Confirmation Reconfirmation About us What’s new? Resources

Tab 16: Written Record Retention Policy (Electronic and Paper Documents)

The community foundation submits a written policy that includes retention guidelines for covered documents, guidelines that indicate when it is permissible or mandatory to destroy applicable documents, and the procedures for ceasing destruction of documents.

For more information, review Core materials, FAQs and a glossary of important terms

Related Standards

IV. Stewardship and Accountability
IV.A A community foundation is a steward of charitable funds, investing and prudently managing funds and maintaining accurate financial records.

View all National Standards

Key Element

Written policy that includes:

retention guidelines provided for covered documents

guidelines that indicate when it is permissible or mandatory to destroy applicable documents

the procedure for ceasing any destruction of documents in the case of any actual or potential official investigations

Core Materials
FAQs
Glossary

Required Document

Record-retention policy

Why do the National Standards include a record-retention policy?

The Sarbanes-Oxley Act primarily affects only publicly traded companies, but the provisions related to document destruction apply to all organizations, including nonprofits making it illegal to destroy documents to prevent their use in official proceedings.

Document destruction and retention: The Sarbanes-Oxley Act increases criminal penalties for obstruction of justice caused by the destruction of documents that are anticipated to be the subject of a federal investigation.

Many foundations find it beneficial to have policies that describe which files and documents they must keep permanently or for extended periods of time and which can be disposed of on a regular basis. (See, Jane C. Nober, "Keep, File, Toss?," Foundation News & Commentary, March/April 1998.) As with all policies, they should be appropriate to the specific needs of the foundation.

Records retention policy
A policy that governs the storing of documents for a set period of time usually in accordance with a policy which takes into account requirements under state and federal law.

Sarbanes-Oxley Act
The Sarbanes-Oxley Act of 2002 (often shortened to SOX) is legislation that was designed to rebuild public trust in the corporate community in the wake of the Enron scandal and other corporate and accounting scandals. Sarbanes-Oxley requires publicly traded companies to adhere to governance standards that expand board member roles in overseeing financial transactions and auditing procedures. Nonprofit organizations are required to comply with two Sarbanes-Oxley provisions: whistle-blower protection and document destruction. However, incorporating other internal controls and policies included in the act may lead to greater accountability and transparency by nonprofits to their boards of directors, their donors, and the general public.

Reconfirming?

Review all key elements and consider if your organization has made changes to your policies, powers or practices.

Pay special attention to key elements and core materials marked with and a . These represent minimum requirements for reconfirmation as well as Pension Protection Act requirements. Items marked with a are particularly critical for those who submitted record books prior to January 2007.