Section: Information Technology
Policy Number: 925Responsible Office: Information Technology
Effective Date: 5/1/19Revised: 5/1/19; 6/11/20
The purpose of the Record Retention and Data Disposal Policy is to establish mandatory records retention and disposal plans as part of an overall records management program that applies to all departments and authorized users at St. John’s University (St. John’s). This policy outlines the practices for managing, maintaining, and disposing of records in an orderly, reasonable, and lawful manner.
This policy applies to the University Community. Adherence to this policy helps safeguard the confidentiality, integrity, and availability of St. John’s information assets, and protects the interest of St. John’s, its customers, personnel, and business partners.
Records are classified as follows:
Active records are those that are currently being used in the operations and transactions of the business or are otherwise part of current activities such that they need to be organized, classified, and maintained in a form suitable for fast and reliable access for individuals authorized to use the records. Active records are stored in a primary storage medium, such as accessible file cabinets for paper, and disk and cloud storage for electronic records.
A review of the record is conducted after the expiry of the retention period or, if that is not feasible, the record is retained, and a later review date is set. The review is conducted by the appropriate personnel in consultation with relevant stakeholders.
Decisions must not be made with the intent of denying access or destroying evidence.
Once a record is no longer active, it may be archived for a period as set forth in the St. John’s Records Retention Schedule.
To reduce records storage requirements and associated costs, all records that have no such value to St. John’s are destroyed on a regular basis. If a class of records is not referenced in the Records Retention Schedule, it is considered as having no value for retention and is destroyed once the record’s immediate purpose is completed. Such records may include the following:
Destruction of Records Containing Confidential Information: Records are destroyed in a manner that ensures the confidentiality of the records and renders the information unrecognizable. The approved methods to destroy records include:
Disposal of Electronic Media: All external media are sanitized or destroyed in accordance with industry standard compliant procedures.
Disposal of IT Assets: Department managers coordinate with the IT Department on the disposal of surplus property that is no longer needed for business activities.
PCI DSS compliance requires that cardholder data is handled uniquely and independently of other data classifications. For cardholder data, the following requirements must be fulfilled:
The following are the definitions relevant to the policy:
St. John’s reserves the right to audit networks and systems on a periodic basis to ensure compliance with this policy. Instances of non-compliance must be presented to, reviewed, and approved by the CIO, the Director of Information Security, or the equivalent officer(s).
All breaches of information security, actual or suspected, must be reported to, and investigated by the CIO and the Director of Information Security.
Those who violate security policies, standards, or security procedures are subject to disciplinary action up to and including loss of computer access and appropriate disciplinary actions as determined by St. John’s.