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University Records Center

Implementation of the Records Retention Schedule

Formally Adopted by Office of Audit & Compliance, Office of the General Counsel, and the University Archives and Records Center (Effective January 2, 2001)

Formally Adopted by the President’s Advisory Committee on the University Archives and Records Center (Effective April 11, 2002)

Formally Adopted by Resolution of the Trustees of the University of Pennsylvania (Effective June 17, 2011)

Records Retention Schedule

The Records Retention Schedule is a guideline that sets forth the length of time records are recommended to be retained. This guideline applies to all records listed on the schedule to the extent they are maintained by the University and its Health System, including storage areas. The schedule is intended to cover all University and Health System records for which there is a legal, regulatory or management retention requirement.

The records retention schedule applies to records in the inactive phase of their life cycle. The inactive phase of a record begins at the conclusion of an ongoing matter, such as completion of a contract or clinical research pursuant to a grant. Unless otherwise specified, the retention period set forth in the schedule begins at this point in time.

The records retention schedule identifies some classes of records that have more than one retention period due to the record keeping system in which they are stored. A laboratory record, for example, will have one retention period when it is stored in a laboratory file and a second retention period when it is stored in a patient file. The copy in the patient file should be kept as long as the patient file, which is 21 years from the date of the patient’s last treatment or if the patient is a minor then for 21 years from age 18, and the copy in the laboratory file should be kept as recommended, such as for 4 years. It is not necessary to review the patient file or broad category to remove records that would otherwise be kept for shorter periods in the narrow category.

There are records for which there is no legal, regulatory or management retention requirement and those records should be authorized for destruction by the senior officer of each administrative or academic office of origin. It is recommended that such records be disposed of as early as the end of the active phase of their life cycle. Similarly, records that are duplicates should be disposed of as early as practical, unless the retention schedule requires otherwise.

Storage and Disposition

As discussed in the “Guidelines for the Destruction of Confidential Records,” offices of origin should authorize destruction of confidential records in ways commensurate with their confidentiality. The records retention schedule is the guide for determining how long records should be retained and maintained. It is the option of the office of origin whether to maintain records in that office or in the University Records Center, in paper or alternate format, such as microform or digital formats, so long as the record is authorized for destruction and disposed of in accordance with the records retention schedule. A retention period must be assigned to all records transferred to the University Records Center.

Digital or electronic records. Disposition of records created, retained, or stored in information systems or computers should proceed on the same basis as traditional records. Digital or electronic records for which there is no retention requirement, such as e-mail, should be deleted promptly.

Suspension of Record Disposition Guidelines in the Event of a Claim, Lawsuit, Government Investigation, Subpoena, Summons or Other Ongoing Matters

Upon service of legal process (subpoena, summons or the like), or upon learning of an investigation or audit, or if a claim is made, whether formal or informal, or a dispute arises, the record retention schedule shall be suspended and records related to the legal process, claim, dispute, investigation or audit should not be destroyed.