POLICY AND PROCEDURES

RETENTION AND DESTRUCTION OF

CLIENT, HUMAN RESOURCE AND FINANCIAL RECORDS

Policy

It is the policy of Kadima to maintain a retention and destruction program for client, human resource and financial records. It is further the policy of Kadima that no record will be destroyed in the event that a legal process is initiated against the organization in regard to such record. Additionally, with signed releases, Kadima will provide access to requests for client records, human resource records and financial records.

Procedures

  • Active Records of Clients
  • The clinical director maintains direct oversight of the maintenance of active records of clients.
  • Active records of clients are stored in a locked file room with access only by authorized employees.
  • Twice a year, the staff meets to purge case notes, psychotherapy notes, releases and medication count sheets.
  • Purged materials are placed in envelopes that are identified with the client’s name, case number and the dates of the material being purged.
  • Adult Clients - Purged materials aremaintained in a locked file room for ten years and are destroyed (shredded) after a period of ten (10) years.
  • Child/Adolescent Clients – Purged materials are retained in a locked file room fornineteenyears past the age of majority (age 18) and are destroyed (shredded) after a period of nineteen (19) years after the age of majority.
  • A client data base is maintained of active/inactive/closed client names and demographic information.
  • Inactive/Closed Records of Clients
  • The clinical director maintains direct oversight of the maintenance of inactive/closed records of clients.
  • Inactive/closed records of clients are stored in a locked file room with access only by authorized employees.
  • Adult Clients - Inactive/closed records are destroyed (shredded) after a period of ten years.
  • Child/Adolescent Clients – Inactive/closed records are destroyed

(shredded) nineteen(19) years after the age of majority (age 18).

  • The client data base includes names of inactive/closed clients.
  • Human Resource Records
  • A data base for active employees is maintained by the human resource director.
  • Human resource and data base files, for employees no longer working at Kadima, are destroyed after a period of seven(7) years.
  • Unless otherwise specified, it is the responsibility of the human resource director to ensure that specific time frame(s) for procedures regarding the retention and disposition of human resource records are fulfilled.
  • Financial Records
  • Audited financial reports and 990s are retained in a permanent file in a locked cabinet and locked office in the finance department.
  • Routine vendor invoices, bank statements, cancelled checks and receipt books are retained for seven (7) years in a locked storage room and then destroyed (shredded).
  • Original invoices/titles of items owned (including equipment, furniture, appliances, warranty items and investments) are retained, in a locked storage room, for the period of ownership.
  • Process for Record(s) of Clients, Human Resource Records or Financial Recordsin Legal Review
  • In the event a client’s record, an HR record or a financial record is involved in a legal review, the following steps will be taken to ensure the record is not destroyed.
  • The client’s or HR record will be pulled from the active or closed file room.
  • The client, human resource or financial record will be clearly labeled on the outside that it is in current legal review.

-The labeled record of the clientwill be maintained in a locked drawer in the locked office of the clinical director until such time as the legal review is completed.

-The labeled record of the staff will be maintained in a locked drawer in the locked office of the human resource director until such time as the legal review is completed.

-The labeled financial record will be maintained in a locked drawer in the locked office of the executive director’s office until such time as the legal review is completed.

Reviewed 11/2014