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Document Retention Policy

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Document Retention & Destruction Policy

Document

Document Retention & Destruction Policy

Owner

Office of the President

Effective Date

October 18, 2026

Last Reviewed

October 18, 2026

Next Review

October 2027

1. Purpose

This policy provides standards for the retention and destruction of records and electronic information generated and held by Neponset University. The policy is intended to ensure compliance with applicable laws, support institutional operations, and prevent the inadvertent or premature destruction of records.

2. Retention Schedules

Permanent. Articles of organization; bylaws; minutes of trustee meetings; tax-exempt determination letters; major contracts; intellectual property records; academic transcripts; degree/certificate records; audited financial statements.

Seven (7) years. General financial records; payroll records; expense reports; routine contracts after expiration; learner financial records (administrative fees and waivers).

Five (5) years. Personnel records after termination; learner non-academic conduct records (subject to Title IX requirements where applicable); grievance and appeals files.

Three (3) years. Routine correspondence; calendars; voicemail; instant messaging where retained.

Course-specific. Course assessment records and gradebooks: five (5) years. Recordings of synchronous sessions: three (3) years unless used as evidence in a pending matter.

3. Litigation Hold

Upon notice of any actual or threatened litigation, government investigation, or audit, all routine destruction of potentially relevant records is suspended. The Office of the President and Neponset’s counsel coordinate the litigation hold.

4. Electronic Records

Electronic records held in Neponset systems (email, learning management system, cloud document storage) are subject to the same retention schedules as paper records. Backups are retained according to the schedule above.

5. Destruction

Records that have reached the end of their retention period are destroyed in a manner appropriate to their sensitivity — typically secure deletion for electronic records and shredding for paper records containing personal information.