Records

  1. Maintenance of records
    1. WU records are stored in either paper or electronic form, or both. Documents will be kept in paper form when required by law. All other documents may be electronic.
    2. WU will retain electronic documents as if they were paper documents and records policies apply equally to both kinds.
    3. The structure of electronic information is determined by the database structure.
    4. All staff required to perform any function shall have ready access to all necessary current materials. This will normally be via the website.
    5. WU shall ensure the integrity, accuracy, and currency of records.
    6. All records (including archives) will be kept in good condition in a secure, safe place in a way that:
      1. they are retrievable at short notice
      2. confidentiality of information is maintained
    7. Movement of any hard-copy records between sites shall be risk-managed.

     

  2. Student access
    1. Students shall retain the right to view their own statement of academic record and file contents during semester in normal office hours.

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  3. Version control
    1. Documents shall normally be dated to maintain version control, unless another version control system is employed. (E.g. number of edition, pathname).
    2. The document version on the website is the current version unless otherwise indicated.
    3. Materials shall be reviewed for currency by the authorized staff or faculty member prior to issue or re-issue.
    4. Non-current documents shall have identifiers of issue and/or amendment status.

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  4. Security procedures
    1. Electronic records are available online through a secure website.
    2. Each page is security coded with an access level that differentiates between students and different categories of staff.
    3. The database entry key is kept outside the htdocs folder so that an intruder who penetrates the webserver and subsequently gets into the htdocs folder still cannot access the database.
    4. If students or staff forget their passwords, they can generate new ones only through the information already in the database.

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  5. Emergency planning
    1. Documents and financial files that are essential to keeping WU operating in an emergency will be duplicated or backed up at least every week and maintained off-site.

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  6. Financial records
    1. The CFO is responsible for oversight but implementation is delegated to the bookkeeper(s).
    2. The bookkeeper is responsible to maintain financial records.
    3. Actual expenses and income are recorded.
    4. Except for petty cash, all finances are transacted through the bank account with sufficient detail provided for accurate accounting to be maintained.
    5. The CFO shall provide the Board annuallly with full audited financial reports.
    6. The CFO shall provide financial reports for Board meetings.
    7. Fees and charges are approved annually by the Board.
    8. Copies of receipts and invoices and other source documents are kept in the records.
    9. Reimbursement of out-of-pocket expenses is made on presentation of receipt or appropriate documentation.
    10. Sufficient funds are retained in designated bank accounts to cover liabilities, and the bank accounts are regularly reconciled to outstanding liabilities.
    11. The Board will appoint a financial auditor.

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  7. Archives
    1. Student records will be kept in perpetuity, for each student granted a transcript, degree, diploma or certificate sufficient for giving academic transcripts of students, and verifying graduates' qualifications with third parties. This normally only includes identifying information, lists of units, and qualifications and transcripts issued:
      1. Full name.
      2. Date of birth.
      3. Most recent address, e-mail addresses, and telephones numbers.
      4. The degree or certificate granted.
      5. The date on which it was granted.
      6. The courses and units on which the certificate or degree was based.
      7. The grades earned by the student in each of those courses.
      8. The testamur number.

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  8. Document destruction and suspension
    1. The CEO is responsible to identify records that have met the required retention period and to oversee their destruction or deletion. Destruction of financial and personnel-related paper documents will be done by shredding.
    2. Document destruction will be suspended immediately, upon any indication of an official investigation or when a lawsuit is filed or appears imminent.
    3. From time to time, the CEO may issue a notice, known as a "legal hold," suspending the destruction of records due to pending, threatened, or otherwise reasonably foreseeable litigation, audits, government investigations, or similar proceedings. No records specified in any legal hold may be destroyed, even if the scheduled destruction date has passed, until the CEO withdraws the legal hold in writing.

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  9. Compliance
    1. Failure on the part of employees to follow this policy can result in possible civil and criminal sanctions against WU and its employees and possible disciplinary action against responsible individuals. The CEO and the Board will periodically review these procedures with legal counsel or WU’s certified public accountant to ensure that they comply with new or revised regulations.

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  10. Document retention periods
    1. WU takes seriously its obligations to preserve information relating to litigation, audits, and investigations.
    2. The information listed in the retention schedule below is intended as a guideline and might not contain all the records that WU might be required to keep in the future. Questions regarding the retention of documents not listed in this chart should be directed to the CEO.
File Category Item Retention period
Corporate records Bylaws and Articles of Incorporation Permanent
Corporate resolutions Permanent
Board and committee meeting agendas and Minutes Permanent
Conflict-of-interest disclosure forms 4 years
Finance and administration Financial statements (audited) 7 years
Auditor management letters 7 years
Payroll records 7 years
Check register and checks 7 years
Bank deposits and statements 7 years
Chart of accounts 7 years
General ledgers, journals, and bank reconciliations 7 years
Investment performance reports 7 years
Equipment files and maintenance records 7 years after disposition
Contracts and agreements 7 years after all obligations end
Correspondence: general 3 years
Insurance records Policies: occurrence type Permanent
Policies: claims-made type Permanent
Accident reports 7 years
Safety (OSH) reports 7 years
Claims (after settlement) 7 years
Group disability records 7 years after end of benefits
Real estate Deeds Permanent
Leases (expired) 7 years after all obligations end
Mortgages, security agreements 7 years after all obligations end
Tax Taxation exemption determination and related correspondence Permanent
Salary payment summaries 7 years
Charitable Organizations Registrations 7 years
Human resources Employee personnel files Permanent
Retirement plan benefits (plan descriptions, plan documents) Permanent
Employee handbooks Permanent
Workers comp claims (after settlement) 7 years
Employee orientation and training materials 7 years after use ends
Employment applications 3 years
Withholding tax statements 7 years
Timecards 3 years
Technology Software licenses and support agreements 7 years after all obligations end
Student academic records The names, addresses, and educational qualifications of each member of the faculty. Permanent
Catalogs Permanent
Other documents on educational programs and the curriculum for each. At least five years
Academic results and identifying information, sufficient to issue or verify academic transcripts and qualifications. Permanent
Assessment evidence and tools Whichever of the following is the longer:
Proposed added item: • the student's enrollment period
• the student's right of appeal against assessment results
• up to one year afterwards if there will be an external audit in that time.
• identified risk of litigation.
Educational reporting required by government or accreditation agencies This data may include, for example:
• Student satisfaction data
• Completion rate for each program
• Job placement rate
• A list of employment positions used to calculate job placement rates
• Earnings of graduates
• The percentage of enrolled students receiving federal student loans.
• The data used to substantiate calculations of the above rates. 		At least five years