Highland Area Community Foundation Record Retention and Destruction Policy

These policies cover all records regardless of physical form or characteristics which have been made or received by The Highland Area Community Foundation (hereinafter “HACF”) in the course of doing business.

I. Purpose of policies

These policies provide for the systematic review, retention and destruction of records received or created by HACF in connection with the transaction of business. These policies cover all records, regardless of physical form, contain guidelines for how long certain records should be kept and how records should be destroyed. These policies are designed to ensure compliance with federal and state laws and regulations, to eliminate accidental or innocent destruction of records and to facilitate HACF’s operations by promoting efficiency and freeing up valuable storage space. Included in the federal laws necessitating compliance with these policies is the Sarbanes-Oxley Act ("The American Competitiveness and Corporate Accountability Act of 2002"), which makes it a crime to alter, cover up, falsify, or destroy any document with the intent of impeding or obstructing any official proceeding.

II. Records covered 

These policies apply to all records in any form, including electronic documents. A record is any material that contains information about HACF’s plans, results, policies, or performance. Anything that can be represented with words or numbers is a business record for the purposes of these policies. Electronic documents must be retained as if they were paper documents. Therefore, any electronic files, including information received online, that fall into one of the document types on the schedule must be maintained for the appropriate amount of time. [For example, if a user has sufficient reason to keep an email message, the message should be printed in hard copy and kept in the appropriate file or moved to an “archive” computer file folder.] [Backup and recovery methods will be tested on a regular basis.]

III. Record Retention 

HACF follows the document retention procedures outlined below. Documents that are not listed, but are substantially similar to those listed in the schedule will be retained for the appropriate length of time.



A. Permanent Retention 

Permanent records—Permanent records are records required by law to be permanently retained and which are ineligible for destruction at any time for any reason. These records are necessary for the continuity of business and the protection of the rights and interests of the organization and of individuals. These include records such as organizational documents (Articles of Incorporation and Bylaws), Board minutes and policies, federal and state tax exempt status and independent audits.

No record, whether or not referenced, may be destroyed if in any way the records refer to, concern, arise out of or in any other way are involved in pending or threatened litigation. 

While the listings below contain commonly recognized categories of records, the list should not be considered as having identified all records that HACF may need to consider for permanent and non-permanent status. In particular, and as noted above, any documents that are, or may be involved in pending or threatened litigation, must be retained. The nonprofit’s legal counsel has been asked to assist in determining what records must be retained.

Corporate Records – Permanent

  Annual Reports to Secretary of State/Attorney General

 Articles of Incorporation Board Meeting and Board Committee Minutes

 Board Policies/Resolutions

 By-laws

 Fixed Asset Records

 IRS Application for Tax-Exempt Status (Form 1023)

 IRS Determination Letter

 State Sales Tax Exemption Letter 

Accounting and Corporate Tax Records – Permanent

  Annual Audits and Financial Statements

  Depreciation Schedules

  General Ledgers

  IRS 990 Tax Returns

 Bank records – Permanent

 Check Registers

Payroll and Employment Tax Records – Permanent

Payroll Registers 

State Unemployment Tax Records

Employee Records – Permanent

  Employment and Termination Agreements B. Nonpermanent retention

 Retirement and Pension Plan Documents

 Legal, Insurance and Safety Records – Permanent

 Insurance Policies

Stock and Bond Records

Trademark Registrations

B. Non-permanent retention

 Non-permanent records—Certain records are not required by law to be permanently retained and may be destroyed after the passage of certain years or upon the passing of events as defined by these policies.

Notwithstanding the listing of documents below, no record, whether or not referenced may be destroyed if in any way the records refer to, concern, arise out of or in any other way are involved in pending or threatened litigation.

Corporate Records

Contracts (after expiration) 7 years 

Correspondence (general) 3 years

Accounting and Corporate Tax Records 

Business Expense Records 7 years

IRS 1099s 7 years 

Journal Entries 7 years 

Invoices 7 years 

Sales Records 5 years 

Petty Cash Vouchers 3 years

Cash Receipts 3 years

Credit Card Receipts 3 years 

Bank Records Bank

Deposit Slips 7 years

Bank Statements and Reconciliation 7 years 

Electronic Fund Transfer Documents 7 years 

Payroll and Employment Tax Records

Earnings Records 7 years 

Garnishment Records 7 years 

Payroll Tax returns 7 years 

W-2 Statements 7 years 

Employee Records

Records Relating to Promotion, Demotion or Discharge 7 years after termination 

Accident Reports and Worker’s Compensation Records 5 years after termination of claim

Salary Schedules 5 years 

Employment Applications 3 years

 I-9 Forms 3 years after termination

 Time Cards 2 years 

Legal, Insurance and Safety Records

Donor Records and Acknowledgement Letters 7 years 

Grant Applications and Contracts 5 years after completion

Leases 6 years after expiration

OSHA Documents 5 years 

General Contracts 4 years after termination

IV. Emergency Planning 

HACF’s records will be stored in a safe, secure and accessible manner. All documents and financial files that are essential to keeping HACF operating in an emergency will be duplicated or backed up at least every week and maintained off site. All other documents and financial files will be duplicated or backed up periodically as identified by the Executive Director or other person as designated by the Chief Professional Officer and maintained off-site.

VI. Document Destruction

 HACF’s Executive Director is responsible for the ongoing process of identifying its records which have met the required retention period and overseeing their destruction. Destruction of financial and personnel-related documents will be accomplished by shredding. Document destruction will be suspended immediately, upon any indication of an official investigation or when a lawsuit is filed or appears imminent. Destruction will be reinstated upon conclusion of the investigation or claim, whichever is latest.

VII. Compliance

 The failure on the part of employees to follow this policy can result in possible civil and criminal sanctions against HACF and its employees and possible disciplinary action against responsible individuals. The Executive Director will periodically review these procedures with legal counsel or the organization’s certified public accountant to ensure that they are in compliance with new or revised regulations.

 Questions concerning these policies, the applicability of certain records to the retention or destruction policies, must be addressed to the Executive Director.

Highland Area Community Foundation

Record Retention and Destruction Policy

Approved by the Board of Directors on February 20, 2024