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UMGC Procedures P-X-1.03

Procedures for UMGC Policy on Records & Information Management

Procedures Owner: Sherri Sampson, VP of Legal Affairs and General Counsel
Procedures Administrator: Godfrey Percival, University Records Manager


  1. Applicability

    1. These Procedures are adopted to implement UMGC Policy X-1.03: Records & Information Management

    2. These procedures apply to all employees, including exempt, non-exempt, and overseas staff, 12-month collegiate faculty and collegiate traveling faculty as well as third parties working for and providing services or products to or on behalf of UMGC such as adjunct faculty, contractors, consultants, and temporary employees.

  2. Definitions

    1. All capitalized terms in these Procedures have the meanings provided in the Policy.

    2. All other capitalized terms in these Procedures have the following meanings:

      1. Records Inventory: Records Management Coordinators or appropriate persons should ensure Records created in their business units are identified, classified according to the Records Retention Schedule, and an inventory of those Records should be maintained in the business unit with a copy shared with the University Records Manager.

      2. Records Storage: All UMGC Records must be maintained in appropriate information systems and at appropriate locations. Appropriate locations include those maintained by vendors under service agreements with UMGC addressing Records Management, storage, and destruction requirements. Physical Records placed in offsite storage must follow the record retention process. Information systems that store electronic Records should have retention requirements applied to ensure Records are purged from the systems when they become eligible for purging.

      3. Records Retention: UMGC's Records Retention Schedule provides standards to ensure that Records are kept as long as legally and operationally required based on federal and state legislative requirements and the administrative and operational requirements of UMGC's business units. The content of the Record determines the retention period, not the media or format (formats include paper, electronic, structured, and unstructured). Records must be retained in compliance with the retention periods set forth in the approved Records Retention Schedule and must not be destroyed before the applicable retention period expires. The University Records Manager should be consulted if there are questions about applicable retention requirements.

      4. Records Destruction: Records that have reached the end of their approved retention period, regardless of whether they are housed onsite or offsite, must be destroyed with the exception of Records subject to a Legal Hold Order, or other hold. It is important to emphasize that if the Record is subject to a Legal Hold Order, the Record is NOT to be destroyed until the Order is released. On at least an annual basis, a pre-destruction report with the Records eligible for destruction should be sent to the business units Record coordinators for distribution to the appropriate Record Owners. The Record Owner is responsible for examining the Records eligible for destruction and determining if retention periods have been met according to the Records Retention Schedule.

      5. Records Archiving: Records in any format of permanent or historical value to the university must be sent to the UMGC Archives for permanent retention.

      6. Electronic Records: Appropriate security should be arranged to ensure that Records are accessible only by users with the appropriate permissions. The system that stores electronic Records should be able to produce an audit trail to show when a Record was last accessed and who accessed the Record.