Paper Records Retention Policy

Policy Owner: Quality & Compliance and Information Technology  

Policy Contact: Catherine Harding 

POLICY STATEMENT

Paper Dental Records

1. The school will maintain a patient’s dental records for at least seven years beyond the time they were last treated. In the case of a patient who was a minor when treated at the school, the school will maintain the patient's dental records for at least seven years past the age of majority which is 18 (MN Statute 3100.9600, subpart 12).
2. Paper records, including charts, radiographs, photographs, and other paper documents, will be maintained in a manner that is HIPAA compliant.  Access to the storage space will be controlled, and access will require completion of HIPAA and data-privacy training modules.
3. Members of the school’s clinical and research communities will have access to the records through a records request made to the Health Information Management Team.  Records are checked out with a signature and returned to the Health Information Management office after use.  
4. Requests to maintain paper records for longer than 7 years after the last dental appointment at the school (or 7 years past the age of majority for pediatric patients) must be made in writing to the Health Information Management office.  The request should include the requested duration of the record retention, and the record will be flagged to indicate the extended retention period.  Requests to extend retention further must be made in a timely manner.
5. Paper records will be discarded in a HIPAA-compliant manner when they no longer need to be retained or no longer contain research value.  Paper records in storage will be reviewed annually by cross-referencing the patient with the axiUm database.  If the patient is at least 25 years old and has not been treated in the school for at least 7 years and the record has not been flagged for extended retention, the record will be discarded in a secure paper shredder.
6. Per Minnesota Statute 325L.12 records retained as electronic records and paper records that have been scanned into the electronic EHR satisfy record retention laws.
   • Per Minnesota Administrative Rule 3100.9600 subp. 2 the same recordkeeping requirements apply to electronic records as apply to paper records.
   • When electronic records are kept, dentists must use unalterable electronic records.
   • Paper records are discarded in a HIPAA-compliant manner, as outlined in this policy, after being scanned into the chart.
7. Any records or information that are part of pending or current litigation may not be destroyed without consent from the Office of General Counsel.

Paper Academic Records

1. The School of Dentistry will maintain all academic records in a manner in accordance with the University of Minnesota Retention of University Records policy.
2. Records will be maintained, at a minimum, for the duration of time defined in the University of Minnesota Records Retention Schedule.

REASON FOR POLICY

Paper records must be retained in a manner that adheres to Minnesota record keeping statutes, maintains adequate HIPAA- and FERPA-compliant privacy controls, serves the members of our community who need access to the records, and is environmentally sustainable considering space limitations.

PROCEDURES

Record Retention Policy | Procedures

RESPONSIBILITIES

Department/Unit Responsibilities

1. The Health Information Management office in the Dental School IT department will maintain dental record request forms, records of chart check-outs and check-ins, and records of requests for chart retention extensions.
2. The Academic Affairs Office will oversee the maintenance of all academic records and records requests through Degrees & Programs.
3. The Compliance Office in the Division of Clinical Affairs will review this policy annually and amend it when necessary.
4. Annual and biennial reviews and purging of paper records in storage will be overseen by the Compliance Office and will be completed by a team of trained individuals.

FORMS/INSTRUCTIONS 

There are no forms associated with this policy.

APPENDICES

There are no appendices associated with this guideline.

FREQUENTLY ASKED QUESTIONS

There is no FAQ associated with this policy.

DEFINITIONS

There are no definitions associated with this policy. 

RELATED INFORMATION

There is no related information associated with this policy.

HISTORY

• Approving Body: Council Affairs Committee
• Date Approved: April 21, 2021
• Date Amended: February 18, 2026

ADDITIONAL CONTACTS