Document Retention and Destruction Policy
What the Fund keeps, how long it keeps it, and when destruction must stop.
ADOPTED by the Board of Directors on October 7, 2026. Published through /transparency. Next review: October 2027. Counsel review is recommended. (IRS Form 990, Part VI, Line 14 asks whether the Fund has a written document retention and destruction policy.)
Adopted by the Board on: October 7, 2026 Next review: October 2027
1. Purpose
The Fund keeps records needed to run the organization, meet legal and tax obligations, and demonstrate accountability to donors and the public. This policy states what to keep, how long to keep it, and how to destroy it — and when destruction must stop.
2. Retention schedule
- Articles of incorporation, bylaws, IRS determination letter, state registrations: Permanent
- Board and committee minutes, resolutions, written consents: Permanent
- Conflict-of-interest disclosures and annual statements: Permanent (or 7 years after the person leaves, whichever is longer)
- Tax returns (Forms 990) and supporting workpapers: 7 years from filing
- Gift records, acknowledgments, Forms 8283/8282 and the non-cash gift register: 7 years from the gift or disposition
- Audited financial statements: Permanent
- Bank statements, ledgers, invoices, receipts: 7 years
- Payroll and personnel records: 7 years after termination of employment
- Contracts and grant agreements: 7 years after expiration or completion
- Insurance policies (expired): 7 years after expiration
- Correspondence and email relating to any of the above: Same period as the underlying record
Where law requires a longer period, the longer period controls. Counsel to confirm the schedule.
3. Electronic records
Electronic records are records under this policy. The Fund maintains electronic records in readable form for the full retention period and keeps backups sufficient to recover them. Deleting an email or file does not destroy the record if a backup or copy retains it — destruction under Section 5 must cover all copies the Fund controls.
4. Storage and responsibility
The Executive Director designates where records are stored (physical and electronic), who may access them, and who is responsible for each category. Donor records are kept to the minimum needed, consistent with the donor privacy policy.
5. Destruction
- Once a year, the Executive Director reviews records whose retention period has expired and authorizes destruction.
- Destruction is by a method appropriate to the medium (shredding for paper; secure deletion for electronic records).
- A log of destroyed records (description, date range, date destroyed, who authorized) is kept permanently.
- No record is destroyed while a litigation hold is in effect (Section 6).
6. Litigation hold — suspension of destruction
If litigation, a government investigation or audit, or any other proceeding involving the Fund is reasonably anticipated, threatened, or pending, all destruction stops immediately for records that could be relevant — including routine deletion under Section 5. The Executive Director, on advice of counsel, issues a written hold notice identifying what must be preserved, and lifts it in writing when the matter is resolved.
Note: federal law criminalizes the destruction of records with intent to obstruct an investigation (see, e.g., 18 U.S.C. §§ 1519 and 1513(e)). When in doubt, preserve. Counsel to confirm.
7. Review
The Board reviews this policy at least annually.