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Managing an Identity Crisis: Forum Guide to Implementing New Federal Race and Ethnicity Categories
NFES 2008-802
October 2008

Chapter 5. Getting it Out: Coding, Reporting, Storage, and Bridging

5.4 Data Storage

  • For ED to have access to this information when needed for civil rights enforcement and other program purposes, the Final Guidance requires educational institutions to store the original responses using the two-part question format for 3 years, unless a given collection specifies otherwise.  This is consistent with current regulations (under 34 CFR 74.53 and 80.42) by which ED grantees or subgrantees are required to retain for 3 years all financial and programmatic records, support documents, statistical records, and other record, as specified.  In most cases, this practice is already in place.  This requirement—maintaining auditable records for 3 years—has not changed.
  • One exception to the general 3-year period are cases in which litigation, a claim, an audit, or another action involving the records that has started before the 3-year period ends has occurred.  In these cases, the records must be maintained until the completion of the action.
  • It would be good practice to maintain the original paper record at the location where it was received, typically at the school or district level.  Once data are electronically transmitted to the SEA level, electronic archived records would be maintained.  States should also provide school districts with guidance regarding their state mandates for record retention and disposal procedures. 

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