Record Retention & Destruction Policy

Purpose

The purpose of this Policy is to ensure that necessary records and documents are adequately protected and maintained and to ensure that records that are no longer needed by the Humane Society of Sarasota County (HSSC) or are of no value are discarded at the proper time. This Policy is also for the purpose of aiding employees of HSSC in understanding their obligations in retaining electronic documents—including email, Web files, text files, sound and movie files, PDF documents, and all Microsoft Office or other formatted files. 

Policy

This Policy represents the Humane Society of Sarasota County’s policy regarding the retention and disposal of records and the retention and disposal of electronic documents.

Administration

Attached as Appendix A is a Record Retention Schedule that is approved as the initial maintenance, retention and disposal schedule for physical records of the HSSC and the retention and disposal of electronic documents. The Executive Director (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, state, and federal laws and includes the appropriate document and record categories for HSSC; 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 or Claims

In the event HSSC is served with any subpoena or request for documents or any employee becomes aware of a governmental investigation or audit concerning HSSC or the commencement of any litigation against or concerning HSSC, 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 is 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 HSSC’s operation, including both original documents and reproductions. It also applies to the electronic documents described above. This Policy was approved by the HSSC Board of Directors on July 1, 2014, and revised on November 6, 2018.

APPENDIX A—Record Retention Schedule

The Record Retention Schedule is organized as follows:

1. Accounting & Finance
2. Contracts
3. Corporate Records
4. Correspondence & Internal Memoranda
5. Electronic Documents
6. Grant Records 
7. Insurance Records
8. Legal Files & Papers
9. Miscellaneous
10. Payroll Documents
11. Pension Documents 
12. Personnel Records
13. Property Records
14. Tax Records
15. Contribution Records
16. Programs & Services Records
17. Fiscal Sponsor Project Records

A.  Accounting & Finance

Credit card record retention and destruction:

• A credit card, with the approval of the Executive Director, may be used to pay for products or services that require immediate payment.
• All records showing customer credit card number must be locked in a desk drawer or a file cabinet when not in immediate use by staff.
• If it is determined that information on a document, which contains credit card information, is necessary for retention beyond 2 years, then the credit card number will be cut out of the document.

B.  Contracts

C. Corporate Records

D. Correspondence & 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 (7 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:

1. Those pertaining to routine matters and having no significant, lasting consequences should be discarded within 2 years. Some examples include:

1. Routine letters and notes that require no acknowledgment or follow up, such as notes of appreciation, congratulations, letters of transmittal, and plans for meetings.
2. Form letters that require no follow up.
3. Letters of general inquiry and replies that complete a cycle of correspondence.
4. Letters or complaints requesting specific action that have no further value after changes are made or action taken (such as name or address change).
5. Other letters of inconsequential subject matter or that definitely close correspondence to which no further reference will be necessary
6. 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.

2. Those pertaining to non-routine matters or having significant lasting consequences should generally be retained permanently. 

E.  Electronic Documents

1. Electronic Mail: Not all email needs to be retained, depending on the subject matter.

1. All email—from internal or external sources—is to be deleted after 12 months
2. Staff will strive to keep all but an insignificant minority of their email related to business issues.
3. All HSSC business-related email is housed on an external server off-property.
4. Staff will not store or transfer HSSC related email on non-work-related computers except as necessary or appropriate for HSSC purposes. 
5. Staff will take care not to send confidential/proprietary HSSC information to outside sources. 
6. Any email staff deems vital to the performance of their job should be printed and stored in the employee’s workspace or saved on the server.

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

1. 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 6 years. PDF files the employee deems vital to the performance of his or her job should be printed and stored in the employee’s workspace.
2. 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 five years, all text files will be deleted from the network and the staff’s desktop/laptop. Text/formatted files the staff deems vital to the performance of their job should be printed and stored in the staff’s workspace.

3. Web Page Files: Internet Cookies

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

HSSC 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.

All electronic files on HSSC’s server are backed up on a separate server housed in a separate building on the campus. This backup is a safeguard to retrieve lost information within a one-year retrieval period should documents on the network experience problems. The digital backup copy is considered a safeguard for the record retention system of the HSSC but is not considered an official repository of HSSC records.

In certain cases a document will be maintained in both paper and electronic form. In such cases the official document will be the electronic document.

F.Grant Records

G. Insurance Records

H. Legal Files

I.  Miscellaneous

J.  Payroll Documents

K.  Pension Documents & Supporting Employee Data

General Principle: Pension documents and supporting employee data shall be kept in such a manner that HSSC can establish at all times whether or not any pension is payable to any person and if so the amount of such pension.

L.  Personnel Records

M.  Property Records

N. Tax Records

General Principle: Donors Forum 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.

O.  Contribution Records

P.  Program & Service Records

Q.  Fiscal Sponsor Project Records

APPENDIX B—Record Retention Summary

The following is a guideline for ease of use only. For specifics, and other time frames not specified, please see Appendix A.

Permanent Retention:

• Accident Claims Files
• Annual Audit Reports
• Board Handbook, which includes:
  • Articles of Incorporation
  • Bylaws
• Contribution Records
• Court Orders
• Employee Handbook
• Financial Statements
• General Ledgers
• Gift Terms
• Insurance Certificates
• Insurance Policies
• Materials of Historical Value
• Minutes of Board and Committee Meetings
• Real Property Records
• Retirement and Pension Records
• Sponsorship Agreements
• Tax Exemption Documents and IRS Rulings
• Tax Returns
• Tax Audit Records
• Tax Information Returns—Annual State and Federal

Retention for 7 Years:

• Accounts Payable and Accounts Receivable Ledgers and Schedules
• Adoption Records
• Annual Audit Records (including work papers)
• Bank Statements and Cancelled Checks
• Contracts and Related Correspondence (7 years after expiration or termination)
• Employee Expense Reports
• Grant Records (keep 7 years after completion of grant period)
• Interim Financial Statements
• Investment Records (where investment sold)
• Labor Distribution Cost Records
• Payroll Registers (gross and net)
• Legal Memoranda and Opinions
• Notes Receivable Ledgers and Schedules
• Personnel records for 7 years after separation:
  • Payroll Deductions
  • W-2 and W-4
  • Garnishments, Assignments, and Attachments
  • Earnings Records
  • Medical Records
  • Personnel File
  • Commissions/Bonuses/Incentives/Awards
  • Employment Contracts
• Tax Records:
  • Excise Tax
  • Payroll Tax
  • Tax Bills, Receipts, Statements
  • Tax Work Paper Packages, originals
  • Sales/Use Tax Records