Records Management Policy

Effective Date:

December 26, 2014

Supersedes:

Record Retention Policy for Paper and Data Records

Policy Review Date:

March 2015

Issuing Authority:

Research Foundation President

Responsible Party:

Chief Compliance Officer

Contact Information:

518-434-7145

rfcompliance@rfsuny.org

Reason for Policy

All organizations need efficient and cost-effective methods to organize and maintain their records and information, and efficient record management is a key activity necessary to achieve the Research Foundation for The State University of New York ("Research Foundation" or "RF") strategic goal of providing outstanding sponsored program administration services and stewardship to the SUNY community and sponsors. The RF Record Management Policy is based upon standards rooted in federal and state laws and regulations, and an acknowledgment that contracts may obligate the RF to unique record management responsibilities.

Legal and regulatory sources were used to identify the minimum requirements for specific types of RF Records. The requirements of the RF Record Management Schedule are based substantially on the following:

Statement of Policy

RF Records must be managed in accordance with the requirements identified in the RF Record Management Schedule. RF Records should be destroyed when the retention requirement of the RF Record Management Schedule has been met, so long as no relevant audit, claim, or litigation is pending or anticipated.

Residual Oracle data may remain in the system beyond the retention requirement of the RF Record Management Schedule.

Research-Related Records that are not RF Records

Research-related Records in the custody, possession, or control of a SUNY campus are subject to SUNY policy and procedure, including but not limited to the State University of New York Records Retention Policy and Schedule. RF operations managers may elect to adopt this Record Management Policy to govern the management of research-related Records at their location, in conformance with local rulemaking procedures.

Exceptions

RF must comply with any sponsor-specific record retention requirements. If a sponsor requires records be retained for a longer period than required by the RF policy, the sponsor's requirements take precedence and must be followed.

Responsibilities

The following table outlines the responsibilities for compliance with this policy:

Responsible Party

Responsibility

RF chief compliance officer

Monitoring compliance across the enterprise under the purview of the owners identified below.

RF vice president of operations

  • Maintain RF Record Management Schedule where the Office of Record is Sponsored Programs or Human Resources.
  • Manage records in accordance with the RF Record Management Schedule.

RF vice president for finance and administration

  • Maintain RF Record Management Schedule where the Office of Record is Finance.
  • Manage records in accordance with the RF Record Management Schedule.

RF vice president for Internal Audit

  • Maintain RF Record Management Schedule where the Office of Record is Internal Audit.
  • Manage records in accordance with the RF Record Management Schedule.

RF vice president of Innovation and Partnerships

  • Maintain RF Record Management Schedule where the Office of Record is Innovation and Partnerships
  • Manage records in accordance with the RF Record Management Schedule.

RF general counsel

  • Maintain RF Record Management Schedule where the Office of Record is the Office of General Counsel.
  • Manage records in accordance with the RF Record Management Schedule.

RF operations managers or designee

Ensure compliance with this policy or the local policy and procedure for the management of records.

Definitions

Record(s) - any information kept, held, filed, produced, or reproduced in any form whatsoever including, but not limited to, reports, statements, examinations, memoranda, opinions, folders, files, books, manuals, pamphlets, forms, papers, designs, drawings, maps, photos, letters, microfilms, computer tapes or discs, rules, regulations or codes.

RF Record(s)- any Record in the custody, possession or control of the RF central office.

Related Information

Record Access Policy

Record Retention: Account Expenditure Records

Record Retention: Person-related Records

Record Retention: Project Administration Records

Forms

None

Note: On or after December 26, 2014, 2 CFR Part 200 is effective and applies to all new awards issued. Funding awarded prior to this date and/or incremental funding may still be governed by OMB Circular A-110, A-21 or A-133, depending on the awarding agency’s specific terms and conditions.

Change History

Date

Summary of Change

December 26, 2014

Changed OMB reference to 2 CFR Part 200.

December 7, 2012

Clarifies that non RF research related documents in the campus possession are subject to SUNY retention guidelines, but allows campuses to adopt this policy for these records if they choose. Updated name and to new template. Effective 3/15/2013

 

 

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