(Doc. T00-051) These Guidelines are issued pursuant to the Board of Trustees’ Policy Statement on Fraudulent Financial Activities (Doc. T00-051, adopted August 2, 2000). Described herein are the steps to be taken when fraud, misappropriation, or similar dishonest activities are suspected. Each campus will be responsible for developing procedures designed to comply with this University Guideline…, General Protocol - Reporting Procedure, Anyone who believes fraud has occurred should report such incident. Employees are protected under Massachusetts General Law, Chapter 149, section 185, from retaliatory actions by the employer. Use the channel of communication with which you are most comfortable. Accordingly, you may report your concerns to your immediate supervisor, department head, campus audit liaison, vice chancellor,…, Responsibilities, University administrators and all levels of management are responsible for establishing and maintaining proper internal controls that provide security and accountability for the resources entrusted to them. Administrators should be familiar with the risks and exposures inherent in their areas of responsibility and be alert for any indications of improper activities, misappropriation, or dishonest…, Investigation Responsibilities, The University Auditor’s Office will evaluate reported situations involving possible impropriety in financial matters pertaining to the University and make inquiries to the extent necessary to determine whether the allegation has substance. The campus audit liaison will be kept apprised of these activities. The University Auditor’s Office is available and receptive to receiving relevant…, Non-Fraud Irregularities, Identification or allegations of acts outside the scope of this policy, such as personal improprieties or irregularities, whether moral, ethical, or behavioral, safety or work environment related, or complaints of discrimination or sexual harassment, should be resolved by the respective area management in conjunction with human resources and/or reference to any other existing University guidance…
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(Doc. T99-061) Effective January 21, 2013 To comply with applicable legal and regulatory standards and the University’s Record Management Policy, to meet good business practices, and to minimize the cost of record retention, the President has issued the following Guidelines for record management pursuant to Trustee Policy T99-061. These guidelines apply to each campus and the President’s Office…, I. Purpose of Guidelines, To establish the standards governing the retention and destruction of all Records, as defined herein, produced or received by the University, identify the appropriate custodians of University Records and establish a method for preserving University Records. All University employees are responsible for ensuring that University Records are generated, used, maintained, stored and retained in…, II. Scope, These Guidelines: Are based on the regulations and laws of the Commonwealth of Massachusetts and the United States, and other accrediting or regulatory bodies [e.g., IRS, NCAA, Equal Employment Opportunity Commission (EEOC)]. If these Guidelines conflict with any applicable law, the law takes precedence and will apply. University policies may impose certain restrictions that are not specifically…, III. Definitions, Record., Any item containing recorded information, generated or received, in any medium and regardless of form or characteristic. Records include: emails, voice mails, text messages, documents, letters, memoranda, reports, cards, books, maps, photographs, blueprints, sound or video recordings (e.g., vinyl records, CD’s, DVD’s, audiotape, videotape), microfilm, magnetic tape, and any other media that…, University Records., Records generated or received by or on behalf of the University, which include information pertaining to University business or resources, or the functions, policies, decisions, procedures, operations, or other activities of any University department or business unit. This definition is to be interpreted broadly., Non-Records., Documents which are not essential are considered Non-Records, and do not need to be kept for any period of time. In general, when reviewing a document to determine whether it is a University Record or a Non-Record, employees need to think about the reasons why the University might want to preserve the information, and how the University uses the document and its contents. As a general rule,…, Legal Hold., A directive by the University’s Office of General Counsel, which alerts some segment of the University that an investigation, litigation, or other legal action has been, or may be, filed against the University. Once a Legal Hold is in place, the University is under a duty to preserve every existing document covered by the Legal Hold, including University Records and Non-Records, until the…, Confidential Records., Any University Record containing personal information or other information, the disclosure of which would harm the privacy of individuals or the security of the University, or that has been designated as confidential by federal or state law. Confidential Records include, but are not limited to, patient or medical records, student educational records, security plans, and trade secrets., Records of Historic Value., Under state law, all Records created prior to 1870 are of Historic Value. The University may deem certain Records created after 1870 to be of Historic Value for the University’s own purposes. Records of Historic Value may not be destroyed and should be archived., IV. Retention of Records, Retention Periods, . In general, the University treats the time periods set forth in the Massachusetts Statewide Records Retention Schedule (“State Schedule”), promulgated by the Secretary of State of the Commonwealth of Massachusetts, as an excellent guide to establish the time periods for which the University should maintain various categories of University Records. Since the State Schedule is a guide, the time…, Record Administrator., The Chancellor of each campus shall designate an individual (“Records Administrator”) who will have primary authority for compliance with these Guidelines; the President shall designate the individual responsible for compliance by the system office. The Records Administrator shall: maintain a copy of all Retention Schedules created by the Records Administrator’s campus/system office’s business…, Retention Schedules., Each business unit shall determine the retention schedule that best addresses its unit’s Records. Campus and System Office business units may use the time periods set forth in the State Schedule, or portions thereof, if deemed appropriate for University Records. may choose to use the State Schedule in its entirety, portions of the State Schedule, or create its own schedule; ensure that such…, Records Covered by More Than One Retention Period, . University Records falling under several retention periods shall be retained for the longest applicable retention period., University Records Not Covered, by a Record Schedule. If a University Record is not covered by the applicable State Schedule, a department or business unit head, in consultation with the relevant campus or system office Records Administrator, should determine the retention period for the record., Beginning of Retention Period., The Retention period begins when the document is created by an employee or when an employee receives a document from any source, e.g., another campus or department, vendor, contractor, etc., Contractual Retention Period., If an agreement provides that certain Records will be kept for a period that is longer than the established retention period, the period specified in the agreement controls., Record Substitution., To the extent not prohibited by law or regulation, a Record in paper form may be digitally scanned, placed on microfilm or micro-fiche, and substituted for an original paper document. The applicable retention period for a Record does not change when a properly substituted image of a Record is created. A Record’s mandatory minimum retention period is counted from the creation or receipt of the…, Inappropriate Treatment of Records., Any University employee who becomes aware of the inappropriate removal, modification or destruction of any Record must promptly notify their immediate supervisor, or, if necessary, the Office of General Counsel or University Internal Audit, about any such activity., Notice of Legal Holds., A copy of every Legal Hold notice shall be sent to all relevant Records Administrators., Departure of University Employees., Records created or maintained by an employee are still University Records which must be preserved pursuant to these Guidelines after an employee leaves the University. Every manager must take steps to preserve the University Records kept by the employee including email and other electronic records, and should contact the Human Resources and Information Technology departments for assistance. A…, V. University Record Retention and Destruction Responsibilities, Retention, Employees are responsible for determining what Records used in the employee’s own work are University Records and assure they are retained for the appropriate time. Employees should periodically review their Records to determine if they are appropriately retaining Records. University Records must be maintained on University property or storage facilities, or on University servers and e-mail…, Deletion and Destruction of Documents, Employees should destroy all University Records, with the exception of any Records subject to a Legal Hold, as soon as practicable after the relevant record retention expiration date. Each business unit shall set an annual date by which all Records whose retention period has expired in the preceding 12 months have been destroyed. Managers must keep an annual record of the types of Records…, VI. Administration and Interpretation, Questions about the administration or interpretation of these Guidelines should be directed to the Office of General Counsel.
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