Document Retention Policy Template
Section 1: Intent and Purpose
Some policies introduce document retention and destruction procedures with a statement of
intent and purpose of the policy. Example purposes include
The organization takes seriously its obligations to preserve information related to
litigation, audits, and investigations.
The purposes of this document retention policy are for organization to enhance
compliance with Sarbanes-Oxley Act and to promote the proper treatment of corporate
records of the Organization.
Section 2: Legal Holds
This section generally gives notice that Board chairs or presidents may issue legal holds. A legal
hold requires suspension from any document destruction due to the reasonable likelihood of
litigation, audits, government investigations, or similar proceedings. Generally, a legal hold
specifies the type of documents that should not be destroyed even if scheduled for destruction.
Section 3: Document List and Retention Time Period
This section outlines in list format:
the category of records and documents to be retained;
specific documents items; and
Some policies also require listing of where document is located or stored.
Categories of records or files and documents commonly retained often include:
Corporate records such as
o foundational documents such as articles of incorporation and bylaws; and
o governance and board policies including corporate resolutions, board agendas and
minutes, and conflict-of-interest disclosure forms.
Finance and administration files including
o financial statements, payroll records, bank deposits and statements, invoices, sales
o equipment files and maintenance records, contracts, general administrative and
legal correspondence, donor records, and grant applications
Insurance records including
o policies and claims made on policies, accident reports, OSHA safety reports and
group disability records
Real property records including
o Real property deeds, leases (current and expired), mortgages and security
Tax documents including
o 501(c)(3) application – Form 1023, IRS Form 990s, charitable organization
registration statements, exemption application
Human resources documents including
o employee personnel files, retirement benefit plans, employee handbooks and
training materials, employment applications
o IRS Form I-9, tax withholding statements, payroll tax returns
o software licenses and support agreements
o press releases and publicly filed documents
The retention period varies by type of document. Some documents, such as foundational
documents should be retained permanently, other documents such as general correspondence
may be retained for a certain number of years.
In determining retention periods, some considerations to keep in mind include federal or state
legal requirement to retain certain documents, statutes of limitation for certain claims that may
be brought against an organization by employees, third parties or the attorney general, and IRS
Section 4: Electronic Documents and Records
This section outlines procedures to retain electronic documents or correspondence. An
organization may require that electronic documents be printed and stored with other physical
files, or allow for electronic documents to be archived electronically with backup and recovery
methods in place to prevent loss.
Section 5: Emergency Planning
This section generally requires that records are stored in a safe, secure, and accessible manner.
Section 6: Document Destruction
This section generally outlines who is responsible for overseeing document destruction process
and mechanism for destruction. Some policies also include an affirmative statement that requires
suspension of any document destruction upon notice of an official investigation.
Section 9: Compliance
This section lays out possible consequences for non-compliance with the policy, including
disciplinary actions, as well as, civil and criminal sanctions. It also may call for periodic review
of the policy with legal counsel and/or a certified public accountant.