Policy: Record Retention and Destruction
Board Approval
______
I.PURPOSE
The purpose of this Policy is to ensure that necessary records and documents of name of ministryare adequately protected and maintained in compliance with all applicable federal and state laws and regulations.
This policy covers all documents and records regardless of physical form.
As of the effective date of this Policy, emails sent and received by name of ministry personnel as well as electronic documents prepared on a computer are subject to the Policy of the center where the employee’s office is maintained. Name of ministry does not have its own email network, email server or computer network.
II.DOCUMENT RETENTION
Nameof ministry follows the document retention schedule outlined below. Documents that are not listed shall be treated the same as those of similar type.
The documents are not intended to serve as an exhaustive list of every document subject to a particular retention period in a particular area within name of ministry. Instead, the list is meant to serve as a guide that will aide employees as to particular retention periods. Use your judgment and the documents listed as a guide. By way of example, correspondence related to a particular document would be retained for the same period. If after review you are still unsure what retention policy applies, then direct specific questions to the Executive Director.
We have made every effort to draft this policy in such a manner that it can be followed by all employees with minimum disruption and relative ease. To that end, we have limited the applicable retention periods to the following time periods: (1) Permanent; (2) 7 years; and (3) 3 years.
Corporate Records
Articles of Incorporation and BylawsPermanent
Annual Information Reports, Federal and StatePermanent
IRS RulingsPermanent
Tax Exemption Documents and Related CorrespondencePermanent
Board and Board Committee Meeting MinutesPermanent
Board Policies and ResolutionsPermanent
Conflict of Interest Disclosure Statements7 years
Fixed Asset RecordsPermanent
Licenses and PermitsPermanent
Finance and Accounting
Annual Audit Reports and Financial StatementsPermanent
Auditor Management LettersPermanent
Annual audit records, including work papers and 7 years after completion
other documents that relate to the audit of audit
IRS Form 990 Tax ReturnsPermanent
Accounts Receivable, Accounts Payable, Notes Receivable 7 years
ledgers and schedules
Chart of Accounts7 years
Interim Financial Statements7 years
Bank Statements and Canceled Checks7 years
Investment Performance Reports, Investment Consultant7 years
Reports, Investment Manager Correspondence
Employee Expense Reports7 years
Credit Card records3 years
Annual Plans and Budgets3 years
Insurance Records
Policies (including expired policies)Permanent
Certificates issued to name of ministryPermanent
Claims Files (correspondence, records, documentation, etc.)Permanent
Claims, Settlements, and ReleasesPermanent
Accident Reports, Inspection Reports, Safety Reports7 years
Audits and Adjustments3 years
Legal
Court OrdersPermanent
Legal Memoranda and Opinions (including all7 years after close of
subject matter files) matter
Litigation Files3 years after expiration of
appeals or time for
filing of appeals
General
Grant proposals, awards, reports, documentation,7 years after completion
correspondence, invoices, forms, etc. of grant period
Grant applications declined/withdrawn3 years
Software licenses and support agreements7 years after obligations
end
Contracts and Related Correspondence7 years after expiration
or termination
Consultant’s Reports3 years
Correspondence or memoranda pertaining to routine 3 years
matters and having no significant, lasting consequences
Material of Historical Value, including pictures Permanent
and publications
III.COMPLIANCE
This Policy is mandatory and all name of ministry documents must be managed according to this Policy. Failure on the part of employees to follow this policy can result in possible civil and criminal sanctions against name of ministry and its employees and possible disciplinary action against responsible individuals.
The Executive Director will periodically review these procedures with the name of ministry legal counsel or auditing firm to ensure that they are in compliance with new or revised regulations.
IV.DOCUMENT DESTRUCTION
The Executive Director is responsible for annually, during the first quarter of the fiscal year, initiating the process of identifying records which have met the required retention period, and directing their destruction. Destruction of paper documents shall be accomplished by shredding.
Paper documents that are to be destroyed pursuant to this Section IV that contain confidential or sensitive business information or sensitive personal information such as Social Security numbers, drivers license numbers, bank account numbers or credit card numbers, should be shredded (i.e., crosscut shredded), burned or otherwise pulverized in order to make such documents unreadable or undecipherable and then recycled.
V. LITIGATION HOLD
Name of ministry is legally obligated to retain all documents relevant to any pending or reasonably anticipated litigation, investigation or administrative proceeding. All name of ministry documents, wherever located, are potentially subject to a litigation hold. A litigation hold always supersedes any inconsistent document destruction period or other requirement of this Policy. NO STEPS MAY BE TAKEN TO DELETE, ALTER, OR OTHERWISE DESTROY NAME OF MINISTRY DOCUMENTS THAT ARE SUBJECT TO A LITIGATION HOLD EXCEPT UNDER THE EXPRESS DIRECTION OF THE EXECUTIVE DIRECTOR FOLLOWING A DETERMINATION THAT PRESERVATION IS NOT REQUIRED.
It is extremely important that you carefully follow the instructions that accompany notification of a litigation hold requiring the preservation and retention of specified documents, to avoid the possibility of impeding an ongoing investigation, audit or name of ministry defense or prosecution in legal proceedings. The failure to preserve records where required by law may expose name of ministry or responsible individuals to administrative sanctions, civil liability or criminal penalties for obstruction of justice or other crimes.
If you believe that a name of ministry document maybe relevant to pending or potential litigation, claim or administrative proceeding, or if you have any questions about a litigation hold instruction, you should consult the Executive Director.
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