Document Retention and Destruction Policy
I. Purpose
In accordance with the Sarbanes-Oxley Act, which makes it a crime to alter, cover up, falsify, or destroy any document with the intent of impeding or obstructing any official proceeding. This policy provides for the systematic review, retention and destruction of documents received or created by the Society in connection with the transaction of organization business. This policy covers all records and documents as outlined below, regardless of physical form (including electronic documents), contains guidelines for how long certain documents should be kept and how records should be destroyed. The policy is designed to ensure compliance with federal and state laws and regulations, to eliminate accidental or innocent destruction of records and to facilitate the Society’s operations by promoting efficiency and freeing up valuable storage space. This policy also ensures that documents are promptly provided to authorities in the course of legal investigations or lawsuits.
II. Document Retention
The following types of documents will be retained for the following periods of time. At least one copy of each document will be retained according to the following schedule. Documents that are not listed, but are substantially similar to those listed in the schedule will be retained for the appropriate length of time.
III. Document Retention Schedule
Corporate Records
Articles of IncorporationPermanent
IRS Form 1023 filing for tax-exempt statusPermanent
Letter of Determination from the IRS granting tax-exempt statusPermanent
By LawsPermanent
Board policiesPermanent
ResolutionsPermanent
Board meeting minutesPermanent
Sales tax exemption documentsPermanent
Tax or employee identification number designationPermanent
Annual corporate filingsPermanent
Financial Records
Chart of AccountsPermanent
Fiscal Policies and ProceduresPermanent
AuditsPermanent
Financial statementsPermanent
General LedgerPermanent
Calculation of Release for Operations of investment incomePermanent
Check registers/books7 years
Business expenses documents7 years
Bank deposit slips, with detail7 years
Cancelled checks7 years
Invoices7 years
Investment records (deposits, earnings, withdrawals)7 years
Property/asset inventories7 years
Petty cash receipts/documents3 years
Credit card receipts3 years
Tax Records
Annual tax filing for the organization (IRS Form 990)Permanent
Payroll registersPermanent
Filings of fees paid to professionals (IRS Form 1099)7 years
Payroll tax withholdings7 years
Earnings records7 years
Payroll tax returns7 years
W-2 statements7 years
Personnel Records
Confirmation of employment lettersPermanent
Pension recordsPermanent
Employee applications and resumes7 yrs frm term.
Promotions, demotions, letter of reprimand, termination7 yrs frm term
Job descriptions, performance goals7 yrs frm term
Employee offer letters7 yrs frm term
Salary ranges per job description7 yrs frm term
I-9 Forms7 yrs frm term
Time reports7 yrs frm term
Workers’ Compensation records5 years
Insurance Records
Property Insurance policy3 yrs frm term
Directors and Officers Insurance policyPermanent
Workers’ Compensation Insurance policyPermanent
General Liability Insurance policyPermanent
Insurance claims applicationsPermanent
Insurance disbursements / denialsPermanent
Contracts
Employee contracts7 yrs frm term
Construction contractsPermanent
Legal correspondencePermanent
Loan / mortgage contractsPermanent
Leases / deedsPermanent
Vendor contracts7 years
Warranties7 years
Management Plans and Procedures
Staffing, programs, marketing, finance, fundraising and evaluation plans7 years
Vendor contacts7 years
Disaster Recovery Plan7 years
IV. Electronic Documents and Records
Electronic documents will be retained as if they were paper documents. Therefore, any electronic files, including records of donations made online, that fall into one of the document types on the above schedule will be maintained for the appropriate amount of time. If a user has sufficient reason to keep an email message, the message should be printed in hard copy and kept in the appropriate file or moved to an “archive” computer file folder. Backup and recovery methods will be tested on a regular basis.
V. Emergency Planning
The Organization’s records will be stored in a safe, secure and accessible manner. Documents and financial files that are essential to keeping the Organization operating in an emergency will be duplicated or backed up at least every week and maintained off site.
VI. Document Protection
Documents (hardcopy, online or other media) will be stored in a protected environment for the duration of the Document Retention Schedule. Computer backup media will be included.
VII. Document Destruction
Hardcopy of documents will be destroyed by shredding after they have been retained until the end of the Document Retention Schedule. Online copies will be destroyed by proven means to destroy such media after they have been retained until the end of the Document Retention Schedule.
Document destruction will be suspended immediately, upon any indication of an official investigation or when a lawsuit is filed or appears imminent. Destruction will be reinstated upon conclusion of the investigation.
VIII. Provision of Documentation for Investigations or Litigation
Documents requested and subpoenaed by legally authorized personnel will be provided within 5 business days. The President (CEO) will authorize provision. No documents will be concealed, altered or destroyed with the intent to obstruct the investigation or litigation.
IX. Compliance
Failure on the part of employees or contract staff to follow this policy can result in possible civil and criminal sanctions against the Society and its employees or contract staff and possible disciplinary action against responsible individuals. The Vice President of Administrationwill periodically review these procedures with legal counsel or the organization’s certified public accountant to ensure that they are in compliance with new or revised regulations.
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