Operational
POLICY
It is the policy of Bethany Christian Services (Bethany) and its subsidiaries that all organization documents are to be retained and stored safely for specific amounts of time based on regulatory, accreditation and general business practice standards to ensure access to essential materials, maintain historical data, and protect client and business information.
All case records, including those closed and being retained, are confidential and must be protected in accordance with the agency Release and Access of Information Policy & Procedure and as permitted by federal and state law.
PROCEDURE
CLIENT RECORDS
Retain Permanently
- Adoption (Placement)
- Pregnancy Counseling (Relinquished)
Retain for 7 Years AfterClosing Date
- Adoption Home Studies (Independent)
- Family Counseling
- Family Group Decision-Making
- Family Preservation
- Foster Care
- Foster Homes
- In-Home Services
- Independent Living
- Pregnancy Counseling (Non-relinquished)
- Refugee
- Residential
- Volunteer
Client File Retention
File retention guidelines are as follows (unless the state requires longer retention standards):
- Telecommuters will not maintain any type of closed files.
- Closed files are to be stored safely and securely by the appropriate branch.
- After records have been retained for therequired number of years, they must be destroyed in a secure/confidential manner. (The Destruction of Confidential Info P&P).
Please note: Client files from Bethany’s Embryo Adoption program that were not transferred to the National Fertility Support Center in 2012 must be maintained as follows:
Permanently
- Embryo Adoption
- Embryo Donor Counseling (Released/Donated)
Retain for 7 Years after Case Closure
- Embryo Donor Counseling (Non-Release/Donated)
BUSINESS DOCUMENTS
Retain Permanently
- Articles of Incorporation
- Appointment Calendars of Executives
- Bylaws
- Legal Correspondence
- Meeting Minutes
- Contracts and Agreements
- Copyrights
- Trademarks
- Real Estate Deeds
- Marketing Materials
- Organizational Charts
Retain for 7 Years
- Accident Reports
- Fire Inspection Reports
- Insurance Policies – timeframe begins at the time of termination
- Inventory Records
- Safety Records
- Real Estate Contracts and Mortgages
Retain for 4 Years
- Settled Insurance Claims – timeframe begins at the time of termination
Retain for 3 Years
- Administrative Correspondence
Retain for 1 Year
- General Correspondence
- Unfunded Grants
FINANCIAL RECORDS
Retain Permanently
- Capital Stock and Bond Records
- Annual Financial Statements
- General Ledger
- General, Cash Receipts, Cash Disbursement, Purchase Journals
- Plan and Trust Agreement for Retirement Fund
- IRS Approval Letter
- Auditors’ Reports
- Donor Records
- Tax Returns and Worksheets
Retain for 7 Years
- Accounts Receivable and Payable
- Bank Deposit Slips, Reconciliations, Statements
- Contracts
- Donations
- Grants – Funded
- Invoices
Retain for 6 Years
- Employee Payroll Records (W-2, W-4, annual earnings, etc.) – timeframe begins at time of termination
- Time Cards and Daily Time Reports
Retain for 4 Years
- Cancelled Checks
- Credit Memos
- Depreciation Records
- Employee Expense Reports
- Interim Financial Statements
- Freight Bills
- Internal Reports
- Inventory Lists
- Invoices – Sales
- Invoices – Purchases of Permanent Assets – timeframe begins at time of termination
- Payroll Journal
- Petty Cash Vouchers
- Subsidiary Ledgers (accounts receivable, accounts payable)
Retain for 2 Years
- Budgets
HUMAN RESOURCE DOCUMENTS
Bethany’s Human Resource Department maintains personnel files for all employees in accordance with applicable laws and regulations. Files are electronically maintained in UltiPro as well as hard copy as needed. Questions regarding the retention of Human Resource documents should be directed to the Senior Director of Human Resources.
STORAGE OF RECORDS FOR CLOSED BETHANY OFFICES PROTOCOL
Upon the dissolution of a Bethany office, the client records, which are property of Bethany Christian Services, will be transferred to and stored for safekeeping at the designated branch office responsible for continuation of services for consumer informationor licensed child placing agency responsible for continuation of services as approved by state licensing requirements. If no such office is designated, the files shall be stored at Bethany Christian Services' National Office at 901 Eastern Avenue, NE, Grand Rapids, Michigan. The closed office information and the location of the records will be noted in the Branch database.
ADDITIONAL NOTES:
Retention timeframes may be adjusted per contractual agreement or state law.
Hard copy or paper records do not need to be maintained if the information is electronically stored (scanned papers, saved on the server) and there is a back-up system for the electronic storage.
Withdrawn adoption applications that occur without a placement would follow the same guidelines noted above, with retention occurring for 7 years.
On-Site Storage
- Hard copy records
- Must be kept in locked file cabinets or containers, or in cabinets or containers within a locked room or vault.
- Access to closed records is on a “professional need to know” basis.
- Electronic records
- Must be maintained on a secure drive with a file back-up.
- Access to closed records is on a “professional need to know” basis.
Off-Site Storage
Off-site storage areas for closed records will be:
- Physically secure.
- Area will protect the records from unauthorized access or theft by being locked and maintained with limited access or through a gatekeeper system.
- Environmentally controlled.
- Area will protect the records from damage or loss from temperature fluctuations, fire, water damage, pests, and other hazards.
- Accessible at all times.
- Area will be kept organized so that records are easily accessible.
References
COA RPM 6
From:
Collaborative Electronic Records Project. (2008). Records retention and disposition guidelines. Retrieved from
U.S. House of Representatives. (2002). HR 3763 – Sarbanes-Oxley Act of 2002.
*Due to the volume of laws, regulations, and standards, specific citations are not provided. Laws, regulations, and standards that apply to this policy include, but are not limited to:
Internal Revenue Service Regulations and Guidelines
Health Information Portability and Accountability Act
Fair Labor Standards and National Labor Relations Act
Occupational Safety and Health Administration
Civil Rights Act
Accounting and Business Standards of Practice
Department of Health and Human Services
Updated from Case Record Access & Storage Policy and Procedure, includes Record Storage for Closed Office Procedure
APPROVED: 7/13/2011 by PQI Committee; Senior Executive Team
Revised/Approved: 7/9/2015 by the PQI committee
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