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1610 PR.02 Disposal of Obsolete Computers and Peripherals
March 1, 2018
The University owns computers and peripherals that no longer have value to the University. It is appropriate to dispose of them by donation, sale, or recycling, within the limits of this procedure.
The University recognizes the importance of preserving the privacy of users and data stored in IT systems. Users must honor this principle by neither seeking to obtain unauthorized access to IT Systems, nor permitting or assisting any others in doing the same. The University must also protect the Copyright and Licensing agreements with software providers.
The University must protect its investments in computers and peripherals and abide by regulations imposed by granting or contracting agencies with regard to equipment. The University must also comply with state sales tax laws and Internal Revenue Service rules for documenting and reporting all forms of compensation.
Under Connecticut Regulations Section 22a-449(c)-113 Standards for Universal Waste Management, used or broken electronics such as desktop, laptop computers, and computer peripherals are now considered Universal Waste and are banned from normal trash dumpsters. These items are now required to be collected and sent to a licensed disposal facility. Please contact Yale Environmental Health and Safety (“EHS”) at 203-785-3551 for pertinent information. While this designation does not impose any restrictions while computers and peripherals are in use, it does prescribe special handling of recycled computers and peripherals.
University information must be destroyed or rendered unrecoverable prior to re-purposing any computer, electronic device or media.
Fair Market Value (“FMV”)
The price that would be agreed on between a willing buyer and a willing seller, neither being under any compulsion to buy or sell and both having reasonable knowledge of the relevant facts.
The State of CT has classified certain electronics as Universal Waste. These electronics are defined as electronic equipment that can store or transmit data and/or is used for entertainment purposes. This includes all computers and peripherals. This category, somewhere between normal municipal solid waste and hazardous waste, allows fairly normal handling of the material but requires special end-of-life disposal appropriate to the material. Please contact EHS for further classifications.
Data Removal prior to disposal
Prior to redeployment, donation, or selling of any computer or peripheral, the data must be removed in accordance with Policy 1609 Media Control and related Procedure 1609 PR.01 Disposal of Media Containing Confidential or Protected Health Information. Desktop Support Providers can help clients navigate the data removal process. For computers that will be recycled, Yale’s recycling supplier has contracted to use industry standard methods to dispose of electronic media devices for the University and provide certificates of destruction at the end of the destruction process.
CD/DVD and floppy disk media may be placed in shredding bins. More information about this service is available through the Walk-in Computer Support Centers.
Please see Section 8 Specific Procedures, below, for instructions on how to make use of each of the following disposal options:
Re-deploy: Computers that are not capable of performing complex tasks may still be capable of performing simpler tasks and thus may be used either within their own or another Yale department. Such computers must be re-deployed within the University.
Donate: Obsolete computers and peripherals that are still operational (but no longer of use to the University) may be donated to non-profit organizations, when donating the equipment furthers one or more of the University’s exempt purposes (education, research and community service). The donee must be an exempt organization for federal income tax purposes under Internal Revenue Code Section 501(c)(3).
Sell: Obsolete computers and peripherals that are still operational (but no longer of use to the University) may be sold at fair market value to individuals, non-profit organizations or for-profit entities. This option is subject to strict rules governing the determination of fair market value, adherence to tax laws and regulations and documentation of the transaction. If computers are to be sold, they must be priced at fair market value only. If the computers were purchased with funds from a grant or a contract, they may not be sold from one department to the other within the University. Please refer to the Policy 4209 Equipment, Section 4209.3 on Transfer, Release or Sale of Equipment.
Recycle: Computers and peripherals may be of such age or condition that they cannot be used for their intended purposes. These computers and peripherals should be recycled. All electronic materials to be recycled should be referred to the Office of Environmental Health and Safety. To request a pickup of obsolete equipment, complete a Universal Waste/Used Electronics request via the EHS website. Call the Yale Environmental Affairs Waste Request Line at 203-432-6545 for further information.
If making a universal waste request for electronic devices with electronic protected health information (“ePHI”) or other sensitive data, electronic devices with ePHI or other sensitive data must remain in a secured location while awaiting pickup. A secured location is defined as one that utilizes adequate means (e.g., locked doors) to limit physical access to only authorized individuals. Devices may not be placed outside offices in hallways while awaiting pickup.
All computers and peripherals are donated or sold “as is” and with no warranties expressed or implied. Any recipient of the equipment must sign an acknowledgement of this condition.
The sale of equipment is subject to Connecticut sales tax if it is:
- Shipped to a Connecticut address; or
- Picked up by the purchaser from a location in Connecticut, such as the University campus.
If the transaction is subject to Connecticut sales tax, the tax rate must be applied to the total sales price of the equipment including any shipping charges. (Note: The University is not required to collect sales tax if the purchaser is a tax-exempt organization and it provides the University with a properly completed Form CERT-119, Certificate for Purchases of Tangible Personal Property and Services by Qualifying Exempt Organizations.) Contact the Tax Office for a CERT-119 certificate.
Contact the University’s General Accounting Office to obtain information on the University’s procedures for recording taxable sales, reporting, and remitting sales tax to the state.
If the chosen method is re-deploy, or sell at fair market value, or recycle, there are no income tax consequences for the University or the recipient.
If the chosen method is to donate, there are no income tax consequences for the recipient. The University may be able to deduct the fair market value of the donated equipment on its income tax return.
The Lead Administrator of the unit that owns the computer or peripheral (henceforth to be called the “equipment”) determines when it is not suitable for its originally intended purpose. Desktop Support Providers (“DSPs”) may be requested to assist in this determination.
In all cases, the re-deployment, recycling, donation or sale of equipment must be approved in writing by the administrator of the department that owns the equipment.
C. Local redeployment
If the equipment is identified as obsolete but is still operational, the preferred option is to redeploy it for another use within the unit. After meeting the requirements of Step D, no further actions are needed with this option, and the remainder of this procedure may be ignored. This is the preferred method for the University.
D. Data removal
Note: Correct removal of files from equipment is an absolutely irreversible process. Proceed with care.
If the data on the electronic media device is not available from another location, please ensure that the University allows you to destroy this data by reviewing the Yale Records Retention Schedule maintained by the Office of General Counsel.
For equipment containing highly confidential information, disposal is managed by Yale data disposal suppliers. The supplier has contracted to use industry standard methods to dispose of electronic media devices for the University and provide certificates of destruction at the end of the destruction process. Please complete the Universal Waste/Used Electronics request.
When the equipment will not be recycled, the Lead Administrator is responsible for ensuring that all files have been removed from the equipment. Desktop Support Providers can assist clients in navigating the data removal process when no sensitive data is involved.
In addition to hard drives, other electronic media (DVD, CD, diskette, zip drive etc.,) must be physically destroyed to be rendered unreadable. For instructions on proper disposal of electronic media, call the Help Desk at 203-432-9000 or visit one of the Walk-in Computer Support Centers.
E. Software License Accounting
Software that has been licensed under University contracts must be removed from equipment that is being donated or sold outside of the University. If the machine is to be re-deployed within the University such software must be deleted if the licensed software is to be installed on the system replacing the one being re-deployed.
F. Removal from inventory
The Lead Administrator is responsible for removing the equipment from departmental inventory lists and the Moveable Equipment Inventory (“MEI”) list as appropriate. If the cost is under MEI Capitalization amount (currently $5,000), the equipment will not be in MEI.
G. Redeployment to another unit
Departments can redeploy equipment to other departments but must keep all appropriate documentation listed in the Record section of this document.
Equipment may be donated only to non-profit organizations. The donee must be an exempt organization for federal income tax purposes under Internal Revenue Code Section 501(c)(3) and must acknowledge the gift in writing. No licensed software may be supplied with the equipment other than an Operating System as supplied at initial purchase.
Equipment may be sold at fair market value to individuals, non-profit organizations or for-profit entities. This option is subject to strict rules governing the determination of fair market value, adherence to tax laws and regulations and documentation of the transaction. If computers are to be sold, they must be priced at Fair Market Value (“FMV”) only. The Lead Administrator is responsible for determining the FMV of the equipment using the Desktop Support Provider who researches price(s) of comparable equipment.
J. Scrap & Salvage
If the equipment is not operational or unsuitable for any use, it should be scrapped. Parts and peripherals may be salvaged. The remainder of the equipment should be, picked up by the Office of Environmental Health and Safety for recycling. Under no circumstances is it acceptable to dispose of scrap equipment by introducing it into regular trash streams such as tossing it into the trash or dumpster. This includes hard drives removed from towers and physically destroyed. The State of CT requires special end-of-life disposal appropriate to the material.
The department that re-deploys, recycles, donates, or sells computers or peripherals must maintain the following records:
- Written approval from the Lead Administrator.
- If the computers or peripherals are re-deployed in another department, they must be removed from the inventory list of the department that donated it and transferred to the department that received it. The departments should retain a copy of this transaction on file.
- For equipment that is sold, a copy of the cash receipts, documentation supporting the determination of the fair market value of the equipment along with the equipment’s disposal records.
- If the computers or peripherals that are listed in the inventory are recycled, they must be removed from the list, and the department should retain a copy of this transaction on file.
For donated equipment, a written acknowledgement from the 501(c)(3) organization.
Note: If a department donates equipment and the fair market value of all equipment donated by the department during the fiscal year is $10,000 or greater, a copy of the gift acknowledgement(s), along with a copy of the documentation for determining the fair market value of the equipment, must be forwarded to the University Tax Office.
Lead Administrator chooses the most appropriate disposal option amongst the various options listed in this policy. The administrator must assess the Fair Market Value of the equipment and also bear responsibility for the removal of electronic data on equipment before disposal.
Information Technology Services
Desktop Support Providers (“DSPs”) can assist with the assessment of equipment obsolescence and identification of the Fair Market Value of the equipment. DSPs can also direct clients to data erasure services prior to recycling obsolete equipment.
Yale Environmental Health and Safety
EHS is available for disposing and recycling obsolete, broken, or other unusable computers and equipment in compliance with the CT State Law. To request a pickup of obsolete equipment, complete a Universal Waste/Used Electronics request via the EHS website. Call the Yale Environmental Affairs Waste Request Line at 203-432-6545 for further information.