Records Retention Policy
The Department of Research and Innovation (DRI) occupies a critical role within the University in terms of central support for institutional business with respect to research, consultancy and commercialisation activity. Through the provision of support, co-ordination and growth of external funding, DRI is the custodian of a significant amount of official and contractual documentation. A considerable amount of this documentation commits the University to legal obligations; and as such there are statutory and audit requirements that must be satisfied when considering the archiving of historical documents. This policy statement will, therefore, establish a framework for the retention of official documents within DRI – the policy is designed to conform to the institutional policy with regards to records retention policy that is managed by the Records Management section.
2. RETENTION CRITERIA
The period of retention for a record series will be determined by the retention criteria which are:
Administrative records, for example subject files and correspondence files, have a clear lifecycle beginning with their creation, current use, semi-currency when they are referred to less and finally to non currency when they have been superseded by new information and can be confidentially destroyed.
Many record series exist within a statutory framework where specific legislation determines a minimum period in which the information must be kept, for example the Companies Act 1985, the Finance Act 1985 and the Taxes Management Act 1970 set minimum retention periods for a range of financial records. There will also be instances where the University will retain records to defend itself against potential civil actions and certain retention periods will then be determined by reference to the Limitation Act 1980, the Latent Damage Act 1986 and other relevant legislation.
Documentation within DRI that will require effective retention include:
- Contractual documentation related to R, V, C and G coded projects. This is restricted only to the official documentation held at DRI level; there will be additional requirements for projects
- EU Structural Fund projects must adhere to the EU Structural Funds Handbook section 2.10,Document Security and Retention
- Projects must adhere to the Swansea University Financial Policies and Procedures section E.12.21 Document security and retention for EU Structural Fund supported projects and the WEFO Guidance on Management and Retention of Records
- EU Framework projects are required to keep all authentic copies of FP7 documents (reports, timesheets, receipts, etc.) for at least 5 years after the end date (i.e. the date on which you receive your final payment) of the project.
- MOUs, NDAs and other confidentiality agreements
- Documentation related to patents and wider forms of IP protection (e.g. trademarks etc) and disclosures
- Formation of spin-out and hosting of spin-in companies
- IP income
- Consultancy income (invoices and proposal documentation)
The University’s records manager will agree the retention criteria and the period of retention with the Head of DRI and where required provide advice and guidance.
3 RETENTION SCHEDULES
The period of retention will be set-out in DRI retention schedule. A standard retention schedule form is appended. The schedule sets-out provenance, records series, the agreed retention period and the criteria on which the retention period is based. The retention period starts from the last entry in the record, for example from file closure; however retention periods will vary depending on sponsor requirements.
At the end of the retention period the records will be assessed to ensure whether changes in legislation, particular disputes, claims and enquiries require extended retention. If the retention period remains valid the records will be appraised for their historic value in accordance with the University’s archive collection policy (where appropriate, some records will be transferred to the University Records Management Service for longer term archiving). All records not retained as archives will then be confidentially destroyed.
The maintenance and development of the records retention policy and the retention schedules is the responsibility of the records management service of Swansea University (‘contact details’).