College Advancement and Public Relations

10:02:07 Foundation Document Retention Policy

1. 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 review, retention, and destruction of documents received or created by the Chattanooga State Foundation in connection with the transaction of organization business.
2. This policy covers all records and documents, regardless of physical form, contains guidelines for how long certain documents should be kept, how records should be destroyed (unless under a legal hold), and release the foundation’s records upon receipt of a request.
3. The policy is designed to ensure compliance with federal and state laws and regulations, to eliminate accidental or innocent destruction of records.
4. Documents for this policy include records described below and those substantially similar to those listed:
   1. Annual reports to Secretary of State - permanent
   2. Annual audits and Financial Statements - permanent
   3. IRS Form 990 - permanent
   4. IRS determination letter - permanent
   5. Bylaws - permanent
   6. Board Policies - permanent
   7. Board meeting minutes - permanent
   8. General Ledgers - seven years
   9. Banking records  - seven years  
   10. Contracts - seven years
   11. Donor records - seven years
   12. Donor acknowledgement letters - seven years
   13. Grant records - seven years
   14. General correspondence - three years

5. Document Destruction: The College Advancement Department, in coordination with the Foundation’s Accountant, are responsible for the ongoing process of identifying Foundation records which have met the required retention period and overseeing their destruction. Destruction of financial documents will be accomplished by shredding.
   1. 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.
6. All records and documents, regardless of physical form, are covered by this policy, and electronic files are appropriate, including scans of permanent records, email communications, and other digital messages like voice mail or text messages if they are able to be stored and retrieved as needed.
7. Release of the foundation’s records, upon receipt of a request, will be made in compliance with any applicable laws and is granted to the Vice President of College Advancement and Public Relations as the executive role for the Foundation.

Approved by Foundation Board:  Feb. 3, 2020