How long do I need to keep records related to disclosures and conflict manage plans?
Often the documentation related to a potential conflict disclosure and its management fall into multiple record categories. For example, some of the documents may be “Business and Financial records” governed by the document retention requirements of SPG 604.1. This SPG mandates a 7-year retention period when the particular documents relate to sponsored research, and sets other retention periods for other types of business and financial records. Other documents may fall into the category of “Personnel Records” governed by the document retention requirements of SPG 201.46, although generally this would not be the case. See SPG 201.46 ¶ II.A.2.g. Rather, records related to the disclosure of potential conflicts of interest and conflicts of commitment would in general be considered “Operating Unit records.” See SPG 201.46 ¶ II.E.2. Currently there is not a University-wide standard for retention of Operating Unit records. However, after discussions with Human Resources and the Office of the
