than official repositories, must also be properly disposed of when they are outdated and no longer useful. This policy is intended to ensure that the university: meets legal and regulatory standards; reduces risk by prioritizing the disposal of confidential data contained in inactive records; optimizes the use of electronic and physical storage space; minimizes the cost of record retention; preserves the history of the university; and destroys inactive records.

Managing Official University Records
Users throughout the community share in the task of adhering to the retention and disposal policy. Units that maintain university records are called “official repositories.” They are responsible for establishing appropriate record retention management practices based on this policy and other department specific needs. Official records should be stored consistently within the unit in a manner that provides protection against misuse, misplacement, damage, destruction, unauthorized exposure, or theft. Each official repository’s administrative manager or a designee must: implement the unit’s record management practices; ensure these management practices are consistent with the policy; educate the staff within the unit in understanding sound record management practices; ensure that records are retained in a readable format regardless of changes in technology or equipment obsolescence by 1) printing out archival or permanent documents and saving to a file system, 2) maintaining the old equipment and software applications, or 3) migrating the records to a new technology; preserve records of historic value, consult with the Provost or COO and transfer those records to the university archives if necessary; preserve permanent records within unit; destroy inactive records that have no archival value upon passage of the applicable retention period; ensure access to confidential files is restricted to authorized users only; and ensure that outside vendors used for record storage follow the university’s record retention policy.

Preserving Official University Records
When University records, regardless of format, become inactive, consult with the COO or Provost Office to determine if Permanent (Archival) Records should be transferred to the University Archives, or permanently maintained in the unit where it originated or was received. Most University records which contain employment, personnel or legal information should be treated as confidential, non-archival records. Please contact the Director of Human Resources immediately if you have a question about the characterization of a record with this type of information

Disposing of Official University Records
If you have determined that it is appropriate to dispose of the records, destroy them in one of the following ways:

1. Paper Records: Non-confidential paper records may be recycled.
2. Confidential Records: Shred or otherwise render unreadable records with confidential information, including social security numbers, credit card information, driver’s license information, or other information designated confidential. Appropriate measures need to be taken when disposing of records containing personal identifying information, such as a name, address, phone number, personal mark, or other identifier that can be used to identify a person, when coupled with one or more data elements including social security number, driver’s license number, mother’s maiden name, financial services or bank account number, etc., by 1) shredding the record, 2) destroying the personal identifying information contained in the record, 3) modifying the record to make the personal identifying information unreadable, or 4) taking reasonable actions consistent with commonly accepted industry practice.
3. Electronic Records other than Email: The IT Department, in consultation with the COO, arrange for the proper disposal of all electronic devices or media in a manner that prevents inadvertent loss or disclosure. Other Ashesi University policies and applicable law also govern proper disposal of Ashesi University related information and licensed software on electronic devices and media. In addition, proprietary information may also be subject to the terms of sponsored research agreements, non-disclosure agreements, or license agreements. Unit administrators are responsible for contacting the Ashesi Support Centre, who will assist in ensuring that these stated guidelines are followed. The information on any computer hard drive, smart phone, or other electronic device must be erased and not recoverable before the equipment is reassigned within a unit. · Outdated or broken computer equipment or other electronic devices will be picked up by emailing supportcentre@ashesi.edu.gh. A contracted disposal vendor will properly erase any information contained within the equipment that cannot be erased in-house.

This policy was developed after reviewing various record retention policies and schedules from leading universities and other authorities. They were then customized to reflect best practices at Ashesi University. While the policy identifies many of the records generated and retained throughout the university, it cannot cover every situation or anticipate future additions and modifications. Therefore, these are to be considered “living documents” that will be revised as needed. All such records are confidential to the University, and such records will be considered privileged and confidential. The stated record retention period of seven (7) years may be increased by government regulation, judicial or administrative consent order, private or governmental contract, pending litigation, or audit requirements. Such modifications supersede the requirements listed in this policy. Suspension of record destruction required for any of these reasons will be accomplished by a notice sent out to affected units. You are encouraged to submit your suggestions for improvements and additions or modifications to the retention schedule to the COO or the Provost.

(Policy adapted from: University of Ghana and American University in Washington D.C.)