CourseLink Retention and Disposition Policy

CourseLink Retention and Disposition Policy
Subject CourseLink Retention and Disposition Policy 
Date of effect July 15, 2024
Date of last revision  May 1, 2024
Date due for review May 1, 2025. Thereafter, review at least once every year.
Previous policy N/A
Responsibility for policy and related procedures

Executive Director, Open Learning & Educational Support

Manager, Online Technologies

Related legal requirements, codes of practice and/or University policies
  • Ontario “Freedom of Information and Protection of Privacy Act” (“FIPPA”)
  • University of Guelph Records Management policy
  • University of Guelph Acceptable Use Policy and Guidelines
  • University of Guelph Access and Privacy Guidelines
  • GDPR
  • University/departmental business needs 


This policy covers the following:


Open Learning and Educational Support has developed this policy to:

  • Establish standard practice for the retention and disposition of electronic CourseLink records
  • Establish standard schedule for the transfer/disposal of records (Appendix 1)
  • Preserve University history (but with the understanding that only a small percentage of records continue to have value indefinitely and are kept permanently)
  • Define responsibilities for the creation of policies and standards relating to, and the management of, CourseLink records


All records created, received, and/or maintained by Open Learning and Educational Support employees and those acting as agents in the course of their duties with regard to CourseLink, regardless of physical form or characteristic (including paper, electronic, audiovisual, microform), are considered CourseLink records and subject to this policy.

The policy therefore applies to all CourseLink records and records from predecessor learning management systems and covers all records regardless of format, medium or age and impacts upon those who:

  • create electronic records;
  • have access to records;
  • have any other responsibilities for records, for example storage and maintenance responsibilities;
  • have management responsibility for staff engaged in any these activities.


Record: Any information contained in any electronic medium which is capable of preserving such information. Includes any information contained in the original and in any copy of correspondence, memoranda, forms, directives, reports, drawings, diagrams, cartographic and architectural items, pictorial and graphic works, photographs, films, and sound recordings, regardless of form and characteristics.

Active Record: A record that is usually less than one year(s) old and to which reference is sufficiently frequent that it must be held for operational purposes.

Dormant Record (also: “Semi-Active” records): A record that is usually more than one year(s) old and to which access is neither frequent nor urgent enough to warrant maintenance in relatively expensive virtual space.

Electronic files: Any electronic record stored either on a personal computer, central computing facility or electronic device. Online storage, or cloud storage, is usually considered to be records that are located on an active disk or memory device. Offline storage can be any remote storage facility.

Non-Records (also: “Working”, “Unofficial” or “Transitory” records): Records created incidental to performance of the mission. They are "operational", "support", and "service" type records which are considered to be of temporary value to CourseLink (e.g., duplicate copies of correspondence, duplicate copies of records used for short term reference purposes, blank forms, and transitory messages used primarily for the informal communication of information, etc.). Transitory messages do not set policy, establish guidelines or procedure, certify a transaction, or become a receipt. Transitory messages may include but are not limited to e-mail messages with short-lived or no administrative value, voice mail, self sticking notes, document drafts, and meeting notes. Non-records and transitory messages should be maintained for as long as administratively needed, and the retention schedules do not apply. Non-records should be discarded when their business use has ended.

Retention Periods: The retention periods indicated in the CourseLink Retention and Disposition Schedule (Appendix I) are to be used as a recommendation concerning the length of time a record should remain in an active records office or online (A) and the length of time it should be stored in a dormant area (D). This is indicated, for example, by recording "A-2, D-3" for a record having a five-year retention. Established retention periods will be followed unless there is a legitimate business purpose for granting an exception and the exception is approved by the Manager, Online Technologies. An example exception might include access to course records for provincial reporting purposes.


Information is a resource of the same importance to good management as other standard resources like people, money, and facilities. It represents its collective memory, underpins its daily operation and supports the image it presents to the world outside. The information resources of CourseLink must therefore be managed as a valuable asset. Appropriate records management is a vital aspect of maintaining and enhancing the value of this asset.

Records management, through the proper control of the content, storage and volume of records, reduces vulnerability to legal challenge or financial loss and promotes best value in terms of human and space resources through greater co-ordination of information and storage systems.


The Executive Director, Open Learning & Educational Support together with the Manager, Online Technologies are ultimately accountable for the recordkeeping and records management practices of CourseLink and ensuring it follows this policy. Note that the University of Guelph “FIPPA Delegation of Authority instrument” recommends that the authority for the development of department-specific records management plans for records containing personal information should be done via records retention schedules filed with relevant vice-president or, where not applicable, the President.

The Manager, Online Technologies is committed to enhance accountability, transparency and improvement of service delivery by ensuring that sound records management practices are implemented and maintained.

The Manager, Online Technologies supports the implementation of this policy and requires each staff member to support the values underlying in this policy.

Staff with specific responsibilities for records management will have these clearly defined in their job descriptions.


It is important that archiving of records happens as part of a managed process and is adequately documented. Therefore, CourseLink must have in place clearly defined arrangements for the appraisal and selection of records for archiving, and for documenting this work.

The system should ensure that:

  • The appropriate records are reviewed and archived/transferred to storage each year in accordance with this policy;
  • Documentation of the archive/transfer of records is completed and retained;
  • Records subject to litigation, investigation and/or a Freedom of Information request are not destroyed. Once the case has concluded, the records may be archived in accordance with this policy;
  • When authorised, destruction of records must be completed securely, either by using an official system tool or by scheduled maintenance with the vendor;
  • Staff will record the date of the destruction of the records, the month, year and means by which they were destroyed and how many records were destroyed.


Retention and Disposition Schedule 
[Insert Office] Retention and Disposition Schedule

Coding for “Record Security” (indicates degree of record security):

High – Protection of data is required by law or University rules and regulations;

Medium – Protection of data is not otherwise protected by statute or regulation, but University has a contractual obligation to protect the data;

Low – Data has no requirement for confidentiality.

Coding for “Years” (indicates retention length):

A = Length of time retained in active records office or online

D = Length of time retained in dormant or semi-active area

FY = Fiscal Year (May 1 to April 30)

AY = Academic Year (September 1 to August 31)

CY = Calendar Year (January 1 to December 1)

Item No./

Classification No.

Record Security

(see above)

Title of Records Series


Office of Primary Interest

(Office responsible for keeping official or legal copy of record)


Active and Semi-Active Retention

(see above)

Total Retention

Year (see above) or Event Trigger + Retention period

Final Disposition

Method of disposition (destroyed, transferred or archived)

1. Medium  Content/Course Files Electronic Individual Faculty Content tool



7 years Secure Destruction
2.  High 

User Activity

  • Discussions
  • Quizzes
  • Grades
  • Dropbox
  • Checklist 
Electronic  Individual Faculty  Each tool listed 



7 years  Secure Destruction
3.  High

User Data (possible)

  • Profile
  • Activity Log
  • Internal Email
  • Locker Files
  • Turnitin Data
  • Enrollment Data
  • User Collections
Electronic Open Learning and Educational Support Each tool listed A7  7 years  Secure Destruction 
4.  High Record of Destruction          Permanent