Policy: IM05: Records Retention Policy and Procedures


  1. Purpose
    RHI supports appropriate access and privacy protection of official student academic records consistent with its commitment to Freedom of Information and Privacy Protection Act (FIPPA) requirements. This policy outlines RHI procedures and criteria for access, privacy, custody, and retention of students’ academic records to best support clarity and consistency in practice. Accreditation requires the DMS program to adhere to the privacy guarantees for student records and information. The Robert Health Institute has policies and procedures for maintaining, removing, and archiving student evaluation records. Teaching and clinical instructors must submit all types of retention records. Submissions are then reviewed by QAC or designated staff, and the length of time to retain records is determined in accordance with QAC’s mandate and compliance with provincial and federal laws.

RHI’s Records Retention Policy encompasses electronic records and ensures compliance with information-related legislation (specifically Ontario’s Freedom of Information and Privacy Protection Act(FIPPA)).

  1. Definitions
    2.1 Student: The student is any person enrolled at RHI in full-time or part-time study leading to a post-secondary diploma or certificate from RHI. It includes students who are on scheduled breaks or leave school.
    2.2 Nimble Information Strategies Inc (NIMBLE): Third parties that store student assessment record information for a minimum of 25 years.
    2.3 Former student: means any person who is no longer considered a “student” or an “alum/alumnus.”
    2.4 Permanent information: Persistent information means information that RHI keeps permanently, including,
    4.4.1. Personal information is required in the administration of official student academic records, such as legal name, student number, date of birth, citizenship, postal address, email address, and telephone number.
    4.4.2. Academic information such as diploma name, specializations, results for each course attempted, and registration status by academic term.
    4.4.3. Academic progression decisions (or academic standing)
    4.4.4. Credential received and date of conferral
    4.4.5. Academic awards and honors received

2.5 Non-permanent information: means information that RHI disposes of in accordance with post-secondary student records retention schedules and disposition schedules, including,
2.5.1 Narrative evaluations of a student’s academic performance subsequent to their admission, used to judge their progress through an academic program.
2.5.2 Bases for a student’s admission, such as the application for admission and supporting documents.
2.5.3 Results of petitions and appeals filed by a student.
2.5.4 Information relevant to a student’s academic performance has been furnished at the request or with the consent of the student concerned.
2.5.5 Letters of reference that may or may not have been provided on the understanding that they shall be maintained in confidence.

3. Policy and Procedures
Records will be kept in the Staff/Student Office as required by law. Records of student evaluation will be kept for 25 years with a third party at Nimble Information Strategies Inc (NIMBLE). While it is necessary to carry personal records to perform various functions, once the task is interrupted or the work is completed, these records must be returned and stored for the next use.

3.1 Academic Records
3.1.1 Enrolment Reports – These reports (including all spreadsheets and Ministry audits) will be kept permanently. They will be stored in a secure location with limited access.
3.1.2 Course Section Marks and Student Marks – These records will be kept permanently. Course exam marks and student marks are kept together by student files and then alpha by the student name with student-specific marks attached to the course section with which they are associated. Due to the ever-increasing volume of these documents, storing these records outside of the Office of the Registrar may be necessary for a secure location and scanning copies of submitted grades to NIMBLE electronically for storage for 25 years. Paper and electronic copies of grades have been verified and signed by the instructor and/or President and will be retained in perpetuity.
3.1.3 Graduation Assessments (Diploma Audits, Substitutions Memo, etc.) – All information related to graduation assessments will be kept on file for 25 years. This retention period will allow unsuccessful candidates ample opportunity to obtain information on how final decisions were reached. These records will first be kept in student name order and then moved by the program to a safe location for later use.
3.1.4 Unresolved requests are held by a designated secretary and are sorted by their stage in the process, then alphabetically by last name.
3.1.5 Special Exams and Exam Applications – Special exams and their requests will be held in the Staff/Student Office for one year by semester, then alphabetically by last name.
3.1.6 Graduate Student Files – These files are kept alphabetically by last name. These documents will be processed one year after the student graduates.
3.2 Clinical Records
3.2.1 Clinical placement Evaluations: (Clinical performance evaluation, CCSA exams, Clinical rotation Memo, etc.) – All information related to the Clinical Placement Assessment will be kept in the Clinical Coordinator’s file for one year. The clinical coordinator submits the original and electronic copies to the CCSA representative at the end of the student’s clinical placement. The CCSA representative transfers the original clinical CCSA assessment document and electronic copy to the Sonography Canadia and QAC office. The QAC will send it to the Staff/Student Office for perpetual retention and send it to NIMBLE for 25 years of storage. This hold period will provide ample opportunity for unsuccessful candidates to obtain information on how to reach a final decision. These records will first be kept in student name order and then moved by the program to a safe location for later use.
3.2.2 Co-operative Placement Information/Paleo DNA Information – These records will be kept alphabetically for one year

3.3 Transcript Requests Records
3.3.1 Hardcopy Requests: Transcript requests that fall into this category include hardcopy forms and fax and email requests submitted to the Staff/Student’s Office. These records will be kept for five years in alphabetical surname order based on the month in which the request is made.
3.3.2 Online Requests-Transcript requests are automatically assigned to the individual student record unless the request is designated “pending.’ until assigned to requesting student.
3.3.3 Sponsorship Letters/ Student Consent Release Forms – The Student Consent Release Form is to be attached to the transcript request and kept on file. (See Hard Copy Requests above).
3.4 Biographical Records
3.4.1 Exemption Forms-Immigration documents will be stored alphabetically by the last name for one year after the student graduates. Those students who do not graduate will keep their immigration documents until their program is canceled.
3.4.2 Name Change Forms – Hard copy forms will be destroyed when student electronic records are changed.
3.5 Communication Records
3.5.1 Background Check Authorization Forms- These forms, signed by the current/former student, are sent to the Staff/Student Office by various agencies looking to verify information about the student. Once the request has been fulfilled, or the request has expired, then scanned to the electric copies for permanent retention under the student file. However, the hard copy forms are destroyed if applicable.
3.5.2 Confirmation of Enrolment Requests – Confirmation of Enrolment requests is stored electronically on the student’s record. Hardcopy requests are stored alphabetically for one year.
3.5.3 List of Approved Graduands – A list of successful graduates will be posted on the website prior to each convocation ceremony. All previous listings will be permanently displayed on the website under the Graduation webpage. The information in these lists will be considered public information unless otherwise requested by the student. Copies of the convocation program will be retained in the Staff/Student Office.
3.5.4 Letters of Permission- (Request, Copy of Letter, and Director/Chairman’s Permission) – Electronic copies of the permission will be kept by year issued. Electronic Letters of Permission records will be kept for five years. Students who have not earned transfer credit within five years will be asked to reapply.
3.5.5 Letters of Successful Completion- Copies of these letters are retained in electronic form.
3.6 Registration Records
3.6.1 Enrolment Reports – These reports (including all spreadsheets and Ministry audits) will be kept permanently. They will be stored in a secure location with limited access.
3.6.2 First Aid Certificate Copies –Electronic copies of documents showing successful completion of the Student First Aid Certificate will be kept permanently, but hard copies will be destroyed once the electronic copy is recorded on the student’s transcript.
3.6.3 Timetable Information – Timetable-related information and all exam timetable information will be retained for five years. These records will be stored in accordance with the terms within the Staff/Student Office.
3.7 Government Records
3.7.1 Evaluation of Accreditation Canada -These letters will be kept electronically permanently for the next evaluation cycle.
3.7.2 Ministry of Colleges and Universities letter -These letters will be kept electronically permanently for every renewal cycle.
3.7.3 CMRITO and Sonography Canada letter- These letters will be kept electronically permanently for every renewal cycle.

This policy refers primarily to the article: Records Retention Guide.