Document Retention & Destruction Policy
Document 7 of the Board Governance Binder
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Document Retention & Destruction Policy
Document Retention and Destruction Policy
I. Purpose
This policy establishes guidelines for the retention and destruction of documents and records of PROVENIQ Foundation, Inc. This policy is designed to ensure compliance with applicable federal and state laws, protect the Corporation’s interests, preserve important records, and provide for the orderly disposal of documents that are no longer needed.
II. Scope
This policy applies to all records of the Corporation, regardless of format (paper, electronic, digital, audio, video). It applies to all Directors, Officers, employees, volunteers, and contractors.
III. Retention Schedule
| RECORD TYPE | RETENTION | AUTHORITY |
|---|---|---|
| Articles of Incorporation | Permanent | State law |
| Bylaws and amendments | Permanent | Governance |
| Board meeting minutes | Permanent | Governance |
| Committee meeting minutes | Permanent | Governance |
| Tax-exempt determination letter | Permanent | IRS |
| Form 990 annual returns | Permanent | IRS |
| Financial audit reports | Permanent | Best practice |
| Annual financial statements | 7 years | IRS/state |
| General ledger and journals | 7 years | IRS |
| Bank statements and reconciliations | 7 years | IRS |
| Accounts payable/receivable | 7 years | IRS |
| Payroll records and tax filings | 7 years | IRS/DOL |
| Grant agreements and reports | 7 years after close | Funder/IRS |
| Donor records and gift acknowledgments | 7 years | IRS |
| Contracts and agreements | 7 years after expiration | Legal |
| Insurance policies | 7 years after expiration | Legal |
| Employee personnel files | 7 years after separation | DOL/state |
| Employment applications (not hired) | 3 years | EEOC |
| Conflict of interest disclosures | 7 years | Governance |
| Director acknowledgments | 7 years after service | Governance |
| Whistleblower reports | 7 years | Governance |
| ADA accommodation records | 7 years | ADA/EEOC |
| Technology license agreements | Permanent | IP/Legal |
| Sublicense agreements | 7 years after termination | IP/Legal |
| IP assignment agreements | Permanent | IP/Legal |
| Data breach incident records | 7 years | Cybersecurity |
| General correspondence | 3 years | Best practice |
| Press releases and publications | Permanent | Historical |
IV. Destruction Procedures
Documents that have met their retention period shall be destroyed in a manner appropriate to their content. Paper documents containing sensitive information shall be shredded. Electronic records shall be permanently deleted using secure deletion methods. The CEO or their designee shall maintain a destruction log recording the date, description of records destroyed, and the individual authorizing destruction.
V. Litigation and Investigation Hold
In the event the Corporation becomes aware of pending or threatened litigation, government investigation, or audit, all document destruction shall cease immediately for any records that may be relevant to the matter. The CEO or Board Chair shall issue a written litigation hold notice to all affected parties. Destruction of documents subject to a litigation hold is a serious violation of this policy and may constitute a criminal offense.
VI. Electronic Records
Electronic records (including email, databases, cloud storage, and digital files) are subject to the same retention and destruction requirements as paper records. The Corporation shall maintain backup systems for critical electronic records. The CEO shall ensure that electronic records associated with the Pet Command ecosystem (MAYDAY, ShelterOS, LifeLog, VetOS, Guardians, ACO-Mobile, SYSOP) are retained and managed consistent with the Corporation’s data governance policies and any applicable platform-specific retention requirements.
VII. Responsibility
The CEO is responsible for overseeing compliance with this policy. The Finance, Audit & Risk Committee shall periodically review compliance. All staff, Directors, and contractors are responsible for retaining records in accordance with this schedule.
VIII. Annual Review
This policy shall be reviewed annually by the Governance & Nominating Committee.