terms conditions

Data Retention Policy

Policy #: SL/001

Total pages: 9

Attachments: 0

Approved by:

Keval Pankhania

Effective Date:

05/04/2018

Date Revised:

23/04/2018

Date to be reviewed:

05/04/2019

RECORD RETENTION AND DESTRUCTION POLICY

1) Purpose

The purpose of this Policy is to ensure that necessary records and documents of are adequately protected and maintained and to ensure that records that are no longer needed by Snellers LTD and Sneller Property Consultants or are of no value are discarded at the proper time. This Policy is also for the purpose of aiding employees of Snellers LTD and Sneller Property Consultants in understanding their obligations in retaining electronic documents - including e-mail, Web files, text files, sound and movie files, PDF documents, and all Microsoft Office or other formatted files.

2) Policy

This Policy represents the Snellers LTD and Sneller Property Consultants’ policy regarding the retention and disposal of records and the retention and disposal of electronic documents.

3) Administration

Attached as Appendix A is a Record Retention Schedule that is approved as the initial maintenance, retention and disposal schedule for physical records of Snellers LTD and Sneller Property Consultants and the retention and disposal of electronic documents. The Data Controller (the “Administrator”) is the officer in charge of the administration of this Policy and the implementation of processes and procedures to ensure that the Record Retention Schedule is followed. The Administrator is also authorized to: make modifications to the Record Retention Schedule from time to time to ensure that it is in compliance with local, state and federal laws and includes the appropriate document and record categories for Snellers LTD and Sneller Property Consultants; monitor local, state and federal laws affecting record retention; annually review the record retention and disposal program; and monitor compliance with this Policy.

4) Suspension of Record Disposal In Event of Litigation or Claims

In the event Snellers LTD and Sneller Property Consultants is served with any subpoena or request for documents or any employee becomes aware of a governmental investigation or audit concerning Snellers LTD and Sneller Property Consultants or the commencement of any litigation against or concerning Snellers LTD and Sneller Property Consultants such employee shall inform the Administrator and any further disposal of documents shall be suspended until shall time as the Administrator, with the advice of counsel, determines otherwise. The Administrator shall take such steps as is necessary to promptly inform all staff of any suspension in the further disposal of documents.

5) Applicability

This Policy applies to all physical records generated in the course of Snellers LTD and Sneller Property Consultants’ operation, including both original documents and reproductions. It also applies to the electronic documents described above.

This Policy was approved by the Chairman and Managing Director of Snellers LTD and Sneller Property Consultants on 05.04.2018.

APPENDIX A RECORD RETENTION SCHEDULE

The Record Retention Schedule is organized as follows:

SECTION TOPIC

  1. A. Accounting and Finance
  2. B. Contracts
  3. C. Corporate Records
  4. D. Correspondence and Internal Memoranda
  5. E. Electronic Documents
  6. F. Grant Records
  7. G. Insurance Records
  8. H. Legal Files and Papers
  9. I. Miscellaneous
  10. J. Payroll Documents
  11. K. Pension Documents
  12. L. Personnel Records
  13. M. Property Records
  14. N. Tax Records
  15. O. Contribution Records
  16. P. Fiscal Sponsor Project Records

 

A. ACCOUNTING AND FINANCE

Record Type

Retention Period

Accounts Payable ledgers and schedules

7 years

Accounts Receivable ledgers and schedules

7 years

Annual Audit Reports and Financial Statements

Permanent

Annual Audit Records, including work papers and other documents that relate to the audit

7 years after completion of audit

Annual Plans and Budgets

2 years

Bank Statements and Canceled Checks

7 years

Employee Expense Reports

7 years

General Ledgers

Permanent


Interim Financial Statements

7 years

Notes Receivable ledgers and schedules

7 years

Investment Records

7 years after sale of investment

 

B. CONTRACTS

Record Type Retention Period

Record Type

Retention Period

Contracts and Related Correspondence (including any proposal that resulted in the contract and all other supportive documentation)

7 years after expiration or termination

 

C. CORPORATE RECORDS

Record Type Retention Period

Record Type

Retention Period

Corporate Records (minute books, signed minutes of the Board and all committees, corporate seals, articles of incorporation, bylaws, annual corporate reports)

Permanent

Licenses and Permits

Permanent

 

D. CORRESPONDENCE AND INTERNAL MEMORANDA

General Principle: Most correspondence and internal memoranda should be retained for the same period as the document they pertain to or support. For instance, a letter pertaining to a particular contract would be retained as long as the contract (7 years after expiration). It is recommended that records that support a particular project be kept with the project and take on the retention time of that particular project file.

Correspondence or memoranda that do not pertain to documents having a prescribed retention period should generally be discarded sooner. These may be divided into two general categories:

1. Those pertaining to routine matters and having no significant, lasting consequences should be discarded within two years. Some examples include:

  • Routine letters and notes that require no acknowledgment or follow up, such as notes of appreciation, congratulations, letters of transmittal, and plans for meetings.
  • Form letters that require no follow up.
  • Letters of general inquiry and replies that complete a cycle of correspondence.
  • Letters or complaints requesting specific action that have no further value after changes are made or action taken (such as name or address change).
  • Other letters of inconsequential subject matter or that definitely close correspondence to which no further reference will be necessary.
  • Chronological correspondence files.

Please note that copies of interoffice correspondence and documents where a copy will be in the originating department file should be read and destroyed, unless that information provides reference to or direction to other documents and must be kept for project traceability.

2. Those pertaining to non routine matters or having significant lasting consequences should generally be retained permanently.

E. ELECTRONIC DOCUMENTS

1. Electronic Mail: Not all email needs to be retained, depending on the subject matter.

  • All e-mail—from internal or external sources—is to be deleted after 12 months.
  • Staff will strive to keep all but an insignificant minority of their e-mail related to business issues.
  • Snellers LTD and Sneller Property Consultants will archive e-mail for six months after the staff has deleted it, after which time the e-mail will be permanently deleted.
  • All Snellers LTD and Sneller Property Consultants business-related email should be downloaded to a service center or user directory on the server.
  • Staff will not store or transfer Snellers LTD and Sneller Property Consultants related e-mail on non-work-related computers except as necessary or appropriate for Snellers LTD and Sneller Property Consultants purposes.
  • Staff will take care not to send confidential/proprietary Snellers LTD and Sneller Property Consultants information to outside sources.
  • Staff with more than 500MB in their e-mail account will be unable to send or receive messages until the size of their account is reduced. Staff will be notified by the IT department as their account size approaches 500 MB.
  • Any e-mail staff deems vital to the performance of their job should be copied to the staff’s H: drive folder, and printed and stored in the employee’s workspace.

2. Electronic Documents: including Microsoft Office Suite and PDF files. Retention also depends on the subject matter.

  • PDF documents – The length of time that a PDF file should be retained should be based upon the content of the file and the category under the various sections of this policy. The maximum period that a PDF file should be retained is 6 years. PDF files the employee deems vital to the performance of his or her job should be printed and stored in the employee’s workspace.
  • Text/formatted files - Staff will conduct annual reviews of all text/formatted files (e.g., Microsoft Word documents) and will delete all those they consider unnecessary or outdated. After five years, all text files will be deleted from the network and the staff’s desktop/laptop. Text/formatted files the staff deems vital to the performance of their job should be printed and stored in the staff’s workspace.

3. Web Page Files: Internet Cookies

  • All workstations: Internet Explorer should be scheduled to delete Internet cookies once per month.

Snellers LTD and Sneller Property Consultants does not automatically delete electronic files beyond the dates specified in this Policy. It is the responsibility of all staff to adhere to the guidelines specified in this policy.

Each day Snellers LTD and Sneller Property Consultants will run a tape backup copy of all electronic files (including email) on Snellers LTD and Sneller Property Consultants’ servers, as specified in the Snellers LTD and Sneller Property Consultants Disaster Recovery Plan. This backup tape is a safeguard to retrieve lost information within a one-year retrieval period should documents on the network experience problems. The tape backup copy is considered a safeguard for the record retention system of Snellers LTD and Sneller Property Consultants, but is not considered an official repository of Snellers LTD and Sneller Property Consultants records. All monthly and yearly tapes are stored offsite.

In certain cases a document will be maintained in both paper and electronic form. In such cases the official document will be the electronic document.

F. GRANT RECORDS

Record Type

Retention Period

Original grant proposal

7 years after completion of grant period

 

 

Grant agreement and subsequent modifications, if applicable

7 years after completion of grant period

 

 

All requested IRS/grantee correspondence including determination letters and “no change” in exempt status letters

7 years after completion of grant period

 

 

Final grantee reports, both financial and narrative

7 years after completion of grant period

 

 

All evidence of returned grant funds

7 years after completion of grant period

 

 

All pertinent formal correspondence including opinion letters of counsel

7 years after completion of grant period

Report assessment forms

7 years after completion of grant period

 

 

Documentation relating to grantee evidence of invoices and matching or challenge grants that would support grantee compliance with the grant agreement

7 years after completion of grant period

 

 

Pre-grant inquiry forms and other documentation for expenditure responsibility grants

7 years after completion of grant period

 

 

Grantee work product produced with the grant funds

7 years after completion of grant period

G. INSURANCE RECORDS

Record Type

Retention Period

Annual Loss Summaries

10 years

Audits and Adjustments

3 years after final adjustment

Certificates Issued to {Insert Name of Organization}

Permanent

Claims Files (including correspondence, medical records, injury documentation, etc.)

Permanent

Group Insurance Plans ‑ Active Employees

Until Plan is amended or terminated

Group Insurance Plans – Retirees

Permanent or until 6 years after death of last eligible participant

Inspections

3 years

Insurance Policies (including expired policies)

Permanent

Journal Entry Support Data

7 years

Loss Runs

10 years

Releases and Settlements

25 years

 

H. LEGAL FILES AND PAPERS

Record Type

Retention Period

Legal Memoranda and Opinions (including all subject matter files)

7 years after close of matter

Litigation Files

1 year after expiration of appeals or time for filing appeals

Court Orders

Permanent

Requests for Departure from Records Retention Plan

10 years

I. MISCELLANEOUS

Record Type

Retention Period

Consultant's Reports

2 years

Material of Historical Value (including pictures, publications)

Permanent

Policy and Procedures Manuals – Original

Current version with revision history

Policy and Procedures Manuals ‑ Copies

Retain current version only

Annual Report

Permanent

Applicant information

2 years

J. PAYROLL DOCUMENTS

Record Type

Retention Period

Employee Deduction Authorizations

4 years after termination

Payroll Deductions

Termination + 7 years

W-2 and W-4 Forms

Termination + 7 years

Garnishments, Assignments, Attachments

Termination + 7 years

Labor Distribution Cost Records

7 years

Payroll Registers (gross and net)

7 years

Time Cards/Sheets

2 years

Unclaimed Wage Records

6 years

K. PENSION DOCUMENTS AND SUPPORTING EMPLOYEE DATA

General Principle: Pension documents and supporting employee data shall be kept in such a manner that Donors Forum can establish at all times whether or not any pension is payable to any person and if so the amount of such pension.

Record Type

Retention Period

 

 

Retirement and Pension Records

Permanent

L. PERSONNEL RECORDS

Record Type

Retention Period

Commissions/Bonuses/Incentives/Awards

7 years

 

 

EEO‑ I /EEO‑2 ‑ Employer Information Reports

2 years after superseded or filing (whichever is longer)

 

 

Employee Earnings Records

Separation + 7 years

 

 

Employee Handbooks

1 copy kept permanently

 

 

Employee Medical Records

Separation + 6 years

 

 

Employee Personnel Records (including individual attendance records, application forms, job or status change records, performance evaluations, termination papers, withholding information, garnishments, test results, training and qualification records)

6 years after separation

 

 

Employment Contracts – Individual

7 years after separation

 

 

Employment Records ‑ Correspondence with Employment Agencies and Advertisements for Job Openings

3 years from date of hiring decision

 

 

Employment Records ‑ All Non‑Hired Applicants (including all applications and resumes ‑ whether solicited or unsolicited, results of post‑offer, pre‑employment physicals, results of background investigations, if any, related correspondence)

2-4 years (4 years if file contains any correspondence which might be construed as an offer)

 

 

Job Descriptions

3 years after superseded

 

 

Personnel Count Records

3 years

 

 

Forms I-9

3 years after hiring, or 1 year after separation if later

M. PROPERTY RECORDS

Record Type

Retention Period

 

 

Correspondence, Property Deeds, Assessments, Licenses, Rights of Way

Permanent

 

 

Original Purchase/Sale/Lease Agreement

Permanent

 

 

Property Insurance Policies

Permanent

N. TAX RECORDS

General Principle: Donors Forum must keep books of account or records as are sufficient to establish amount of gross income, deductions, credits, or other matters required to be shown in any such return.

These documents and records shall be kept for as long as the contents thereof may become material in the administration of federal, state, and local income, franchise, and property tax laws.

Record Type

Retention Period

Tax-Exemption Documents
and Related Correspondence

Permanent

IRS Rulings

Permanent

Excise Tax Records

7 years

Payroll Tax Records

7 years

Tax Bills, Receipts, Statements

7 years

Tax Returns ‑ Income, Franchise, Property

Permanent

Tax Workpaper Packages ‑ Originals

7 years

Sales/Use Tax Records

7 years

Annual Information Returns - Federal and State

Permanent

IRS or other Government Audit Records

Permanent

O. CONTRIBUTION RECORDS

Record Type

Retention Period

Records of Contributions

Permanent

Snellers LTD and Sneller Property Consultants’ or other documents evidencing terms of gifts

Permanent

P. FISCAL SPONSOR PROJECT RECORDS

Record Type

Retention Period

Sponsorship agreements

Permanent