PURPOSE:
Idaho College of Osteopathic Medicine (ICOM) generates a wide variety of written material in
electronic and paper forms, and some must be retained for varying periods. Records retention
policies and regulations are identical regardless of the form. This document outlines the policy
and procedures governing the retention and destruction of records at ICOM.
SCOPE:
This policy applies to all members of the ICOM community who manage and maintain ICOM data.
POLICY:
ICOM retains vital records of the history of the College to guide current and future operations
and to comply with its legal obligations. Two important categories of material that must be
retained and disposed of with particular care are records of historic value and those governed
by regulation. They should be retained for a period consistent with their purpose and as may
be required by law.
The Registrar shall be official steward of student records.
All Institutional Records are the property of ICOM, regardless of their physical location, even
when they are in the possession of individuals, and, as such, shall not be permanently
removed from the Institution nor destroyed except in accordance with this Policy.
Any ICOM business conducted, or Institutional Records stored on institutional or outsourced
IT services are subject to the provisions of the ICOM Data Security and Acceptable Use
policies; may be subject to a litigation discovery request, subpoena, or court order; and may
constitute a public document subject to disclosure under applicable Federal and State laws.
Record retention is applied across Departments, regardless of type of Institutional Record.
Email and other electronic communications relating to ICOM business are part of the
Institution’s records and shall be retained depending on the nature of the document,
consistent with the retention requirements for that type of document.
If ICOM is a party to a lawsuit, faculty and/or staff must preserve such records until ICOM’s
legal counsel determines that the records are no longer needed. The Office of the President
will notify department heads to preserve paper and electronic records in the event of
litigation or investigation.
Employees who become aware of the possible omission, falsification, or inaccuracy of
information entered into Institutional Records, or become aware of the improper destruction of records, shall report this knowledge to the Chief Information Officer and/or Director of
Compliance.
Non-records, as defined, are maintained for as long as administratively necessary and
retention schedules do not apply. Non-records may be discarded when business use is
terminated, unless there is a legal matter prohibiting destruction.
Official records stored on-site may be stored as hard copies with digitized backups or in a
media suitable for the storage of the record.
Official records shall be duplicated onto an appropriate media and stored in designated off-
site storage facilities, for reconstructive use in the event of a natural or man-made disaster.
Off-site storage facilities are secure locations that safeguard the records from ordinary
hazards such as water, mildew, rodents; man-made hazards such as theft, accidental loss,
sabotage; disasters such as fire, flood, earthquakes, wind; and unauthorized use, disclosure,
and destruction.
Compliance with record retention shall be reviewed periodically and modified as mandated by
changing legal requirements and Institutional policy.
Failure to comply with this Policy may result in punitive action against the violating faculty or
staff member, including suspension or termination.
RESPONSIBLE OFFICIALS:
ICOM Faculty, Staff, and Students; Registrar
POLICY OWNER:
Chief Information Officer/Information Security Authority
APPROVAL:
Effective: 8/23/21
Last Reviewed: 1/25/24
Review Requirement: Annual