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Records Retention

RECORDS MANAGEMENT IS CRITICAL TO COMPLIANCE

SUNY maintains a comprehensive Records Retention Policy that codifies the retention periods for the various records housed by SUNY campuses. SUNY Policy 6609 has a series of appendices (available through the policy and also on the Records Retention compliance webpage) that lists all the various records, and the specific period that a campus must retain them, and what records must be kept permanently. This SUNY policy and appendices has been pre-approved by State Archives and the Office of the State Comptroller. When the SUNY Schedule does not cover a particular record, SUNY campuses are to defer to the New York State schedule (available on the State Archives website) for the proper retention period.

WHY Follow the Records Retention Schedule: When they are followed proactively, they help SUNY to avoid risks on the back end, including data breaches and audit requests that span back farther than the SUNY schedule requires us to keep them for, and also helps to save on storage costs and IT costs. Non-Compliance with records retention schedules causes an undue burden on the University to maintain electronic servers and physical storage space in order to house all of the information that the institution is obligated to keep. Also, information that no longer serves a legal, operational, or historic value to the institution, but that contains private data raises the possibility for a potential privacy breach.

If you have specific questions about what can, and cannot be disposed of, please contact the Records Management Officer at SUNY System Administration.

What is a Record:

Any information kept, held, filed, produced or reproduced by, with or for an agency or the state legislature, in any physical form whatsoever including, but not limited to, reports, statements, examinations, memoranda, opinions, folders, files, books, manuals, pamphlets, forms, papers, designs, drawings, maps, photos, letters, microfilms, computer tapes or discs, rules, regulations or codes. (According to SUNY's FOIL (Compliance with Freedom of Information Law) policy, Document Number 6601).

Background on SUNY Records Retention Generally & the SUNY Records Schedule

SUNY has a Records Retention Policy that codifies the retention periods for the various records housed by SUNY campuses. The policy has a series of appendices (available through the policy and also on the Records Retention compliance webpage) that list all the various records, and the specific period that a campus must retain them.

This SUNY policy and appendices has been pre-approved by State Archives and OSC, and when they are followed proactively, they help SUNY to avoid risks on the back end, including data breaches and audit requests that span back farther than the SUNY schedule requires us to keep them for, and also helps to save on storage costs and IT costs.

When the SUNY Schedule does not cover a particular record, SUNY campuses are to defer to the New York State schedule (available on the State Archives website) for the proper retention period.

SUNY Records Retention Schedules
Click here, or on the graphic at right, for access to a listing of the SUNY Records Retention schedules. The schedules are part of the appendices of SUNY Policy 6609: Records Retention and Disposition.

Records Management Officers
Each campus has designated a Record Management Officer to ensure compliance with the SUNY records retention schedule at their campuses. Click here, or on the graphic at right, for tools and guidance for Records Management Officers across the SUNY System. The webpage details the duties of the Records Management Office, and also offers tools and advice for campus RMO's.

SUNY Policies & Procedures on Records Retention

SUNY Policy 6609: Records Retention and Disposition

SUMMARY OF POLICY: Retention and disposition of official records of the campuses of the State University of New York are governed by the NYS Arts and Cultural Affairs Law. Such records may not be destroyed unless in conformity with the General Retention and Disposition Schedule for New York State Government Records with respect to categories of state government records included therein or with the State University of New York Records Retention and Disposition Schedule with respect to education and other SUNY-specific records. Requests to destroy paper records after transfer from paper to digital form must be approved by the State Archives unless such dispositions are pre-approved under the SUNY Records Retention Schedule for that category.

SUNY Procedure 6603: Compliance with the Personal Privacy Protection Law

SUMMARY OF PROCEDURE: The State University of New York (University) is subject to the provisions of the “Personal Privacy Protection Law” (Pu blic Officers Law §§91-99) and the University’s implementing regulations under 8 NYCRR § 315
(Access to Personal Information Maintained by State University of New York). The Personal Privacy Protection Law and regulations (PPPL) require the University to take certain steps to protect the privacy rights of individuals to whom state agency records pertain and to provide individuals with an opportunity to review and correct such records. Under the PPPL: a) the University shall maintain in its records only such personal information that is relevant and necessary to accomplish a purpose of the University that is required to be accomplished by statute or executive order, or to implement a program specifically authorized by law; b) personal information will be collected, whenever practicable, directly from the person to whom the information pertains; and c) the University will seek to ensure that all records pertaining to or used with respect to individuals are accurate, relevant, timely and complete. Furthermore, under the PPPL: a) subject to certain exceptions, the University shall, within five business days of a written request from an individual for a reasonably described record pertaining to that individual, provide access to the record, deny access in writing, stating the reasons for denial, or acknowledge receipt of the request in writing, stating the approximate date when the request will be granted or denied; b) within 30 business days of a request from an individual for correction or amendment of a record or personal information that is reasonably described and that pertains to the data subject, the University shall either make the amendment or correction in whole or in part or inform the data subject in writing of the refusal to amend or correct the information, including the reason for refusing to make the amendment or correction; and c) no record containing personal information will be disclosed to third parties without the consent of the data subject unless the disclosure is made to individuals or entities as specified in the “Disclosure of Records” in the Procedures section below or pursuant to a subpoena or other compulsory legal process.

Other Records Retention Resources

SUNY Plattsburgh Records Retention Webpage

SUNY College at Brockport Records Retention Awareness Installment 1 Video Series
Brockport created a Records Management Awareness Video

NYALGO, New York Association of Local Government Records Officers
NYALGRO is a non-profit organization formed to provide a network to all who are responsible for records upkeep and information for local governments.

For questions related to Records Retention and Disposition, please contact Nedra Abbruzzese-Werling, Records Management Officer of SUNY.

The information contained on the SUNY Compliance website is for general campus guidance only and is not intended, nor can be relied upon, as legal advice or the imposition on SUNY campuses of specific policies or requirements. The site is intended to be an informational-only clearinghouse for some of the laws, rules, and regulations that may impact the State University of New York’s campuses. Additionally, given the rapid, changing nature of laws, rules and regulations, there may be delays or omissions contained on this site which therefore cannot be relied upon as complete. For complete compliance information, consult your campus compliance officials or the SUNY Compliance Administrator. For legal advice, consult your lawyer.

SUNY is not responsible for the content of external Internet sites. SUNY External Site Disclaimer.


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