Records Management Program FAQ

CUNY Records Management Program

• What is a Departmental Schedule?
  Your Departmental Schedule acts as an “at a glance” companion to the complete CUNY Records Retention and Disposition Schedule (CUNY Schedule).  Used in conjunction with the Administrative Schedule, it will enable you to quickly locate the retention periods for the records that are kept in your department.  You should always consult with the CUNY Schedule or your department’s Records Coordinator if you have additional questions about a record’s retention period.
   
• What is the Administrative Schedule?
  The Administrative Schedule covers the administrative records that are most commonly found across all departments at your College.  You may not have every item listed on the Administrative Schedule and do not have to create records where no records currently exist.

• How do I read my Departmental Schedule?
  Your Departmental Schedule includes for each item an Item Number, followed by the Record Series Title, a brief Description/Example of the item, the item’s required Retention Period, and lastly, under CUNY Schedule Reference, where this item can be located in the CUNY Schedule.  For ease of reference, the items in your Departmental Schedule are generally listed in the order in which they appear in the CUNY Schedule.  In addition, duplicate copies of records, except where necessary for clarification, are not listed.  For the most part, your Departmental Schedule lists only those items where your department is responsible for the official copy.

• Where do the retention periods come from?
  The CUNY Schedule has been adapted from the Records Retention and Disposition Schedule MI-1 issued by the State Archives program of the New York State Education Department.  In the adaptation process, a great many items in Schedule MI-1 were deleted because of their inapplicability to CUNY, and most of the remaining items have been edited so that they are more accessible to the CUNY community. The State Archives requires that the retention periods for items prescribed in Schedule MI-1 may not be shortened. For a number of items, however, CUNY has decided that it is appropriate to lengthen the retention periods prescribed in Schedule MI-1 in the CUNY Schedule or the Departmental Schedules. 

• What if a record I have is not in my Departmental Schedule?
  You should consult either the CUNY Schedule for the record’s retention period, or your department’s Records Coordinator for clarification.  Make sure to notify your department’s Records Coordinator for the possible addition of this item to your Departmental Schedule.

• What should I do if I do not have records listed in my Departmental Schedule?
  You are not required to create a record where none currently exists.  Your Departmental Schedule contains only records existing in the department at the time the Departmental Schedule was created.  If an item is in your Departmental Schedule and you no longer maintain those records, please contact your department’s Records Coordinator about a possible update to your Departmental Schedule.

• What do I do with duplicate records?
  The items listed in the CUNY Schedule refer only to the official copy of a record, regardless of its form (paper or electronic).  Once you have determined that your record is truly a duplicate, you should retain the record only while it is needed and then dispose of it at the earliest administrative opportunity.  In no case should duplicate records be retained longer than official copies that contain the same information.  To confirm the retention period of official copies, please consult the CUNY Schedule.

• What do I do with files that have records in them with different retention periods?
  Often you will have files containing records where individual items have different retention periods.  It is recommended that you do not spend time weeding through the file removing items as they become eligible for destruction, but rather retain the entire file for a single retention period.  That retention period should be based on whichever item in the file has the longest retention requirement.  An exception to this recommendation is if any of the items requires Permanent retention.  In this case, you must identify and save the items with a Permanent retention requirement and dispose of the remaining items in the file either at the end of their applicable retention period or the longest retention period of all the items in the file that need not be held permanently.

• What do I do with records that are past their retention period?
  Once you have identified that a record’s retention period has expired, you should do the following:
  
  (a)    Determine that the record does not need to be retained in connection with any threatened or ongoing legal actions.  If legal action is either threatened or ongoing, all records retention guidelines are suspended, even if the retention period has expired.  If the retention period has expired by the time the legal action ends, the records must be retained for at least one additional year. If the retention period has not expired, the records must be retained for the remainder of the retention period, but not less than one year after the legal action ends.   To verify that no legal actions have been threatened or initiated, your department’s Records Coordinator must consult with your College’s Records Management Coordinator, who will then consult with CUNY’s Office of the General Counsel.
  
  (b)    Determine that the records do not need to be retained because they have been requested in connection with a program or fiscal audit or other needs of state and federal agencies.  If such a request has been made, the records must be retained beyond their retention periods until the College or the University receives the audit report or until the need has been satisfied.  Please consult with your department’s Records Coordinator if you identify any such items.
  
  (c)    Determine that the records do not need to be retained in connection with any request made under the New York State Freedom of Information Law (FOIL).  If such a request has been made, the records must be retained beyond their retention periods until the request has been answered and any potential appeal has been made and resolved.  Please consult with your department’s Records Coordinator if you identify any such items.
  
  (d)    Determine if the records should be saved for archival purposes.  Please consult with your department’s Records Coordinator if you identify any such items.
  
  (e)    If it has been determined that the records are not needed in connection with a legal action, are not subject to an audit or FOIL request, and are not appropriate for transfer to your College’s archives, you should contact your department’s Records Coordinator for a Records Disposition form.  You must complete this form before destroying any official copies of records.  This form will ask you to do an inventory of the items, as well as note the quantity of records eligible for disposition.  Your College’s Records Management Coordinator will determine if the records will be either shredded or transferred for recycling.
   
• Can I keep records a different amount of time than listed in the Departmental, Administrative, or CUNY Schedules?
  You can never keep records for a shorter retention period than is listed in the Departmental, Administrative, or CUNY Schedules.  If you have records that you feel should be kept longer than the listed retention period, please contact your department’s Records Coordinator.  The two of you will be able to determine if there is a need to keep the records longer than is currently specified.  Your department’s Records Coordinator will then consult with your College’s Records Management Coordinator, who will consult with the University Records Management Coordinator and CUNY’s Office of the General Counsel for a final determination of whether a longer retention period is appropriate.  In some cases, your concerns will lead to changes in the Departmental, Administrative, and CUNY Schedules.
• When does my “year” start?
  Although there is no set date to start the year, most departments find it easier to follow either a fiscal or academic year.  Remember that the retention period is the designated number of years plus the current year.

• What if my department is involved in a lawsuit?
  If legal action is either threatened or ongoing, all records retention guidelines are suspended, even if the retention period has expired.  If the retention period has expired by the time the legal action ends, the records must be retained for at least one additional year. If the retention period has not expired, the records must be retained for the remainder of the retention period, but not less than one year after the legal action ends.  To verify that no legal actions have been threatened or initiated, your department’s Records Coordinator must consult with your College’s Records Management Coordinator, who will then consult with CUNY’s Office of the General Counsel.

• What do I do with electronic records?
  While items in the Departmental, Administrative, and CUNY Schedules for the most part cover records regardless of the physical form in which they are maintained, electronic records in some subject areas are treated differently.  If so, these different requirements are specifically listed in the Schedules. Your department’s Records Coordinator will contact your College’s Records Management Coordinator if you have any additional questions or concerns about the retention and disposition of electronic records.

• Where can I get more details about the CUNY Records Retention and Disposition Schedule?
  The CUNY Schedule, which includes an introduction that may be helpful in your use of the Schedule, as well as an index, is available online at http://policy.cuny.edu/pdf_source/rrs.pdf or http://policy.cuny.edu/toc/rrs/.

^{Last Revised: 6/19/2013}