University Policy Number 1102
Categorized: General Policies
Responsible Office: University Records Management
- Detailed procedures on records management, retention, and disposal are available from George Mason University’s Agency Records Manager, Special Collections Research Center, University Libraries. Additional information can be found at the Records Management website, as follows: http://recordsmanagement.gmu.edu/.
Related Law & Policy:
- Code of Virginia, Title 42.1, Chapter 7: Virginia Public Records Act
- Virginia Records Retention and Disposition Schedule, General Schedule No. 111: College and University Records
- The Library of Virginia’s Virginia Public Records Management Manual
- University Policy 1114: Data Stewardship
- University Policy 1114A: Removal of University Data from Electronic Media
- University Policy 1117: Responding to Virginia Freedom of Information Act (FOIA) Requests for Records
- University Policy 1122: FERPA Compliance
- University Policy 1118: Compliance with the Health Insurance Portability and Accountability Act (HIPAA)
- University Policy 4011: Ownership and Maintenance of Research Records
- University Policy 1301: Responsible Use of Computing
This policy applies to all employees and authorized agents of George Mason University and to all University Records generated and managed by George Mason University.
II. Policy Statement
The Code of Virginia, §42.1-85, requires that Mason establish and maintain an active, continuing program for the economical and efficient management of records. George Mason University is required to adhere to all schedules published by the Library of Virginia. Employees of Mason are responsible for ensuring that University Records are preserved, maintained, and accessible throughout their lifecycle.
A. The Office of University Records Management is authorized to:
- Implement a University Records Management Program in keeping with the policies and procedures published by the Library of Virginia.
- Determine the classification of University Records and identify vital, inactive, and permanent records.
- Conduct operational reviews as needed of the implementation of the records management policies and practices within the University to discover where policies and standards are met.
B. University Employees and Authorized Agents must:
- Comply with the retention and disposition schedules published by the Library of Virginia and adhere to the University Records processes and practices of their respective university departments.
- Ensure against premature disposal of University Records in violation of the Virginia Public Records Act.
- Not retain University Records longer than the retention schedule authorizes.
- Adhere to the retention and disposition schedules dictated by federal regulations and accreditation requirements.
- Ensure that information in confidential or privacy-protected records is protected from unauthorized disclosure.
C. University Department, Local Academic Unit, School and/or College, or Office (to be referred to as “Department”) must:
- Appoint one or more departmental Records Coordinators to liaison with the University Records Manager regarding departmental records. Coordinators serve as a records information resource for their department and are responsible for supporting University Records Management in the development and implementation of the records management program within their department. Records Coordinators must attend training as required by University Records Management.
- Ensure that employees understand their responsibilities and comply with the appropriate management of the department’s University Records.
- Consult University Records Management about maintenance, retention, and proper disposal of University Records in their possession and be responsible for the maintenance and retention of the department’s University Records while in their possession.
- Determine whether to transfer Inactive paper and electronic records to University Records Management or to retain inactive University Records internally.
- Ensure University Records created in digital format are maintained in digital format. Digital storage options must be approved by Information Technology services and University Records Management, especially in cases of information containing identifiable information.
- Verify that there is no audit, investigation, or legal action pending or anticipated on the department’s University Records that are eligible for disposal, and confirm that the records have not otherwise been reactivated. If there is no action that would prohibit records disposal, the appropriate records coordinator must sign the Certificate of Records Destruction (RM-3) form in a timely fashion and return to the form to University Records Management for their final approval.
- Be aware of any records retention requirements agreed to outside of the requirements set forth by the Virginia Public Records Act and report those requirements to University Records Management. These agreements include but are not limited to retention periods, policies, or procedures outlined in agreements with accreditation institutions, athletic agencies, grant and research organizations, etc.
D. University Records Destruction
- University Records cannot be destroyed without the authorization of the University Records Manager and a completed and signed Certificate of Records Destruction (RM-3) form.
- University Records with “identifying information” must be disposed of within six months of the expiration of the records period, unless under audit, investigation, or litigation.
- Paper records containing confidential or identifying information must be destroyed using a confidential method such as pulping, confidential shredding, or burning.
- Electronic University Records must be “scrubbed” clean or the storage media physically destroyed. “Deletion” of electronic records in computer files or other electronic storage media is not acceptable nor effective.
E. Permanent and Vital Records
- Permanent Records must be maintained indefinitely. Certain Permanent Records may be transferred to the George Mason University Archives in the Special Collections Research Center, University Libraries.
- Although Vital Records are subject to records management regulations, Vital Records are not eligible for transfer to the George Mason University Records Center until they have become inactive.
Records Management means the systematic control of records throughout their life cycle to ensure efficiency, economy and security in their creation, use, handling, control, maintenance, and disposition. It also is a process of managing data and other information in a secure format that allows for its timely access.
Public Record has the same meaning as defined in the Virginia Freedom of Information Act, Virginia Code §2.2-3701, as amended: “all writings and recordings that consist of letters, words or numbers, or their equivalent, set down by handwriting, typewriting, printing, photostatting, photography, magnetic impulse, optical or magneto-optical form, mechanical or electronic recording or other form of data compilation, however stored, and regardless of physical form or characteristics, prepared or owned by, or in the possession of a public body or its officers, employees or agents in the transaction of public business.”
University Record means those Public Records the University has the responsibility to maintain under the Virginia Records Act, §42.1-76 et seq.
Active Records means University Records that are undergoing processing and are needed, and referred to frequently, in the daily operations of the University.
Inactive Records means University Records that are not used with sufficient frequency to justify keeping them in the office of creation.
Vital Records means records absolutely needed to conduct business or to reconstitute an agency, organization, office, or unit (during or after an emergency), or to preserve the rights of the state or its citizens. Vital Records are part of an agency’s records disaster prevention and recovery program.
Records Schedule means a listing of records series, approved by the Library of Virginia, that provides management instructions throughout the information lifecycle for University records.
Retention means the length of time records should be kept in a certain location for administrative, legal, fiscal, historical or other purposes.
Temporary Records means University Records that have a limited administrative, fiscal, or legal value over time.
Permanent Records means University Records of enduring historical or vital value or as evidence of the roles and responsibilities of the creator, not to be sent to temporary storage.
Records Disposition means final destruction or transfer of records to the proper archival repository.
Certificate of Records Destruction (also known as an RM-3) means the document approving the destruction of records in accordance with Library of Virginia (LVA) Records Retention and Disposition Schedules and requires the signature of the University Records Manager prior to destruction of the records. A completed RM-3 Form serves as evidence of proper disposal when records are subpoenaed as evidence, audited, or investigated.
Identifying Information means:
- Social security numbers;
- Driver’s license numbers;
- Bank account numbers;
- Credit or debit card numbers;
- Personal identification numbers (PIN);
- Electronic identification codes
- Automated or electronic signatures or passwords;
- Any other numbers or information that can be used to access a person’s financial resources, obtain identification, act as identification, or obtain goods or services.
Records Coordinators – Individuals who serve as a liaison between University Records Management and their respective department.
Additional definitions are available at the GMU Records Management website.
A. Effective Date:
This policy will become effective upon the date of approval by the Senior Vice President for Administration and Finance and the Provost and Executive Vice President.
B. Date of Most Recent Review:
V. Timetable for Review
This policy, and any related procedures, shall be reviewed every three years or more frequently as needed.
Senior Vice President for Administration and Finance
Date approved: September 20, 2002
Revision Approved: April 12, 2011
Revision Approved: February 5, 2019