A Document Retention and Destruction Policy identifies the record maintenance responsibilities of staff, board members, and volunteers to ensure legal compliance and transparency. Adopting such a policy is a key governance practice highlighted by the IRS on Form 990.
Clan Campbell Society (North America) Document Retention & Destruction Policy
Article I: Purpose
The purpose of this policy is to ensure that [Organization Name] maintains its records in accordance with federal and state laws, ensures their availability during audits or litigation, and establishes a systematic process for the destruction of outdated materials.
Article II: Administration
The [Executive Director/Board Treasurer] is responsible for overseeing the administration of this policy and ensuring that records are stored in a safe, secure, and accessible manner.
Article III: Document Retention Schedule
The following retention periods are based on standard IRS and legal guidelines:
| Record Category | Retention Period |
|---|---|
| Corporate Records (Articles of Incorporation, Bylaws, IRS Determination Letter, Board Minutes) | Permanent |
| Tax Records (IRS Form 990, Tax Returns) | Permanent (Minimum 7 years recommended) |
| Financial Records (Audited Statements, General Ledgers, Check Registers) | 7 Years |
| Bank Records (Statements, Reconciliations, Deposit Slips) | 7 Years |
| Donor & Grant Records (Grant Agreements, Gift Acknowledgments) | 7 Years (after end of grant period) |
| Personnel Records (Employment Tax Records, Pension Details) | 7 Years (after termination) |
| Legal/Contract Records (Contracts, Leases, Licenses) | 3 Years (after expiration) |
| Correspondence (General emails, memos) | 2 Years |
Article IV: Electronic Records & Backup
Electronic records will be maintained as if they were paper documents. All essential financial and legal files shall be duplicated or backed up weekly and stored off-site or in a secure cloud-based environment.
Article V: Document Destruction
Once the retention period has expired, documents should be destroyed in a way that preserves confidentiality (e.g., shredding for paper, permanent deletion for digital files).
Article VI: Litigation Hold (CRITICAL)
If the organization is notified of an ongoing or anticipated government investigation, audit, or private litigation, all relevant document destruction must cease immediately. No records shall be destroyed or concealed until the matter is legally resolved and written approval is granted by legal counsel.