Record Retention and Document Destruction Policies

I. PURPOSE

In accordance with the Sarbanes-Oxley Act, which makes it a crime to alter, cover up, falsify, or destroy any document with the intent of impeding or obstructing any official proceeding, this policy provides for the systematic review, retention, and destruction of documents received or created by Achieve Now in connection with the transaction of organization business.

This policy covers all records and documents, regardless of physical form, contains guidelines for how long certain documents should be kept, and how records should be destroyed (unless under a legal hold). The policy is designed to ensure compliance with federal and state laws and regulations, to eliminate accidental or innocent destruction of records, and to facilitate Achieve Now’s operations by promoting efficiency and freeing up valuable storage space.

II. DOCUMENT RETENTION

Achieve Now follows the document retention procedures outlined below. Documents that are not listed, but are substantially similar to those listed in the schedule, will be retained for the appropriate length of time.

Corporate Records
Bylaws and Articles of Incorporation - Permanent
Board Meeting and Board Committee Minutes - Permanent
Board Policies/Resolutions - Permanent
Fixed Asset Records - Permanent
IRS Application for Tax-Exempt Status (Form 1023) - Permanent
IRS Determination Letter - Permanent
State Sales Tax Exemption Letter - Permanent
Conflict-of-interest Disclosure Forms - Permanent
Contracts (after expiration) - 7 years

Correspondence
IRS Correspondence - Permanent
Correspondence re: Corporate Records - 7 years
General Correspondence - 1 year

Accounting and Corporate Tax Records
Annual Audits and Financial Statements - Permanent
Depreciation Schedules - Permanent
General Ledgers - Permanent
IRS Form 990 Tax Returns - 7 years
Business Expense Records - 7 years
IRS Forms 1099 - 7 years
Journal Entries - 7 years
Invoices - 7 years
Cash Receipts - 7 years
Credit Card Receipts - 7 years
Sales Records (box office, concessions, gift shop) - 5 years
Petty Cash Vouchers - 3 years

Bank Records
Check Registers - 7 years
Bank Deposit Slips - 7 years
Bank Statements and Reconciliation - 7 years
Electronic Fund Transfer Documents - 7 years

Payroll and Employment Tax Records
State Unemployment Tax Records - Permanent
Payroll Registers - 7 years
Earnings Records - 7 years
Garnishment Records - 7 years
Payroll Tax Returns - 7 years
W-2 Statements - 7 years

Employee Records
Employment and Termination Agreements - Permanent
Retirement and Pension Plan Documents - Permanent
Records Relating to Promotion, Demotion, or Discharge - 7 yrs. (after termination)
Accident Reports and Worker’s Compensation Records - 7 years
Salary Schedules - 5 years
Employment Applications - 7 yrs. (after emp. action)
I-9 Forms - 3 yrs. (after termination)
Time Cards - 3 years

Donor and Grant Records
Donor Records and Acknowledgment Letters - 7 years
Grant Applications and Contracts - 7 years (after completion)

Legal, Insurance, and Safety Records
Appraisals - Permanent
Insurance Policies - Permanent
Real Estate Documents - Permanent
Trademark Registrations - Permanent
Leases - 7 years (after expiration)
General Contracts - 7 yrs. (after termination)
OSHA Documents - 6 years

Communications
Press Releases - Permanent
Annual Reports - Permanent
Other publications - 7 years
Photos - 7 years
Press Clippings - 7 years

Electronic Documents and Records

Electronic documents will be retained as if they were paper documents. Therefore, any electronic files, including records of donations made online, that fall into one of the document types on the above schedule will be maintained for the designated amount of time.

If a user has sufficient reason to keep an e-mail message, the message should be printed in hard copy and kept in the appropriate file or moved to an “archive” computer file folder. Backup and recovery methods will be tested on a regular basis.

Emergency Planning

Achieve Now’s records will be stored in a safe, secure, and accessible manner. Documents and financial files that are essential to keeping the organization operating in an emergency will be duplicated or backed up at least every week and maintained off-site.

III. DOCUMENT DESTRUCTION

Achieve Now’s Executive Director is responsible for the ongoing process of identifying the records that have met the required retention period and overseeing their destruction. Destruction of financial and personnel-related documents will be accomplished by shredding to the extent that the document is completely illegible.

Document destruction will be suspended immediately upon any indication of an official investigation or when a lawsuit is filed or appears imminent. Destruction will be reinstated upon conclusion of the investigation.

IV. COMPLIANCE

The organization expects all employees to comply fully with any published records retention or destruction policies and schedules, provided that all note the following general exception to any stated destruction schedule:

If you believe, or the organization informs you, that organization records are relevant to litigation, or potential litigation (i.e., a dispute that could result in litigation), then you must preserve those records until it is determined the records are no longer needed.

This exception supersedes any previously or subsequently established destruction schedule for those records. If you believe that exception may apply, or have any question regarding the possible applicability of that exception, please contact the Executive Director, who will immediately seek legal counsel.

Failure to comply with this Document Retention Policy may result in punitive action against the employee, including suspension or termination. Questions about this policy should be referred to the Executive Director, who is in charge of, and responsible for, administering, enforcing, and updating this policy.