Cloud Storage

Any records created or received by your office must remain findable and accessible for the full retention period. This is not always straight forward in OneDrive/Google Drive. Keep in mind when using these systems:

You must retrieve and preserve any records which have not passed their retention until the full retention period has been met. While migrating these records to your new vendor’s platform is not absolutely required, the records must be retained in a form that remains accessible and readable. We recommend wording to this effect be included in your contract to help eliminate any misunderstandings on this point.

Any metadata is considered to be part of the record and must be preserved and managed for the full retention period, the same as the content.

It is your responsibility to ensure vendors meet the retention requirements as well as delete the records after the retention has been met.  Further, the University must be able to access the records for the entire retention period, especially if they need to be turned over to the public records office, auditor or an attorney.

Yes. Using a third-party vendor to store information in the cloud or using third-party services, such as Moodle, as part of interaction with students does not affect how these records are defined. Even if the records are not in our custody, these records are created on behalf of the University.