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Policies and Regulations

POLICY TITLE: Document Retention and Disposal

APPLIES TO: All Divisions and Departments

ADMINISTRATIVE AUTHORITY: Library Office of the Registrar Office of General Counsel Division of Finance & Administration

APPROVED BY: Kentucky State University Board of Regents

EFFECTIVE DATE: August 8, 2025

NEXT REVIEW DATE: August 8, 2028

POLICY STATEMENT:

State and federal laws mandate the retention and prohibit the premature destruction of certain documents. The purpose of this policy is to establish a systematic process for the retention and disposal of Kentucky State University (KSU) records. This policy ensures that records are maintained for the required legal, fiscal, and administrative periods and are disposed of in a timely and appropriate manner thereafter.

DEFINITIONS:

Disposition

The final action for a record after its retention period has expired, which may include secure destruction or transfer to University Archives for permanent preservation.

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Legal Hold

A directive issued by the Office of General Counsel to suspend the normal disposition of specific records due to pending or anticipated litigation, investigation, or audit.

Records Retention Schedule

The official State University Model Records Retention Schedule promulgated by the Kentucky Department for Libraries and Archives (KDLA), which dictates the minimum time university records must be kept.

University Record (Public Record)

As defined by Kentucky law, any documentary materials, regardless of physical form or characteristics, which are prepared, owned, used, or retained by KSU.

PROCESS:

Adoption of State Records Retention Schedule

Kentucky State University hereby adopts the State University Model Records Retention Schedule promulgated by the KDLA and incorporates its provisions by reference. This schedule serves as the official authority for all university records retention periods.

Employee and Departmental Responsibilities

All KSU employees are responsible for managing the university records in their control in accordance with this policy, whether those records are in paper or electronic format.

Information must be maintained in a manner that ensures it is accessible to appropriate parties for its entire retention period.

Each department head shall designate a departmental records coordinator to oversee compliance with this policy within their unit.

Legal Holds

No university record, whether paper or electronic, will be destroyed or deleted if it is pertinent to any ongoing or anticipated government investigation, proceeding, or private litigation.

The Office of General Counsel is the only office with the authority to issue or release a legal hold.

All employees must comply immediately with any legal hold notification and must check with the Office of General Counsel for any current or foreseen litigation before disposing of any documents that may be relevant.

Records Disposition

When a record's retention period has expired and it is not subject to a legal hold, it must be disposed of in accordance with this policy.

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Records containing confidential or sensitive information (e.g., Personally Identifiable Information) must be destroyed in a secure manner, such as shredding for paper records or secure data erasure for electronic records, to render them unreadable.

A log documenting the destruction of records should be maintained by the department.

Requirements for Federal Awards

Records pertaining to federal awards will be retained for at least three (3) years from the date of submission of the final financial report, in accordance with the Uniform Guidance Records Retention Requirements (2 CFR 200.334).

REFERENCES AND RELATED MATERIALS:

State University Model Records Retention Schedule (KDLA)

Open Records Policy

Open Records Request Procedures

2 CFR 200.334

725 KAR 1:010

CONTACTS:

Subject	Office	Telephone	E-mail
Policy Questions	Office of General Counsel	(502) 597-6414	Zachary.Atwell@kysu.eduGeneral.Counsel@kysu.edu

HISTORY:

Revision Type	Date of Issuance/Revision	Drafter(s)/Editor(s)
Issued (New Policy)	August 2024	YPTC
Substantive Revisions	June 2025	Zach Atwell