Data Retention Administrative Policy

University Data & Records Management Administrative Policy


Eastern Michigan University has a responsibility to manage its records such that it preserves University history, meets regulatory and legal requirements, minimizes risk, optimizes the use of University space, and minimizes costs to the University.


This Policy applies to all Records regardless of their form and applies to all faculty, staff, and students, as well as any University affiliate who creates and/or manages Records. This Policy, and its accompanying University Data and Record Retention Schedule (“Retention Schedule”) replace and supersede any existing retention policies or guidance that University officials may have adopted for Records.



A record is defined as any information, regardless of physical format, which has legal, fiscal, administrative or enduring value, including but not limited to paper, microforms, photographs, drawings, maps, motion picture film, and electronic records maintained in magnetic or optical format such as databases, e-mail, voicemail, CDs and DVDs, videotapes and audiotapes, computer tapes and discs, and word processing documents.

Inactive Records

Inactive records are those no longer required to carry out the administrative or operational functions for which they were created, but must be kept for administrative, fiscal, legal, or historical purposes in accordance with approved records retention schedules.

Confidential Records

Records containing sensitive personal (or personally identifiable) information.

Vital Records

Vital records are those necessary to re-establish or continue the University in the event of a disaster; to recreate the University's legal and financial position; or to preserve the rights of the University, its trustees, faculty, staff, and students.

Archival Records

Archival records are those determined to be of enduring value and therefore preserved and made available for historical research in the University Archives.


Records created or received during the normal course of University business are the property and/or responsibility of EMU, and all employees are responsible for ensuring that all Records are managed in accordance with University policies and in compliance with applicable federal and state laws. For Records specifically described in the accompanying Retention Schedule, the department or office identified in the Retention Schedule as the Responsible Unit shall be responsible for that Record’s retention and disposal.

University Records are the responsibility of departments until the applicable retention period has passed. Appropriate secure physical or digital storage must be maintained. If paper Records whose retention times are not permanent are digitized, the original paper copy should be destroyed. If paper Records whose retention times are permanent are digitized, the paper copies should be transferred to University Archives. Where records are digitized, the electronic record becomes the official Record and should be managed following the Retention Schedule.

Departments should not retain Records longer than the Retention Schedule authorizes, or dispose of Records prematurely. Compliance with this Policy and the Retention Schedule may be subject to internal audit.

Department, college, school or academic unit requirements:

  1. Manage Records in accordance with University Policy and the Retention Schedule.
  2. Ensure that information of a sensitive or confidential nature is protected from unauthorized disclosure until final disposition and that such records are destroyed by a means that prohibits reconstruction of the information or, in the case of electronic records, properly deleted or purged.
  3. Establish a regular record destruction process.
  4. Audit files regularly to ensure compliance with the Retention Schedules.
  5. If you have been notified by Legal Affairs of a “preservation notice” for any Records for purposes of a legal dispute, do not destroy the Records even if their scheduled retention period has expired.
  6. Assist in identifying and preserving Records of vital or enduring/archival value to the University.
  7. Provide suggestions for additions/changes to this Policy or the Retention Schedule as needed.  

Destruction of University Records

For Records that are not Archival Records or Inactive Records, disposal is the final phase of a Record’s life cycle. The following are considered appropriate methods for disposing of Records slated for destruction.

  1. General recycling/shredding (for paper Records that are not Confidential Records).
  2. Confidential recycling/shredding, which may require departmental supervision and/or vendor certification (for paper Confidential Records).
  3. The destruction of electronic Records must be performed according to the Division of Information Technology security standard for data deletion. 

Source(s) of Authority and Other References:

  • Board Policy 2.06 Policy on Policies
  • DoIT Policy 8.09 Electronic Media Sanitation and Disposal
  • MCL 399.809-.812 Michigan History Center Act

Effective: May 19, 2023

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