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Policy Number: 01.010 Policy Title: Record Retention and Destruction Policy Antioch College Continuation Corporation Policy Type: Board Policy Governing Body: Board of Trustees Date of Current Revision or Creation: May 22, 2010 Record Retention and Destruction Policy Antioch College Continuation Corporation The purpose of this Records Retention Policy (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 Antioch College Continuation Corporation (the “Corporation”) or are of no value are discarded at the proper time. This Policy is also for the purpose of aiding employees of the Corporation 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. This Policy represents the Corporation’s policy regarding the retention and disposal of records and the retention and disposal of electronic documents. Attached as Appendix A is a Record Retention Schedule (the “Record Retention Schedule”) that is approved as the initial maintenance, retention and disposal schedule for a physical records of the Corporation and the retention and disposal of electronic documents. The Secretary of the Corporation (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 complies with local, state and federal laws and includes the appropriate document and record categories for the Corporation; monitor local, state and federal laws affecting record retention; annually review the record retention and disposal program; and monitor compliance with this Policy. Exceptions to this Policy are made of the Record Retention Schedule is superseded by state or federal law, or as a result of investigation by a governmental agency or litigation. Member of the Corporation’s Board and its committees are encourage to properly dispose of materials distributed in conjunction with board or committee meetings such as agenda books, reports, handouts, or other materials given the confidential nature of some of this information. The original materials provided for meetings are complied by the Secretary, kept permanently by the Corporation and available to trustees/committee members upon request to the Secretary. This Policy applies to all physical records generated in the course of the Corporation’s operation, including both original documents and reproductions. It also applies to the electronic documents described above.
This Policy was approved by the Board of Trustee of the Corporation on May 23, 2010 Print Name: Pavel Curtis Title: Secretary APPENDIX A RECORD RETENTION SCHEDULE ACCOUNTING RECORDS: Record Type Retention Period Accounts Payable ledgers and schedule 7 years Accounts Receivable ledgers and schedule 7 years Annual Audit Reports and Financial Statements Permanent Annual Audit Records, including work papers 7 years after completion of audit And other documents that relate to the audit Annual Plans and Budgets 2 years Bank Statements and Canceled Checks 7 years Employees Expense Reports 7 years General Ledgers Permanent Interim Financial Statements 7 years Notes Receivable ledgers and schedules 7 years Investment Records 7 years after investment Credit Card Records 2 years
CONTRACTS: Record Types Retention Period Contracts and Related Correspondence 7 years after expiration or (Including any proposal that resulted in termination the contract and all other supportive documentation) CORPORATE RECORDS: Record Types Retention Period Corporate Records (minute books, signed Minutes of the Board and all committees, Permanent Corporate seals, articles of incorporation, Bylaws, annual corporate reports) Informal Notes of Board Meetings Until the formal minutes are approved Licenses and Permits Permanent Documentation of Whistleblower Complaints 6 years following completion of investigation CORRESPONDENCE AND INTERNAL MEMORANDA: General Principle: Most correspondence and internal memoranda should be retained for the same period as the document such correspondence or internal memoranda pertain to or support. For example, a letter pertaining to a particular contract would be retained as long as the contract (7 years after expiration). 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 after two years. Such correspondence or internal memoranda include, but are not limited to, the following: • Routine letters and notes that require no acknowledgment or follow-up, such as notes of appreciation, congratulations, letters of transmittal, and plans for meetings. • Form letters that require no follow-up. • 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 letter of inconsequential subject matter or that definitely close correspondence to which no further reference will be necessary.
Chronological correspondence files should be retained for the present years and two past years. Those pertaining to non-routine matters or having significant lasting consequences should generally be retained permanently. ELECTRONIC DOCUMENTS: 1. Electronic Mail: Emails should either be retained or discarded, depending on the subject matter. In general: • All email (from internal or external sources) is to be deleted after 12 months. • Staff will strive to keep all but an insignificant minority of their email related to business issues. • The Corporation will archive email for six months after the staff has deleted it, after which time the email will be permanently deleted. • All Corporation business-related email should be downloaded to a service center or user directory on the server. • Staff will not store or transfer Corporation-related email on non-work-related computers except as necessary or appropriate for Corporation purposes. • Staff will take care not to send confidential/proprietary Corporation information to outside sources. • Any email staff deems vital to the performance of their job should be copied to a drive folder designated by the Corporation, and printed and stored in the employee’s workspace. 2. Electronic Documents: including Microsoft Office Suite and PDF files. Retention also depends on the subject matter. • PDF document: 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. • Text/formatted files: Staff will conduct annual reviews of all text/formatted files (e.g. Microsoft Word documents) and will deleted 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 that staff deems vital to the performance of their job should be printed and stored in the staff’s workspace 3. Web Pages Files: Internet Cookies • All Workstations: Internet Explorer should be schedule to delete Internet cookies once per month. The Corporation 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 specific in this Policy.
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. GRANT RECORDS: Record Types Retention Period Original grant proposal 7 years after completion of grant completion Grant agreement and subsequent 7 years after completion of grant modifications, if applicable completion All requested IRS/grantee correspondence 7 years after completion of grant including determination letters and “no change” completion in exempt status letters Final grantee reports, both financial and 7 years after completion of grant narrative completion All evidence of the returned grant fund 7 years after completion of grant completion All pertinent formal correspondence including 7 years after completion of grant opinion letters of counsel completion Report assessment forms 7 years after completion of grant completion Documentation related to grantee evidence 7 years after completion of grant of invoices and matching or challenge grant completion that would support grantee compliance with the grant agreement Pre-grant inquiry forms and other 7 years after completion of grant documentation for expenditure completion responsibility grants Grantee work product produced with 7 years after completion of grant The grant funds completion
INSURANCE RECORDS: Record Types Retention Period Annual Loss Summaries 10 years Audits and Adjustments 3 years after final adjustment Certificates Issued to the Corporation Permanent Claims Files (including correspondence, Permanent Medical records, injury documents, etc.) Group Insurance Plans- Active Employees Until Plan is amended or terminated Group Insurance Plans –Retirees Permanent or until 6 years after death of last eligible participants Inspections 3 years Insurance Policies (including expired policies) Permanent Journal Entry Support Data 7 years Loss Runs 10 years Releases and Settlements 25 years LEGAL FILES AND PAPERS: Record Types Retention Period Legal Memoranda and Opinions 7 years after close of matter (including all subject matter files) Litigation Files 1 year after expiration of appeals or time for filing appeals Court Orders Permanent Requests for Departure for Records Retention 10 years Plan
MISCELLANEOUS: Record Type Retention Period Consultant’s Reports 2 years Material of Historical Value (including pictures, publications) Permanent Policy and Procedures Manuals – Original Current version with revision history Policy and Procedures Manuals – Copies Retain current version only Annual Reports Permanent PAYROLL DOCUMENTS: Record Types Retention Period Employee Deduction Authorizations 4 years after termination Payroll Deductions Terminations + 7 years W-2 and W-4 Forms Terminations + 7 years Garnishments, Assignments, Attachments Terminations + 7 years Labor Distribution Cost Records 7 years Payroll Registers (gross and net) 7 years Time Cards/Sheets 2 years Unclaimed Wage Records 6 years PENSION DATA AND SUPPORTING EMPLOYEE DATA: Pension documents and supporting employee data shall be kept in such a manner that the Corporation may establish at all times whether or not any pension is payable to any person and if so the amount of such pension. Record Types Retention Period Retirement and Pension Records Permanent
PERSONNEL RECORDS Record Types Retention Period Commissions/Bonuses/ Incentives/ Awards 7 years EEO-1/EEO-2 – Employer Information 2 years after superseded or filing Report (whichever is longer) Employee Earnings Records Separation + 7 Years Employee Handbooks 1 copy kept permanently Employee Medical Records Separation + 6 years Employee Personnel Records (including individual attendance records, application forms, job or status change records, performance evaluations, termination papers, withholding 6 years after separations information, garnishments, test results, training and qualification records) Employment Contracts- Individual 7 years after separation Employment Record- Correspondence with Employment Agencies and 3 years from date of hiring decision Advertisement for Job Opening Employment Records- All Non-Hired Applicants (including all applications and 2-4 years (4 years if file contains any Resumes – whether solicited or unsolicited, correspondence which might be Results of post-offer, pre-employment constructed as an offer) physicals, result of background investigations, if any, related correspondence) Job Descriptions 3 years after superseded Personnel Count Records 3 years Forms I-9 3 years after hiring, or 1 year after separation of later
PROPERTY RECORDS: Record Types Retention Period Correspondence, Property Deeds, Assessment Permanent Licenses, Rights of Way Original Purchase/Sale/Lease Agreement Permanent Property Insurance Policies Permanent TAX RECORDS: The Corporation 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 Types Retention Period Tax-Exemption Documents and Permanent Related Correspondence IRS Rulings Permanent Excise Tax Records 7 years Payroll Tax Records 7 years Tax Bills, Receipts, Statements 7 years Tax Returns – Income, Franchise, Property Permanent Tax Workpaper Packages – Originals 7 years Sales/ Use Tax Records 7 years Annual Information Returns- Federal and State Permanent IRS or other Government Audit Records Permanent Tax Status Determination Letter Permanent
CONTRIBUTION RECORDS: Record Types Retention Period Records of Contributions Permanent The Corporation’s or other documents Permanent evidencing terms of gifts PROGRAM AND STUDENT RECORDS Record Types Retention Period Student Records Permanent Research & Publications Permanent (1 copy only) FISCAL SPONSOR PROJECT RECORDS: Record Types Retention Period Sponsorship agreement Permanent
