TO: Email Recipients For Implementation
FROM: Jamie Lewis Keith, Vice President and General Counsel
RE: EMAIL AND RECORD RETENTION – EFFECTIVE IMMEDIATELY
The Principal Investigators and Deans who receive this memorandum are directed by University of Florida to preserve all records (in any medium) related to all research proposals, awards, awards financial accounting, and all other research-related matters referenced below, effective immediately. This direction is in response to a U.S. Department of Health and Human Services, Office of Inspector General direction and review. When the University receives such direction, the law requires the institution and individuals to preserve records.
Why is it so important to retain documents at this time?
It is critical that the described records not be destroyed. Civil or criminal sanctions may be imposed solely because an item is destroyed, even if the item isn’t ultimately determined to be important.
You must not discard records even if that would normally be your practice. Any automatic electronic destruction process must be discontinued.
Any University policy that would allow for the destruction of records described in this memorandum is suspended and superseded until further notice.
What is a “Record”?
A record is any item in any medium (e.g., electronic, paper or recording) that contains information. For example, a “record” includes drafts, outlines, handwritten personal notes, charts or graphs, copies of original records, messages, and calendars. “Record” also includes information stored electronically, such as e-mails, databases or audio and video recording.
Should I notify other employees?
Principal Investigators who receive this memorandum should implement these records retention requirements in their research groups, including by requiring retention by researchers, technicians, research assistants and administrators in their groups. Deans who receive this memorandum should implement these records retention requirements in their areas, including by requiring retention by all individuals (including department heads and research and research accounting staff) working in their areas who work with research or research administration.
If you have any questions about records or other materials under your control, or if you receive any inquiries regarding this matter, please contact:
Amy Hass, Senior University Counsel
Office of the Vice President and General Counsel
“All records” referenced in the following list–which must be preserved– include, but are not limited to the complete award file, proposals, notices of award, budgets, any award modifications, any notes and correspondence contained in awards files, general ledgers (including individual subsidiary ledgers), purchase orders, invoices, vouchers, notes from meetings discussing these awards, committee or grants team meeting notes, and Financial Status Reports and Financial Reports:
- All records from February 17, 2009 to the present related to or associated with any American Reinvestment and Recovery Act (ARRA) award;
- All records from January 1, 2005 to the present related to or associated with UF Jacksonville federal awards;
- For now, all records related to or associated with any other federal award on which you are the Principal Investigator—although the Division of Sponsored Research will provide you with a list of specific awards soon;
- All Financial Status Reports for ARRA awards, UF Jacksonville federal awards, and any other awards on which you are Principal Investigator;
- All records from January 1, 2005 to the present identifying federal flow-through awards;
- All records from January 1, 2005 to the present identifying cost transfers in connection with federal awards;
- All records relating to the interpretation, implementation or amendment of UF’s federal grant management and accounting policies and procedures.
- All records identifying auxiliary or donor accounts and account balances from January 1, 2005 to the present.