Google Account Retention Policy

Policy Number: 06.0001

Introduction

The Google Account Retention Policy (the "Policy") outlines the duration for which The New School will retain accounts and files associated with New School Google accounts. This Policy is subject to change or revision due to the changes that occur in technology, regulation, system terms of service, and changes in The New School’s operational procedures and strategies.

Purpose

Google Workspace and its associated services (Gmail, Drive, etc.) is an official and primary productivity and collaboration platform for The New School. Retention of data in Google Workspace is based on university roles, status (active or separated), and the type of content within the account. Individuals with a New School Google account are responsible for identifying and saving documents that must be retained to comply with federal, state, or local laws, or other legal obligations or requirements per The New School’s Retention of University Records Policy.

Scope

This policy applies to all university employees, students, alumni, emeritus faculty, and retired employees.

Definitions

Account Retention: The New School stores and maintains Google accounts and/or data and files for a specific period of time, either for operational or regulatory purposes.

New School Employees: Includes Full-Time and Part-Time Faculty, Full-Time and Part-Time Staff, and Student Employees.

Responsibilities

Human Resources: Maintenance of New School Employee statuses.

Information Technology: Policy administration.

Managers: Account extension requests.

Office of the General Counsel: Requests and management of litigation holds.

Registrar's Office: Maintenance of student statuses.

Policy

The New School retains Google account data and associated files for a period of 365 days following separation from the university, after which time they will be permanently deleted (see Google Account Access Guidelines for detailed account parameters).

Google account data and associated files may be subject to the Retention of University Records Policy based on the content and owner(s) of the record. Each office and each employee at The New School has the legal responsibility to demonstrate the proper care and management of their records, including retention of the applicable record for the period outlined in the Record Retention Tables.

Action must be taken to prevent the premature deletion of user accounts that contain data or files that must be retained for a longer period of time. Managers may request an extension of retention by completing the Compliance Extension Request form for terminated employee accounts for a specified period to meet identified compliance needs that are beyond the standard 365 day retention period. The request must be approved by a University Executive Leader, University Dean, Departmental Vice President, or an official designated delegate selected by one of these leaders.

Accounts with litigation holds will be retained for the length of the hold.

The Office of the General Counsel reserves the right to amend or modify the retention periods set forth in this Policy as appropriate and in the best interest of the university.

Policy Administration

Responsible University Official: Chief Information Officer

Responsible Office: Information Technology

Contact Information: itcentral@newschool.edu

Policy History

Effective Date: May 8, 2024

Last Reviewed Date: May 17, 2024

Next Review Date: May 8, 2029

Revision History: N/A