Document retention and destruction policy

Document retention and destruction policy of [ORGANIZATION NAME]

Adopted by the Board of Directors on [DATE].

1. Purpose

This policy sets out how [ORGANIZATION NAME] (the "Organization") keeps, stores and destroys its records, so that it keeps what the law and good practice require, protects private information, and gets rid of records it no longer needs in a safe way.

2. Who this policy covers

This policy covers all directors, officers, employees, volunteers and contractors who create or handle the Organization's records, in paper or electronic form, including email, shared drives and online accounts.

3. Who is responsible

1. The Secretary, [NAME], is responsible for governance records.
2. The Treasurer, [NAME], is responsible for financial and tax records.
3. [NAME OR ROLE] is responsible for program, volunteer and personnel records.
4. These people make sure records are stored safely, that the schedule below is followed, and that destruction is recorded.

4. Where records are kept

1. Electronic records are kept in [NAME OF SHARED DRIVE OR SYSTEM], in an account owned by the Organization, not by any one person.
2. Paper records are kept at [LOCATION], in a locked place where they contain private information.
3. Records that must be kept permanently are kept in at least two places, such as the shared drive and a backup.

5. Retention schedule

Keep permanently:

• articles of incorporation, bylaws and all amendments
• minutes of board and committee meetings, and written consents
• the IRS determination letter and the full exemption application (Form 1023 or 1023-EZ) with everything sent to the IRS
• state charity registrations and certificates
• adopted policies, with the dates they were adopted and changed
• annual financial statements and audit or review reports
• Forms 990, 990-EZ and 990-N confirmations
• property deeds, and records of major assets for as long as the Organization owns them and for at least [NUMBER] years after
• records of restricted and endowment gifts, for as long as the restriction lasts and then at least [NUMBER] years after
• insurance policies (suggested, because claims can arise years later)

Keep for [NUMBER, AT LEAST 7] years after the end of the fiscal year they relate to (suggested):

• bank statements, reconciliations and canceled checks
• general ledger and accounting records
• invoices, receipts and expense reimbursements
• donation records and copies of donor acknowledgment letters
• grant applications, agreements and reports, counted from the end of the grant
• contracts and leases, counted from the date they end

Keep for at least 4 years after the tax is due or paid, whichever is later (IRS minimum), or longer if your state requires:

• payroll records, timesheets and employment tax returns
• Forms W-2, W-4, 1099-NEC and related records

Keep for [NUMBER] years after the person leaves (check your state's rules):

• employee files
• volunteer applications, agreements and background check results

Keep as advised by your insurer or lawyer (often much longer):

• incident and accident reports
• safeguarding concerns and how they were handled
• records connected to any legal claim

Keep until no longer useful, then destroy:

• routine email and correspondence that doesn't fall into a category above
• drafts and working copies, once the final version is saved

6. Email and electronic records

Email and electronic files are records just like paper. File important email (such as a board decision or a donor's gift instructions) into the right folder in the shared drive. Don't keep the Organization's only copy of a record in a personal account.

7. Destruction

1. When a record reaches the end of its retention period, the person responsible may destroy it.
2. Paper records with personal or financial information are shredded. Electronic records are deleted, including from any recycle bin, and devices are wiped before they are thrown away or given away.
3. The person responsible keeps a short log of what was destroyed, when and by whom.

8. Legal hold: stop destroying

1. If the Organization learns of a lawsuit, a government investigation, an audit or a claim, or has reason to expect one, all destruction of related records stops at once. This includes email and electronic files.
2. The Chair will tell everyone affected, in writing, which records to keep.
3. Destruction may start again only when the Chair, after advice from a lawyer if needed, says in writing that the matter is over.
4. Destroying, changing or hiding records to obstruct an investigation is against the law and this policy.

9. Public inspection

The Organization will make its exemption application and its annual returns available for public inspection as the law requires.

10. Breaking this policy

Anyone who breaks this policy may face discipline, up to and including removal from their role.

11. Review

The Board will review this policy and the retention schedule at least every [NUMBER] years.