Records Retention and Destruction Policy
mothers2mothers (m2m) and its branches has adopted this Records Management and Retention policy (hereinafter the “Policy”) to achieve approach to managing m2m records, from creation through active use, storage/retention and disposal. This Policy applies to all m2m operations across the globe and applies to all records, in both hard and electronic forms, as defined below.
The purpose of this Policy is as follows:
- To ensure efficient and effective operation of the business;
- To comply with regulatory record keeping requirements;
- To preserve the confidentiality of m2m information;
- To maintain a manageable volume of well-organized records;
- To mitigate the risk of the mistaken use of outdated records; and
- To minimize storage & other costs associated with the retention of unnecessary
Consistent with these objectives is m2m’s policy that records be retained for as long as (but only so long as) necessary to satisfy legal requirements, financial and audit requirements, and legitimate business purposes. All employees of m2m are charged with the personal responsibility of complying with this Policy.
2. Definitions & Terms
- The term “record” limitation includes documents and without electronically stored information (including writings, drawings, graphs, charts, photographs, sound recordings images and other data or data compilations) created for one or more purposes related to m2m’s business. For examples and without limitation records may also include books, ledgers, file, memoranda, letters, reposts, worksheets, slides, other presentation material, calendars appointment books, telephone logs and miscellaneous reports whether in hard copy of electronic format and computerized data and programs, computer hardcopy printouts, computer related magnetic materials (e.g. Word processing and personal computer diskettes, and magnetic tapes and cassettes) microfilm and micro-fish, telecommunicated material such as facsimiles, and other electronically stored information such as email.
- A records retention period is the length of time for which a record must be retained pursuant to applicable law or in accordance with the records retention schedule.
- The records retention schedule (Appendix A below)is the schedule that sets forth the length of time that categories of records must be maintained. The records retention schedule lists record types regularly kept by m2m and describes their applicable retention periods. Revisions to the records retention schedule will occur as necessary to reflect changes in regulations or business requirements.
- A records hold is any period of time during which pertinent records may not be disposed of even if they are no longer needed for legitimate business purposes or if the applicable records retention period has expired. The circumstances giving rise to a record hold are set forth in section 3.3 below.
3.1 Maintaining & Disposal of Records
- Unless subject to a records hold (see section 3 below) staff should maintain records in accordance with m2m’s records retention schedule set forth herein at Appendix A, and if not listed in the records retention schedule only as long as needed for legitimate business purposes.
- Records created or received during the course of the organization’s business are m2m property and regardless of their location do not belong to the individual employee who created, received or maintained m2m departments retain custodial responsibility and administrative authority over records.
- All m2m organizational records should be maintained on m2m property or in an m2m approved off-site storage.
- Records that do not need to be retained under the records retention schedule or for legitimate business purposes may still need to be retained for litigation, government investigation, or similar m2m will implement a records hold for any such records (see section 3.3 below).
- Unless subject to a records hold, a record should be disposed of at the end of its retention period.
- Email should not be used for official record keeping purposes. Email messages will however, be preserved and saved in every user’s mailbox and back-up databases per m2m policy.
- Email records will be preserved indefinitely for regulatory, legal, fiscal, or business purposes and will be saved in electronic storage media approved by the IT department, or printed out and preserved as paper records. If you are required to retain emails pursuant to a records hold, the IT department will advise you as to the appropriate storage media and process.
3.3 Suspension of Records Retention Periods – Records Hold
Events occasionally will require a suspension of applicable records retention periods. In any of the following circumstances, a records hold will be in effect and you may not dispose of applicable records until further notice.
a. The circumstances calling for a records hold include the following:
- The terms and conditions of a specific grant requires longer retention periods than set out in this policy.
- Specific country statutory legislation requires longer retention periods than the ones in Appendix A.
- You have been advised by m2m that records have been sought, or will imminently be sought, in appending litigation or government proceeding.
- You have been advised by the organization that the company expects records will be sought in a pending or anticipated litigation or government proceeding.
- You are personally aware that records have been or likely will be sought in a pending or anticipated litigation or government proceeding.
b. As to the circumstances described in section 3.2 above, you may receive a directive from the President & Chief Executive Officer, Finance Director or other company official that certain records are subject to a records hold. The directive will describe the types of records subject to the records hold. You must follow this type of directive carefully.
c. As to the circumstances described in 3.3.a above, you may personally become aware of circumstances giving rise to a pending or anticipated litigation or government proceeding even before others in m2m have informed you of a records hold. In those circumstances a records hold is in effect and you should suspend disposal of pertinent records. You must also promptly inform the Chief Operations Officer and your supervisor of the basis for the records hold and seek guidance as to further action with respect to such records.
d. In no event should you ever alter, destroy, or conceal any records with the intent to impede, obstruct or influence any litigation or government proceeding, or in relation to or contemplation of any such litigation or government proceeding.
e. Unauthorized destruction or disposal of m2m records may subject an employee to disciplinary action, including termination.
- As needed to facilitate effective compliance m2m may assign responsibility for administering this Policy to a Records Manager, who will supervise the implementation of the Policy, maintain the records retention schedule, manage active records, and transfer non-active records to off-site storage locations.
- You should address questions regarding this Policy and your obligations under the Policy to your supervisor, your records manager, or the IT department.
5. Management of Off-Site Records
- Records that are no longer in use on a regular basis, but that must still be maintained for the remainder of their respective records retention periods, may be sent offsite. The Records Manager will arrange for records to be archived at an offsite storage facility on a regular basis.
- The Records Manager is responsible for sending records to and from offsite storage, indexing all records, maintained in offsite facilities, and overseeing the disposal of off-site records for which the records retention period has expired.
6. Training & Review
- Employees will receive guidance in the records management policy as necessary, including instruction and advice on the creation, retention, and disposal of records.
- This Policy and the records retention schedule will be reviewed periodically and amended as necessary to reflect any changes in laws, regulations, or business requirements.
Appendix A – Records Retention Schedule
Finance Records and Retention Period (Years)
Auditor’s Reports: 7
Bank Debt Deduction: 5
Bank Deposit Slips, Reconciliations, Statements: 5
Bills of Lading: 5
Checks – cancelled: 5
Contracts – purchase & sale: 5
Credit Memos: 5
Depreciation Records: 5
Employee Expense Report: 5
Employee Payroll Records: 6
Financial Statements: 15
Freight Bills: 5
Internal Reports: 5
Inventory/Asset Lists: 5
Invoices (Sales & Purchases): 5
General Ledger: 15
Journals and Retention Period (Years)
General, cash receipts, disbursements: 15
Payroll records: 5
Time cards & time reports: 5
Organizational Records and Retention Period (Years)
Articles of Incorporation: Permanent
Bylaws & BOD Resolutions: Permanent
Capital stock & bond records: Permanent
Contracts & Agreements: Permanent
Copyright & trademark registration: Permanent
Legal correspondence: Permanent
Mortgages & Notes: Permanent
Insurance Records and Retention Period (Years)
Accident reports: 6
Fire inspection reports: 6
Group disability records: 6
Insurance policies: 6
Safety records: 6
Settled insurance claims: 5
Tax Records and Retention Period (Years)
Tax returns: 7
Sales & Use tax returns: Permanent
Payroll returns: 5
Employment Records/Personnel and Retention Period (Years)
Personnel files: 6
Miscellaneous Records and Retention Period (Years)
Marketing/Sales Documents/Press Releases: 4
Property Records: Permanent
Electronic Mail: Permanent
m2m Donor Cooperative Agmt Records: Permanent
All other documents: 7
* Please refer to section 3.3 for guidance on exceptions to these timeframes.
Full policy approved and reviewed by Frank Beadle de Palomo, President & CEO, 10 June 2016