The majority of sponsored projects have legal requirements as to how long project records, particularly financial records, must be retained. These guidelines recognize these legal requirements as well as the substantial physical and fiscal resources required to retain technical, clinical, financial and other project records. “Records” includes any documentary material made or received in connection with the application for, or conduct of, a sponsored activity. “Records” includes paper, electronic records, and records, reports or data in other media. Electronic records should be backed up regularly in a way that would prevent a catastrophic loss and ensure the quality and integrity of the data. Records should not be retained longer than required. This minimizes unnecessary administrative burden and expense, and records discarded in accordance with regulation and policy are no longer available for audit. Legal requirements and recommendations: Federal awards - Retain records for 3 years after submission of the fiscal status report (annual or, if annual is not required, competitive segment) or after final payment under a Federal contract. If any litigation, claim, or audit is started before the expiration of the 3-year period, the records must be retained until all litigation, claims or audit findings involving the records have been resolved and final action taken. Record retention under Federal grants is governed by OMB Circular A-110, specifically 2 CFR 215.53. Record retention under Federal contracts is governed by the Federal Acquisition Regulation, specifically FAR 52.215-2. State and City awards – A number of these awards require that UMB retain fiscal records for 6 years; it is recommended that all records for projects funded under State and City awards (MOUs, grants, agreements) be retained for 6 years. Other awards - Check the award terms and conditions or the sponsor’s written policies. If the sponsor or award document does not specify a specific time period to retain project records, follow the Federal requirement (retain for 3 years after final payment under the award). Scientific and other technical records Program reports – Retain programmatic/technical progress and final reports for at least 3 years after submission of the final report. Projects that resulted in an invention or discovery - In the event that an invention has resulted from the project, check with the Commercial Ventures & Intellectual Property staff in Office of Research and Development for advice on retention of relevant records. Scientific data – Retain the original data and all project records for at least 3 years after submission of the final report or award termination. Most such records are retained for many years. After the required retention period, the principal investigator/project leader may make the decision to retain the records or to discard them when the records are determined to be no longer useful for research or educational purposes. Clinical study records Corporate clinical study agreements include a provision specifying the required period of record retention for source documents, which may differ depending on the type of study and, ultimately, the success of the test product. The source (essential) documents must be maintained according to FDA regulations. The sponsor should notify UMB and the investigator when the records are no longer required. The ICH Guidance for Industry - E6 Good Clinical Practice: Consolidated Guidance is a good resource regarding essential documents, retention and audit. For studies involving children, records are to be retained indefinitely. Faculty transfers Project records (data, etc) generated at UMB are to be retained at UMB for at least the required retention period. The departing faculty member may take copies of these records. Clinical study data must remain at UMB. Confidentiality provisions of the award as well as HIPAA regulations will generally prohibit the departing faculty member from retaining copies of these data. Discarding and destroying records Be aware of confidentiality and inclusion of personal information in the records. Shred paper documents containing personal, proprietary or confidential information. Deletion of an electronic record may not eliminate all remnants of the record. Ensure that data are securely removed from the media before the computer, disk, tape, USB drive or other device is transferred or discarded. Ask your IT expert about an appropriate utility or program for this purpose. back to top | 
