Actually, I am the author of the retention policy in question. Around 2000, I worked as part of a team with General Counsel to develop and approve the schedules for the university. I just checked the mssa site but the retention policies page won't load. My recollection was that student records are retained permanently. Admissions records, for those individuals who become students at Yale, are the start of the student record. Admissions files for individuals who end up not enrolling are retained for a short period, can't remember how long exactly, and are then destroyed. The admissions files are in a separate schedule.

When at Yale, I worked closely with the Law School registrar to take custody of their paper student files, which filled their sub-basement. At the time, they were in the process of changing to an all-electronic recordkeeping system. Their physical files, like those from the other registrars were more of a subject file. They contained everything on the student, and much of which should not have been there in the first place. Due to old filing habits and convenience (of bundling all of a student's documentation into a single folder used not just by the registrar, but other administrators too), the intermingling of mixed content continued after the advent of FERPA.

When I left Yale in 2005, the management of the Records Program remained unstaffed for a while and since has been withering away. At least this is the gist I get when I speak with colleagues from that time. It's quite possible that the GC picked up the slack. During my tenure, the program gained popularity due to its usefulness, but was a bit of a backdoor operation since the Library was not too keen on managing non-research materials. I was accessioning in excess of 2500 cubic feet of non-permanent paper files and we were in the testing phase of managing ESI using LiveLink, which cut into the resources for the research and archival materials (from the Library's perspective). My guess is that the GC took over the records program.

Not sure how well I addressed your red flags, but did the best I could.

Stephen Cohen, CRM
MetLife | Legal Affairs | 212-578-2373
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