DATA RETENTION POLICY

RETENTION OF RECORDS POLICY AND PROCEDURE

PURPOSE

The purpose of this Policy is to ensure that necessary records and documents of [Organisation name] are adequately protected and maintained and to ensure that records that are no longer needed by [Organisation name] or are of no value are discarded at the proper time. This Policy is also for the purpose of aiding employees of [Organisation name]in understanding their obligations in retaining electronic documents - including e-mail, Web files, text files, sound and movie files, PDF documents, and all Microsoft Office or other formatted files.

POLICY

This Policy represents the policy regarding the retention and disposal of records and the retention and disposal of electronic documents.

ADMINISTRATION

This to be read with RECORD RETENTION SCHEDULE that is approved as the initial maintenance, retention and disposal schedule for physical records of [Organisation name]and the retention and disposal schedule of electronic documents.

The Finance Officer (the Administrator) is the officer in charge of the administration of this Policy and the implementation of processes and procedures to ensure that the Record Retention Schedule is followed. The Administrator is also authorized to: make modifications to the Record Retention Schedule from time to time to ensure that it is in compliance with local laws and includes the appropriate document and record categories for [Organisation name], monitor local, state and federal laws affecting record retention annually review the record retention and disposal program and monitor compliance with this Policy.

SUSPENSION OF RECORD DISPOSAL IN EVENT OF LITIGATION

In the event the Organisation is served with any subpoena or request for documents or any employee becomes aware of a governmental investigation or audit concerning [Organisation name] or the commencement of any litigation against or concerning the Foundation, such employee shall inform the Administrator and any further disposal of documents shall be suspended until such time as the Administrator, with the advice of counsel, determines otherwise. The Administrator shall take such steps as are necessary to promptly inform all staff of any suspension in the further disposal of documents.

APPLICABILITY

This Policy applies to all physical records generated in the course of the Organisations operation, including both original documents and reproductions. It also applies to the electronic documents described above.

RECORD RETENTION SCHEDULE

The Record Retention Schedule is organized as follows:

CONTENTS

Accounting and Finance
Contracts and Memorandums of Understanding
Corporate Records
Correspondence and Internal Memoranda
Electronic Documents
Legal Files and Papers
Miscellaneous
Personnel Records
Property Records
Tax Records
Contribution Records

ACCOUNTING AND FINANCE

Record TypeRetention Period
Accounts Payable ledgers and schedules
Accounts Receivable ledgers and schedules
Annual Audit Reports and Financial Statements
Annual Audit Records, including work papers and other documents that relate to the audit
Annual Plans and Budgets
Bank Statements and Cancelled Cheques
Employee Expense Reports
General Ledgers
Interim Financial Statements
Notes Receivable ledgers and schedules
Investment Records
Internal Audit work papers and findings


CONTRACTS

Record TypeRetention Period
Contracts and Related Correspondence (including any proposal that resulted in the contract and all other supportive documentation)


CORPORATE RECORDS

Record TypeRetention Period
Corporate Records (minute books, signed minutes of the Board and all committees, corporate seals, articles of incorporation, bylaws, annual corporate reports)
Licenses and Permits
Memorandums of Understanding


CORRESPONDENCE AND INTERNAL MEMORANDA

General Principle: Most correspondence and internal memoranda should be retained for the same period as the document they pertain to or support. For instance, a letter pertaining to a particular contract would be retained as long as the contract ([??] years after expiration). It is recommended that records that support a particular project be kept with the project and take on the retention time of that particular project file.

Correspondence or memoranda that do not pertain to documents having a prescribed retention period should generally be discarded sooner. These may be divided into two general categories:

Those pertaining to routine matters and having no significant, lasting consequences should be discarded within [??] years. Some examples include:

Routine letters and notes that require no acknowledgment or followup, such as notes of appreciation, congratulations, letters of transmittal, and plans for meetings.
Form letters that require no followup.
Letters of general inquiry and replies that complete a cycle of correspondence.
Letters or complaints requesting specific action that have no further value after changes are made or action taken (such as name or address change).
Other letters of inconsequential subject matter or that definitely close correspondence to which no further reference will be necessary.
Chronological correspondence files.

Please note that copies of interoffice correspondence and documents where a copy will be in the originating department file should be read and destroyed, unless that information provides reference to or direction to other documents and must be kept for project traceability.

Those pertaining to nonroutine matters or having significant lasting consequences should generally be retained permanently.

ELECTRONIC DOCUMENTS

Electronic Mail: Not all email needs to be retained, depending on the subject matter.
Staff will strive to keep all but an insignificant minority of their e-mail related to business issues.

Staff will not store or transfer [Organisation name]related e-mail on non-work-related computers except as necessary or appropriate for company purposes.
Staff will take care not to send confidential/proprietary Foundation information to outside sources.

Any e-mail staff deems vital to the performance of their job should be copied to the staffs thumb drive.

Electronic Documents: including Microsoft Office Suite and PDF files. Retention also depends on the subject matter.

PDF documents The length of time that a PDF file should be retained should be based upon the content of the file and the category under the various sections of this policy. The maximum period that a PDF file should be retained is [??] years. PDF files the employee deems vital to the performance of his or her job should be printed and stored in the employees workspace.

Text/formatted files - Staff will conduct annual reviews of all text/formatted files (e.g., Microsoft Word documents) and will delete all those they consider unnecessary or outdated. After [??] years, all text files will be deleted from the network and the staffs desktop/laptop. Text/formatted files the staff deems vital to the performance of their job should be printed and stored in the staffs workspace.
Web Page Files: Internet Cookies

All workstations: Internet Explorer should be scheduled to delete Internet cookies once per month.

[Organisation name]does not automatically delete electronic files beyond the dates specified in this Policy. It is the responsibility of all staff to adhere to the guidelines specified in this policy.

LEGAL FILES AND PAPERS

Record TypeRetention Period
Legal Memoranda and Opinions (including all subject matter files)
Litigation Files
Court Orders
Requests for Departure from Records Retention Plan


MISCELLANEOUS

Record TypeRetention Period
Consultant's Reports
Material of Historical Value (including pictures, publications)
Policy and Procedures Manuals Original
Policy and Procedures Manuals Copies
Annual Reports


PERSONNEL RECORDS

Record TypeRetention Period
Employee Personnel Records (including individual attendance records, application forms, job or status change records, performance evaluations, termination papers, withholding information, garnishments, test results, training and qualification records)


Employment Contracts Individual




PROPERTY RECORDS

Record Type Retention Period


Correspondence, Property Deeds, Assessments, Licenses, Rights of Way


Original Purchase/Sale/Lease Agreement


Property Insurance Policies


TAX RECORDS

General Principle: must keep books of account or records as are sufficient to establish amount of gross income, deductions, credits, or other matters required to be shown in any such return.

These documents and records shall be kept for as long as the contents thereof may become material in the administration of federal, state, and local income, franchise, and property tax laws.

Record TypeRetention Period
Tax-Exemption Documents and Related Correspondence
Tax Rulings
Excise Tax Records
Tax Bills, Receipts, Statements
Tax Returns Income, Franchise, Property
Tax Workpaper Packages Originals
Sales/Use Tax Records
Annual Information Returns - Federal and State
Tax or other Government Audit Records


CONTRIBUTION RECORDS

Record TypeRetention Period
Records of Contributions