Document Retention and Destruction Policy
Document Retention and Destruction Policy
Purpose
This policy sets out how DanceSafe, Inc. manages the retention, storage and destruction of its documents and records. It applies to all staff, volunteers, board members and third parties (for example, contractors, etc.) who create or handle the Organization’s records.
Policy Statement
- Paper or electronic documents specified in the retention schedule below must be transferred to the Organization’s designated records custodian (see “Policy Oversight” below) for storage.
- Other paper documents not specified in the schedule may be destroyed after three (3) years.
- Other electronic documents not specified in the schedule may be deleted from individual computers, databases, networks and backup storage after one (1) year of completion.
- No document—paper or electronic—may be destroyed or deleted if it is relevant to or reasonably anticipated to be relevant to:
- A government investigation or inquiry,
- A pending or reasonably anticipated lawsuit or legal proceeding, or
- A formal external audit or review
- .
If in doubt, the matter must be cleared with legal counsel and the Policy Oversight Officer.
- .
- Where government auditing standards or funder agreements require specific retention, those requirements override the schedule below.
Scope
This policy applies to records in all formats: paper, electronic files, email and attachments, messages in collaboration tools, and records stored on organization-owned or personal devices used for Organization business.
Policy Oversight
The Board of Directors designates [title e.g. Executive Director or Board Treasurer] as the Policy Oversight Officer. That person is responsible for implementing this policy, ensuring document transfer and retention, scheduling destruction events, maintaining records of destruction, and consulting with legal counsel if necessary.
Retention Schedule – Minimum Requirements
The following table identifies by category the minimum retention period. If a longer period is required by law, contract, regulation or funder, the longer period governs.
| Type of Document | Minimum Retention Period | Notes / Comments |
| Articles of Incorporation, Bylaws, Amendments | Permanent | Foundational legal documents |
| IRS 501(c)(3) Determination Letter | Permanent | Proof of tax-exempt status |
| Board meeting minutes & committee meeting minutes | Permanent | Governance record |
| Audit reports (independent audits) | Permanent | Historical audit trail |
| Federal & state tax returns (e.g. Form 990 series and CA 199) | Permanent | Audit/tracking requirement |
| Contracts/leases still in effect | Life of agreement | Active obligations |
| Contracts/leases expired | 7 years after expiration | Typical statute of limitations |
| Accounts payable/receivable ledgers and schedules | 7 years | Financial transaction record |
| Bank statements, reconciliations, cancelled checks | 7 years | Financial support documentation |
| Personnel files (Separations / terminated employees) | 7 years after termination | Employment claim risk |
| Payroll records (wages, tax filings) | 7 years | Employment/tax history |
| Volunteer applications & training records | 3 years after last service date | Due diligence for volunteer engagement |
| Event contracts & permits | 7 years after event date | Program liability & history |
| Donor contribution records & acknowledgments | 10 years after last donation | Supports donor history & audits |
| Grant agreements & final reports | 7 years after grant closeout | Funder audit trail |
| Routine correspondence (general) | 2 years | Non-legal, non-financial items |
| Important correspondence (legal, governance) | Permanent | Institutional history |
Storage and Security
- Physical records must be stored in locked cabinets or a secure off-site archive facility with appropriate fire, water and access protection.
- Electronic records must be stored on approved cloud or server platforms, with encryption, access controls and backups. Records should not remain only on personal computers or volunteer-owned devices.
- Email, messages and collaboration tool messages that relate to organization business must be managed as records under this policy.
Destruction Procedures
- Destruction of records must occur only after the applicable retention period has expired and no litigation hold or relevant audit/funder requirement applies.
- For physical records: use shredding or certified destruction services. A certificate or log of destruction must be retained.
- For electronic records: remove from active systems, archives and backups so the information cannot be reasonably reconstructed. Document the method used and keep the log of destruction.
- Automatic deletion protocols (if any) must align with this policy, and must be suspended if a litigation hold is in place.
Litigation Hold
If legal counsel, the Executive Director or Policy Oversight Officer determines that records may be subject to an investigation, audit or legal proceeding, a written litigation hold will be issued. This hold supersedes the expiration dates in the schedule and mandates preservation of all relevant records until release is provided in writing.
Review and Training
- All staff, volunteers and board members will receive notice of this policy at onboarding.
- The policy will be reviewed at least every three (3) years or sooner if legal / regulatory changes occur.
- Training or refresher sessions will be provided when needed.
Compliance and Amendments
- This policy is internal guidance and not legal advice. Where law, contract or funder requirement differs, the stricter requirement governs.
- Any amendments must be approved by the Board of Directors.
