Data and Record Retention Policy

Approved by: The Data and Record Retention Group
Responsible Department: Office of the General Counsel
Responsible Admin: Vice President, General Counsel, and Secretary of the College
Effective Date: July 1, 2008
Last Updated: March 31, 2026
References: Data Cookbook, Data Governance Committee, Colby Data Classification Policy, Data Stewards Listing, System of Record, Records Retention Schedule (Schedule A)

Proper retention of records is essential to conduct the business of the College; to protect the legal interests of the College, students, and employees; to preserve the College’s history; and to comply with applicable state and federal laws and regulations.

Definitions within this policy align with the Data Cookbook, which is managed by the Data Governance Committee.

1. Data Archive: A repository of data from one or multiple systems to extract and preserve data no longer accessible in its originating System of Record (SoR).
2. Data Classification: Data classification levels (e.g., Public, Restricted, Confidential) are defined as set forth in the Colby Data Classification Policy.
3. Data Manager: Data Managers operate with authority delegated by Data Stewards to manage data operations within a defined scope of responsibility appropriate to the tasks, settings, and types of data within a functional area.
4. Data Steward: Data Stewards are accountable for the management and oversight of institutional data in a particular functional area.
5. Data Trustee: Data Trustees are senior college officials who are ultimately accountable for all aspects of Colby data.
6. Functional Area: Refers to discrete administrative operations within the College, for example Admissions or Student Records. Functional areas have designated data System(s) of Record, data stewards, and data managers, who oversee the data in their functional area.
7. Records: Any documentary material, regardless of format or media, created or received in the course of College business that provides evidence of its operations, policies, or decisions.  
8. System of Record: The data system that is considered to be the authoritative source for any given data element, and therefore the source of choice when needing to report on a data element or extract a data element for broader access and usage.
9. Transitory Documents (Non-Records): Items with temporary usefulness (e.g., routine acknowledgments, meeting logistics, personal notes). These may be destroyed once their administrative purpose is served.

The Data and Record Retention Group oversees the College’s Records Retention Policy and procedures. However, primary accountability for the oversight of data rests with the Data Trustees. Information regarding specific Data Trustees, Data Stewards, and designated Systems of Record can be found at the Colby Data Governance Website: https://sites.google.com/colby.edu/data-governance/resources.

Data Stewards are responsible for:

1. Ensuring specific departments and all personnel within their designated functional area adhere to retention and destruction protocols.
2. Primary accountability for the lifecycle of their specific datasets.
3. Adhering to retention and destruction protocols for any System of Records, as well as existing copies, derived from their functional area.
4. Management and oversight of any Data Archives derived from their functional area to ensure they are maintained and purged in accordance with this policy.
5. Overseeing the classification of data and authorization of access within their functional areas, with input from Data Trustees as needed.

Based on their specific functional areas, Data Stewards, in coordination with Data Trustees, must proactively determine how to retain and when appropriate, delete records once they reach the end of their applicable retention period, as defined in the Records Retention Schedule (Schedule A).  

1. Selection of Deletion Methods: Data Stewards must ensure their Functional Areas determine the most effective methods for record deletion. This determination may include the use of manual purge procedures, the implementation of automated deletion protocols, or the engagement of secure external disposal services, such as professional document destruction companies for physical records. Furthermore, Data Stewards should consult with ITS whenever technology providers and software solutions are evaluated, including specialized tools that integrate directly with a System of Record, to manage retention lifecycles and facilitate the removal of records. The decision to utilize specific automated tools or manual processes rests with the Data Steward, provided the chosen approach ensures records are reliably deleted upon reaching the end of their applicable retention period as defined in Schedule A.
2. Litigation Holds: In the event of pending or anticipated litigation, the College will issue a “Litigation Hold.” This overrides all automated and manual deletion protocols for the affected data, as well as any customary deadlines for deletion of such data that otherwise apply if it was not the subject of a hold. The hold on data deletion remains in place until it is lifted.
3. Conflict of Retention Periods: In instances where a record is governed by multiple retention requirements (e.g., federal grant requirements vs. institutional policy), the longest retention period shall apply.
4. Destruction of “Shadow Data”: Data Stewards should take reasonable steps to ensure that the destruction process includes the removal of local copies, extracts, and “shadow” versions of records residing on individual workstations, removable media, or cloud storage platforms within their functional area.
5. Destruction Standards for Data Classification: Except as otherwise provided in this policy or in Schedule A, following the completion of the applicable retention period stated in Schedule A, records are to be destroyed with methods that do not permit recovery, reconstruction, or future use of information based on its classification:
   1. High Risk (Confidential) and Medium Risk (Restricted) Data:
      1. Paper records must be shredded using a secure and verifiable destruction process, such as cross-cut shredding or a professional disposal service utilizing locked collection bins. Verification is confirmed by obtaining a certificate of destruction or by recording the date, method, and record category in a disposal log.
      2. Electronic records must be securely destroyed via proven deletion methods, such as cryptographic erasure, so that data cannot practicably be reconstructed.
      3. Physical media (hard drives, tapes, etc.) must be physically destroyed or degaussed or securely overwritten such that the original data is irrecoverable.
   2. Low Risk (Public) Data:
      1. May be disposed of through standard recycling or simple electronic deletion.

It is the responsibility of every individual who manages or directs a department or division to ensure those in their department/division are aware of and adhere to this policy. To facilitate this, the following oversight and reporting requirements are in place:

1. Audit Process and Disposal Logs: Data Stewards must determine and maintain an appropriate audit process for both the preservation of records that need to be retained and the deletion of records that must be deleted/destroyed within their functional areas. This process must include the maintenance of a disposal log that records the category of records destroyed, the date of destruction, the method used, and the volume or date range of records. Disposal logs must not contain actual sensitive data. Likewise, the audit process must account for record preservation, particularly during a Litigation Hold. When such a hold is issued, it overrides all manual and automated deletion protocols to ensure that relevant data is protected from alteration or destruction until the hold is lifted.
2. Collaborative Recommendations: To support high-quality data stewardship, the Data Steward should:
   1. Meet with peer Data Stewards to share best practices and ensure institutional consistency.
   2. Consult with the Data Governance Committee regarding complex retention requirements or policy interpretations.
3. Annual Compliance Checklist: Data Stewards must ensure the completion of an Annual Record Retention Compliance Checklist. This checklist serves as a formal verification of the department’s good faith efforts to maintain record integrity and lifecycle management.
4. Managerial Oversight: Data Trustees provide oversight by reviewing and approving the completed checklists for their respective divisions. They are ultimately responsible for ensuring their functional areas remain in compliance with institutional and legal standards.