Any records not classified as permanent records will be eligible for destruction consideration once their mandated retention periods elapse and their operational values cease to exist.
Arizona Revised Statute (A.R.S.) § 41-151.19 stipulates that Official Records (henceforth just "records") that no longer have any legal, administrative, fiscal, or historical value (because they fulfilled their mandated retention requirements and no longer have any other operational purpose) shall be eligible for destruction using one of two state approved document destruction methods. Refer to the Destruction Methods section below.
- Maintaining records past their required retention periods without cause increases liabilities for the department and incurs unnecessary storage costs for the University.
- If physical records in storage are required to be kept past mandated retention requirements due to a legitimate operational necessity, notify Records & Archives as soon as possible to make the proper arrangements.
- Consult with your department's leadership to discuss any liability concerns and to ensure the retention extension is justified.
- Also consult with the Office of General Counsel (OGC), if the situation dictates, regarding any potential repercussions associated with maintaining your specific records past their required retention periods.
- Note: Copies created for convenience or reference purposes should not be retained longer than the official record. Convenience or reference copies do not need to be reported to Records & Archives when they are destroyed given all applicable retention and destruction guidelines are met (see guidelines below). Refer to the Definition of a Non-Record for more information.
Litigation and Other Holds
Departments are responsible for making sure that any records, documents, or other materials (paper, digital, or any other media) subject to a current "Litigation Hold" from the OGC, or are subject to any other type of official administrative or audit hold, are retained beyond any and all retention requirements. Failure to do so could result in the University being sanctioned in a legal proceeding. If you are unsure as to whether a Litigation Hold is currently in place, contact the OGC. Departments are also responsible for making sure there are no holds in place of any kind prior to planning or allowing the destruction of any records in their possession.
With respect to physical records being stored by Records & Archives, departments must immediately inform our office of any hold requests by providing the following details so the affected records can be properly preserved:
- The box barcode numbers of the affected records
- The general reason for the hold
- The contact information of the department representative initiating the hold
For records being stored outside of Records & Archives to which a hold applies, e.g., in a digital records storage environment or other departmental records storage area, departments must make arrangements for those records to be held as well.
Conversely, departments should notify Records & Archives as soon as any holds are removed from records being stored by Records & Archives so they can resume following their normal retention plans, or so existing retention plans can be amended based on a new operational need. Please contact us for assistance with this process.
Reporting to the State
A.R.S. § 41-151.19 also stipulates that the destruction of any records subject to retention policies must be reported to the state on an annual basis.
Records Retained by Records & Archives
Records & Archives will be responsible for filing a report with the state regarding the destruction of any stored physical records that complete their mandatory retention periods.
Records & Archives will coordinate with departments regarding the destruction of physical records if departmental approvals are required.
- Records that require departmental approval include, but are not limited to, research, grant, HIPAA related, program creation, select audit, select financial, select student information, select employment, safety related, legal related, policy related, or select space planning and construction related records.
- For those records that do not require departmental approval, destruction confirmations for these types of records will be furnished to the department upon request. It is the department's responsibility to notify Records & Archives immediately if any record holds exist so those records can be properly preserved.
Departments may request a current inventory of their records boxes being stored by Records & Archives at any time. Contact our office to make this request.
Records Retained by Departments
For any records retained by the department during the entire retention period that are now eligible for destruction (paper, digital, or any other media), the department is responsible for destroying these records. The department is also required to notify Records & Archives of their intent to destroy these records using the Self-Report Notice of Records Eligible for Destruction form reporting form (Self-Report Form) prior to the actual destruction of the records. Download the form to your computer so it can be filled out electronically. See the instructions page for a step-by-step guide.
- Records & Archives does not accept physical records for storage that have already completed their retention requirements or are within 1 year of completing their retention requirements. Departments are responsible for destroying these records after reporting the information to Records & Archives and receiving destruction approval.
- Records & Archives does not accept physical records for storage that have a total mandated retention requirement of 2 years or less. Departments are responsible for storing these records and then destroying them after reporting the information to Records & Archives and receiving destruction approval.
- For records destroyed by a department prior to the completion of a required retention period (paper, digital, or any other media), contact the Records & Archives manager for assistance with filling out an incident report and submitting it to the state.
Upon receipt of the Self-Report Form, Records & Archives will verify the accuracy of the information and file a formal certificate of records destruction with the state on behalf of the department. Records & Archives will then return a signed copy of the Self-Report Form back to the department so the destruction of the records can take place. This signed copy is the department's proof of reporting the destruction.
- Contact Records & Archives for assistance with filling out the Self-Report Form. Incomplete or inaccurate submissions will be returned. Read and follow all instructions on the form. Please allow for up to two weeks for processing.
Record Destruction means the destruction of a Record to make it unintelligible or inaccessible. Once a Digital Record or Physical Record is destroyed, the expectation is it will remain destroyed and be considered permanently unavailable.
Digital Record Destruction means digitally altering a Digital Record to the point where it is rendered unintelligible or inaccessible without resorting to some extraordinary forensic data recovery measure.
When destroying a Digital Record, departments must make their best effort to ensure it is rendered unintelligible or inaccessible based on the capabilities of the technology used to store the Digital Record.
Physical Record Destruction means physically altering a Record to the point where it is rendered unintelligible and the remnants are securely discarded using an approved method.
Currently, the University has two approved methods departments may use to destroy physical records: An in-house shredder furnished by the department OR an outside vendor certified by the National Association for Information Destruction (NAID).
- If a shredder is used, the cut style must be cross-cut or finer (strip-cut not authorized).
- Once the documents have been shredded, the paper shreds may be discarded.
- If an NAID vendor is used, Records & Archives recommends contacting the University's Recycling and Waste Management office to arrange for the delivery of a secure document destruction barrel or similar locked container.
- Placing a record eligible for destruction into a secure document destruction container represents the intent to have it physically altered to the point where it is rendered unintelligible. Therefore, records placed into a secure document destruction container will be considered “destroyed” the moment they enter the container even though the actual destruction of the record may take place at a future date when the container is retrieved by the authorized NAID vendor.
- Do not use ordinary unsecured recycle bins or barrels to dispose of any records to which a mandated retention policy applies, or for any records or non-records containing confidential, personal, or proprietary information. When in doubt, treat all information as confidential.
- Ordinary unsecure recycle bins and barrels are approved for use to dispose of non-records that do not contain confidential, personal, or proprietary information.
Always check to ensure there are not any types of records holds in place before destroying any records or non-records belonging to the University.
If you have any questions about the information in this section pertaining to the destruction of records, contact Records & Archives for assistance.