FCF’S Records Management and Retention Policy

I.  POLICY:

1.  It is FCF’s policy to apply effective and cost efficient management techniques to maintain complete, accurate, and high quality records. Records are retained in accordance with all applicable laws and regulations and this policy.

2.  Records that have satisfied their required period of retention will be destroyed in an appropriate manner.

3.  All FCF employees and agents are responsible for ensuring that all records are created, used, maintained, preserved, and destroyed in accordance with this Records Management policy.

4.  Vital and official records will be retained and protected to ensure FCF’s continued operations in the event of a natural or man-made disaster.

5.  Records containing confidential and proprietary information will be securely maintained, controlled and protected to prevent unauthorized access.

6.  All records generated and received by FCF are the property of FCF. No FCF employee, by virtue of his or her position, has any personal or property right to such records even though he or she may have developed or compiled them.

7.  The unauthorized destruction, removal or use of such records is prohibited.

8.  No one may falsify or inappropriately alter information in any record or document.

9.  The Executive Director shall designate an individual to be responsible for implementing and maintaining FCF’s records management program in accordance with this policy.

10. The Operations and Oversight Committee will review and approve all changes and revisions to the record retention schedules.

11. Information pertaining to unauthorized destruction, removal, or use of FCF records or regarding falsifying or inappropriately altering information in a record or document should be reported to the Executive Director and President of the Board of Directors immediately.

II.  DEFINITIONS:

Records: A record is recorded information, regardless of medium or characteristic, which can be retrieved at any time. It includes all original documents, papers, letter: cards, books, maps, photographs, blueprints, sound or video recordings, microfilm, magnetic tape, electronic media, and other information recording media, regardless of physical form or characteristic, that are generated and/or received in connection with transacting its business and is related to FCF’s legal obligations. If not stipulated otherwise, this is the record to which retention schedules apply.

FCF business records include, but are not limited to, letterhead correspondence, legal opinions, real estate documents, directives and policies, official meeting minutes, personnel records, benefit programs, purchasing requisitions and invoices, accounts payable and receivable documents, tax documents, reimbursement documents, completed and signed forms, contracts, insurance documents, general ledgers, audit reports, and financial reports and financial data

Records can only be discarded when the specified retention period has expired and a Certificate of Destruction form is executed.

Non-Records: Non-records material includes duplicate copies of correspondence, duplicate copies of records used for short-term reference purposes, blank forms, stocks of publications, magazines, publications from professional organizations, newspapers, public telephone directories, and transitory messages used primarily for the informal communication of information.  Transitory messages do not set policy, establish guidelines or procedures, certify a transaction, or become a receipt. Transitory messages may include, but are not limited to, e-mail messages with short-lived or no administrative value, voice mail, self-sticking notes, and telephone messages.

Non-records are maintained for as long as administratively needed, and the retention schedules do not apply. Non-records may be discarded when the business use has terminated.

Discretion should be used in determining whether to generate or retain transitory messages in the nature of notes of unofficial meetings, telephone conversations, or other personal notes. If generated, such records should be routinely discarded when they are no longer useful. For example, when the informal record, such as an employee’s personal notes, is transferred to a more formal record, such as, report, the notes are no longer useful and should be discarded.

Preliminary working papers and superseded drafts, particularly after subsequent versions are finalized, should be discarded.  E-mail that contains no substantive data, such as invitations to lunch and responses to such, should be routinely discarded.

Vital Records: Vital records are records that are essential to the continued functioning or reconstitution of FCF or facility during and after an emergency and also preserve the rights of FCF or facility, its employees, clients and other constituent groups.

E-Mail Communications: E-mail communications, messages and documents transmitted by email are similar to paper documents.  They may be considered business records and are subject to this policy.  To determine whether an e-mail message must be retained and for how long, think of it like a paper memo or document.  If you would retain a memo due to its content, then you are required to retain an e-mail message of the same content for the same length of time.

The originator/sender of the e-mail message (or the recipient of a message if the sender is outside FCF) is the person responsible for retaining the message.  E-mail messages may be retained in electronic form in the mailbox, or be printed and filed along with other documents related to the same topic or project.  Users may delete e-mail messages that they are not required by this policy to retain (such as non-record messages and transitory messages) and messages that are being retained in printed form.

III.  RETENTION SCHEDULE:

All records will be maintained and retained in accordance with federal and state laws and regulations and in accordance with this schedule:

1. Documents maintained in perpetuity
   1. Corporate Documents: Articles of Incorporation, Bylaws, Minutes and other records of incorporation.
   2. Financial Documents: Audit reports, Financial Statements (year end): general/private ledgers, trial balance, journals, chart of accounts, checks for important payments and purchases, depreciation schedules.
   3. Legal Documents: deeds, mortgages, bills of sale, contracts (that are still in effect), loan documents and notes; patents, trademark, service marks and copyright registration.
   4. Insurance Documents: Insurance records, current accident reports, claims, policies, etc.
   5. Employee Benefit Documents: Retirement and pension records including Summary Plan Descriptions.
   6. Tax Documents: Tax returns and worksheets, W-2s.

2. Documents maintained for seven years
   1. Financial Documents: Accounts receivable & payable ledgers & schedules; Donations; Internal audit reports; invoices (to customers, from vendors), Purchase orders; Grants (after closure)
   2. Legal Documents: Expired: Contracts, mortgages, notes and leases; Expense Analyses/expense distribution schedules, correspondence on legal matters
   3. Employee Documents: Garnishments; Payroll records & summaries including records related to employee’s leave; Personnel files (terminated employees); Timesheets; Withholding tax statements; I-9s; employment applications

3. Documents maintained for three years
   1. Bank documents: Bank reconciliation, bank statements, deposit records, electronic fund transfer documents, & cancelled checks
   2. General Correspondence

 IV.  RECORDS DESTRUCTION:

1.  Records that have satisfied their legal, fiscal, administrative, and archival requirements may be destroyed in accordance with the Records Retention Schedules.

2. Records that cannot be destroyed include records of matters in litigation or records with a permanent retention. In the event of a lawsuit or government investigation, the applicable records that are not permanent cannot be destroyed until the lawsuit or investigation has been finalized, Once the litigation/investigation has been finalized, the records may be destroyed in accordance with the Records Retention Schedules.

3. FCF records must be destroyed in a manner that ensures the confidentiality of the records and renders the information no longer recognizable as FCF records, The approved methods to destroy FCF records include, but are not limited to, recycling, shredding, burning, pulping, pulverizing, and magnetizing. FCF records cannot be placed in trash receptacles unless the records are rendered no longer recognizable as a FCF record.

V.  Exceptions.

Exceptions to these rules and terms for retention may be granted only by the Organization’s Executive Director or Board President