Control reminder: Responsibilities for proper records retention and disposal

Per RCW 40.14, departments are responsible for retaining and disposing of University records in accordance with retention periods approved by the Washington State Records Committee. If University records are not properly safeguarded during use and disposition, intentional or unintentional release of University data could occur, resulting in a data breach. A data breach may cause significant financial, legal, operational and reputational damage to the University.

The Office of Procedures, Records, and Forms coordinates the records management program and assists departments with records retention and disposition. The Director of Procedures, Records, and Forms is the WSU Records Officer.

Departments review records annually, both paper and electronic, to determine which are ready for disposal. Units should take care to observe all records retention policies per BPPM 90.01 and departmental schedules. The department’s responsibility includes ensuring the physical safety of records, as well as ensuring that confidential records are protected from inappropriate or illegal release.

Records Disposal

After records have been stored for the complete retention period, the records coordinator either sends the records to University Archives or disposes of the records. If the records are to be disposed of, the records coordinator either destroys or recycles the records.

Many records may be recycled in accordance with University recycling procedures (see BPPM 80.80). According to WAC 434-640-020, if records are confidential, departments are responsible for ensuring that the records are protected from unauthorized or illegal disclosure by reducing them to an illegible condition.

Generally, paper records are destroyed by shredding. Departments may shred records with a department-owned shredder, hire a private shredding company, or have the records shredded by WSU Waste Management. If you are working from home during the global pandemic, this may become more challenging.

  • If possible, do not print records while working from home; then follow directions below in deleting electronic records when appropriate.
  • If paper records are required, ensure they are safeguarded and disposed of accordingly. If access to a shredder or shredding services is limited, work directly with your supervisor to plan how records will be disposed of, including scheduling visits to the office periodically to allow for proper shredding.

To completely delete any type of electronic file, the record holder must:

  • Move the file to a trash folder or electronic recycle bin, and
  • Empty the trash folder/recycle bin.

For questions or additional information, you may contact the Office of Internal Audit at ia.central@wsu.edu or the Office of Procedures, Records, and Forms at prf.forms@wsu.edu.

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