Should we keep W-2’s longer than 4 years?

By Angela Ossar, Government Information Analyst

W-2 formI received a call recently from a school district with a question that seemed refreshingly simple on its face:  their payroll department wanted to begin keeping W-2’s longer than the 4-year retention period prescribed by TSLAC (and the Code of Federal Regulations). Which forms should they submit to amend their schedule?

The RMO explained that they’d received Public Information Act requests from former teachers for W-2’s going back to 1996. These teachers were seeking certain benefits from a state agency, and the state agency was requiring copies of the teachers’ W-2’s. When the school district explained to the former teachers that the W-2’s had been destroyed after 4 years in accordance with their approved retention schedule, the former teachers complained.  So, because the information was now electronic, the school district felt that it was easier to simply retain W-2’s indefinitely than to risk angering any more former employees.

Of course, it’s acceptable for the school district to retain the W-2’s longer than required — but should they?

The records analyst in me didn’t like the idea of retaining confidential information longer than necessary because of the risk of security breaches and cost of server storage. The librarian in me couldn’t leave the RMO with just a link to some forms.  “Are you sure it’s necessary for you to keep these longer?” I asked. “Couldn’t the former employee get that information from the IRS?”  I offered to look into the question for the RMO, and began making calls.

As it turns out, the Internal Revenue Service’s toll-free help line was remarkably quick, and it took no more than a minute for them to respond to my question.  The IRS retains copies of W-2 information submitted to them for 10 years.  After explaining the school district’s conundrum, they responded, “You should talk to the Social Security Administration. They get copies of all the W-2’s from us. Maybe they keep them even longer.”

So, I took his advice and gave the Social Security Administration a call. They called me back within a half hour, and their answer was: “We keep that information back to 1978. Actually, we keep it way farther back than that; the individual would just have to submit a form requesting us to do the research for records prior to 1978.”

It should also be noted that all state and local government agencies are required to retain former employee verification records for 75 years after the employee’s termination — in large part to enable former employees to collect benefits.  Those records (the Employee Service Record for local governments, GR1050-12, Former Employee Verification Records for state agencies, RRS 3.3.011) must include the former employee’s social security number, positions held with dates of hire, promotion, transfer, or demotion, and wage or salary rate for each position held.

So, my recommendation to the school was to verify that the Employee Service Record did indeed contain the required information, and, if so, to continue to destroy W-2’s in accordance with its approved records retention schedule. Although the teachers did need access to their former W-2’s to qualify for benefits, there was no need for the school district to provide a service that other agencies already provide.

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