Document Retention and Destruction Policy
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 International Medical Relief. This policy covers all records and documents, regardless of physical form (including electronic documents), contains guidelines for how long certain documents should be kept and how records should be destroyed. 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 International Medical Relief’s operations by promoting efficiency and freeing up valuable storage space.
Failure on the part of employees or contract staff to follow this policy can result in possible civil and criminal sanctions against International Medical Relief, its employees, and/or contract staff and possible disciplinary action against responsible individuals.
- Document Retention. Documents shall be maintained for no less than the periods of time set forth below. Documents that are not listed, but are substantially similar to those listed below, will be retained for the commensurate length of time:
Corporate Records
Annual Reports to Secretary of State- Permanent
Articles of Incorporation – Permanent
Board Meeting/Board Committee Minutes – Permanent
Board Policies/Resolutions – Permanent
By-laws – Permanent
Construction/Asset Records
Construction Documents – Permanent
Fixed Asset Records – Life of Fixed Asset
Accounting and Corporate Tax Records
IRS Application for Tax-Exempt Status (Form 1023) – Permanent
IRS Determination Letter- Permanent
State Sales Tax Exemption Letter – Permanent
Annual audits and year-end financial statements – Permanent
Depreciation schedules – Permanent
IRS Form 990 tax – Permanent
General ledgers – 7 years
Business expense records – 7 years
IRS Form 1099 – 7 years
Journal entries – 7 years
Invoices – 7 years
Sales records (books) – 5 years
Petty cash vouchers – 3 years
Cash receipts – 3 years
Credit card receipts – 3 years
Bank Records
Check registers – 7 years
Bank deposit slips – 7 years
Bank statements and reconciliations – 7 years
Electronic fund transfer documents – 7 years
Payroll and Employment Tax Records
State unemployment tax records – Permanent
Payroll records – Permanent
Garnishment records – 7 years
Payroll tax returns – 7 years
W-2 statements – 7 years
Employment tax records – At least 4 years after filing of the year’s 4th qtr. (or longer, if req’d by state law)
Human Resource records
Employment and termination agreements – Permanent
Retirement and pension plan documents – Permanent
Promotion, demotion or discharge records – 7 years after termination
Accident reports/workers’ compensation records – 5 years
Background checks, drug test results, driving records and employment verifications – 5 years
Resumes, employment applications, etc. (non-hires) – 3 years
Timesheets, compensation history and job history – 4 years after termination
Performance appraisals and disciplinary records – 4 years after termination
I-9 forms – 3 years after hire date or 1 year after termination
Donor and grant records
Donor records and acknowledgment letters – 7 years
Grant applications and contracts – 7 years after expiration
General
Contracts – 7 years after expiration
Correspondence (general) – 3 years
Legal, insurance and safety records
Appraisals – Permanent
Copyright and trademark registrations – Permanent
Environmental studies – Permanent
Insurance policies – Permanent
Real estate documents – Permanent
Stock and bond records – Permanent
Leases – 7 years after expiration
OSHA documents – 5 years
- Electronic Documents and Records. Electronic documents may be permanently deleted on the timetable set forth above. During the relevant retention period, all electronic documents shall be backed up on a regular basis. If a user has sufficient reason to keep an email message, the message should be printed in hard copy, and kept in the appropriate file or moved to an “archive” computer file folder.
- Storage. International Medical Relief’s records will be stored in a safe, secure, and accessible manner.
- Emergency. Documents and financial files that are essential to keeping International Medical Relief operating in an emergency will be duplicated or backed up at least every week and maintained off site.
- Document Destruction. International Medical Relief’s Executive Director shall be responsible for the ongoing process of identifying its records, which have met the required retention period and overseeing their destruction or designating someone who shall be responsible for such process. Destruction of financial and personnel-related documents will be accomplished by shredding. 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.
- Review of Procedures. International Medical Relief shall review this Policy and these procedures with International Medical Relief’s certified public accountant to ensure that it is in compliance with new or revised regulations.
