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Electronic Data Retention and Preservation

Information Technology Services – Fred Miller, Chief Information Officer
Last Revised: 3/6/17
Title: Electronic Data Retention and Preservation Policy
Applicable: Wofford students, faculty, and staff
Contacts: IT Help Center x4357

Background: Wofford College is required to maintain appropriate data backups to safeguard College information in the event of natural disaster or other unplanned interruption in normal business operations. In addition, the Federal Rules of Civil Procedure allow for the discovery of electronic stored information (ESI) if needed as part of a litigation. In order to comply with recovery and litigation requirements, Wofford College needs a policy which outlines how all ESI will be maintained and stored.

Policy: In order to safeguard College information, and to preserve information needed in the event of litigation, Wofford College will store and maintain electronic stored information (ESI) in accordance with the requirements of the Federal Rules of Civil Procedure. In the event that ESI is needed for litigation purposes, Wofford College will preserve data identified as relevant until the hold is terminated.
 

Guidelines:

  1. ITS will store and maintain backups for the following categories of data. Each category of data will be maintained for its defined retention period.
    1. College Business Data – includes data stored on campus servers and storage systems classified as College Business Data. Servers containing this data are backed up nightly. Copies of this data are stored in our on-campus alternate data center, and may be copied to cloud storage as deemed advisable by the Director of Networks. Copies are retained for a period of 21 days. After 21 days the data will be deleted and not be retrievable.
    2. College Non-Essential Operations Data – The College also maintains logs and other data that are not essential to resuming operations in the event of a natural disaster of unplanned interruption. The data retention periods for this data varies.
    3. College Cloud Services – the College has established contractual relationships with a number of vendors to store College data off-campus as part of Software-as-a-Service relationship. Back-up and disaster recovery for these services are the responsibility of the vendors, and vary based on the contract.
    4. College e-mail – Wofford College uses Google gmail for student email, and Microsoft Office365 for faculty and staff email. The college is unable to recover emails once the emails have been deleted from a student’s gmail account. The College is able to preserve email for a faculty or staff member after they have been identified as subject to a litigation hold, but cannot recover emails deleted before their account has been marked as needing ESI preservation.
  2. ITS will maintain a list of servers identified as containing College Business Data. ITS will also maintain a list of the College’s Cloud Service providers.
  3. Unless subject to an ESI preservation notice, records will be destroyed at the end of their retention period.
  4. Information that has been routinely deleted, destroyed, or overwritten in accordance with this policy is not reasonably accessible because of undue burden or cost.
  5. The College’s Director of Purchasing and Risk Management will coordinate the College’s response to litigation hold notices.
  6. Once notified of a litigation hold event, ITS will take immediate steps to preserve all relevant College Business Data. ITS will also add electronic discovery archiving to faculty and staff email accounts identified as subject to the litigation hold.
  7. Preservation of information does not mean that it will necessarily be made available to an opposing party. Before any information is turned over to an opposing party, Wofford’s counsel will review the information for relevance and determine what is not otherwise protected or privileged.