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Document Retention / Destruction Policy

Introduction

In accordance with the Sarbanes-Oxley Act, which makes it a crime to alter, cover up, falsify, or destroy any document with the intent of impeding or obstructing any official proceeding, this policy provides for the systematic review, retention and destruction of documents received or created by Ephrata Public Library in connection with the transaction of organization business.

Purpose

This policy covers all records and documents, regardless of physical form, contains guidelines for how long certain documents should be kept and how records should be destroyed. The policy is designed to ensure compliance with federal and state laws and regulations. Some documents may need to be preserved for operational use or historical value also.

Document Retention

The Ephrata Public Library follows the document retention schedule as is outlined in the table below:

Organizational

Articles of IncorporationPermanent
Annual Reports to the PA Department of EducationPermanent
Board Meeting and Board Committee MinutesPermanent
Board Policies, Resolutions and By-lawsPermanent
Construction Documents and PlansPermanent
State Sales Tax Exemption LetterPermanent
IRS Determination LetterPermanent
IRS Application for Tax-Exempt Status (Form 1023)Permanent – 5 year renewal
Statistics10 years
Contracts (after expiration)7 years
Materials Challenges, Correspondence and Decisions6 years
Complaints or Suggestions6 years
Correspondence (Executive Director-general)2 years
Correspondence (legal)Permanent

Accounting and Tax Records

Annual Audits and Financial StatementsPermanent
Audit InquiresPermanent
General LedgersPermanent
IRS 990 Tax ReturnsPermanent
Business Expense Records7 years
Journal Entries7 years
Invoices7 years
Cash and Credit Card Receipts3 years

Bank Records

Check Registers7 years
Year End Financial Statements7 years
Bank Deposit Slips7 years
Bank Reconciliation 7 years
Bank statements, deposit records, electronic fund transfer and cancelled checks7 years

Payroll and Employment Tax Records

Payroll Register7 years
State Unemployment Tax Records7 years
W-2 Statements7 years
Earnings Records7 years
Garnishment Records7 years
PHEAA Records7 years

Employee Records

Retirement and Pension Plan Documents7 years after termination
Records Relating to Promotion, Demotion or Discharge7 years after termination
Accident Reports and Worker’s Compensation Records7 years after termination
I-9 Forms3 years after termination
PA Child Abuse History Clearance1 year after termination
Criminal Record Check1 year after termination
Employment Applications and Resumes3 years

Grants and Donations

Donor Records7 years
Acknowledgement Letters and Donor Response Cards7 years
Grant Applications and Contracts7 years after completion

Legal, Insurance and Safety Records

AppraisalsBorough of Ephrata
Environmental StudiesBorough of Ephrata
Building InspectionsBorough of Ephrata
Real Estate DocumentsPermanent
Insurance Policies (expired)7 years
Leases 6 years after expiration
OSHA Documents5 years
General Contracts3 years after termination
Insurance CertificatesTerm of Service

Library Patrons & Material Records

Patron Applications2 years after expiration
Internet Agreements2 years after expiration
Catalog of HoldingsDeleted after becoming superseded or obsolete

Electronic Documents and Records

Electronic documents will be retained as if they were paper documents. Therefore, any electronic files, including records of donations made online, that fall into one of the document types on the above schedule will be maintained for the appropriate amount of time. 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.

Document Destruction

The Executive Director and the Manager of Operations are responsible for the ongoing process of identifying records which have met the required retention period and overseeing their destruction. Destruction of financial and personnel-related documents will be shredded.

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.

Compliance

Failure on the part of employees to follow this policy can result in possible civil and criminal sanctions against the Ephrata Public Library and its employees and possible disciplinary action against responsible individuals. The Executive Director and Manager of Operations 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.

This page was last modified on March 18 2011