Document Retention Policy
TABLE OF CONTENTS
- Document Retention Policy
- Document Retention Procedures
- Appendix A – Record Retention Schedule
This policy provides timelines and guidelines for the review, retention and destruction of records and documents of Brado, which includes client data acquired for market research or other contractually obligated purposes. The purposes are to:
- ensure compliance with all applicable federal, state and international laws and regulations,
- ensure adherence to industry standards in the disciplines of accounting, human resources, client services, asset management and other, as appropriate,
- provide a reference for users regarding retention periods by document category,
- eliminate accidental destruction of records, and
- promote efficiency in company operations by eliminating the unnecessary storage of obsolete or duplicate
The retention and disposal schedule for all Brado records is set forth in Appendix A: Record Retention Schedule. The Document Retention Steering Team (the “Administrator”) oversees the administration of this policy and the implementation of procedures to ensure that the Record Retention Schedule is followed. Employees and departments are responsible for appropriately storing and purging their electronic documents according to the schedule.
This policy covers all records and documents regardless of form (electronic or physical) acquired or generated by Brado business transactions, including client data acquired or generated for the provision of services. It applies to all Brado systems and users, including employees, contractors and other authorized third parties.
Violations of this policy should be reported to the user’s supervisor or HR. Brado employees who violate this policy may be subject to disciplinary action, up to and including termination. Other users in violation of this policies and related procedures may be subject to loss of visitor privileges, termination of services and/or termination of engagement from Brado.
These procedures explain processes for the review, retention and destruction of records and documents of Brado. The retention and disposal schedule for all records is set forth in Appendix A: Record Retention Schedule.
The Document Retention Steering Team (the “Administrator”) oversees the administration and the implementation of processes and procedures to ensure that the Record Retention Schedule is followed. The team is led by the Chief Financial Officer (CFO) and includes a representative from Information Technology and Human Resources. Additional members may be designated by the CFO when subject matter expertise is required. The Administrator is authorized to:
- Monitor applicable laws and make modifications to the Record Retention Schedule to ensure compliance with changing legislation or regulations,
- Modify document and record categories and retention periods based on changes in business circumstances or industry standards,
- Monitor as appropriate to ensure compliance with this policy, and
- Communicate requirements and changes as appropriate.
The Administrator will conduct an annual review and update the policy and procedures as appropriate.
Employees and departments are responsible for appropriately storing their documents according to the Record Retention Schedule. It is Brado’s preferred standard to rely primarily upon electronic copies of records and physical copies should be created only when required for the task at hand. Brado utilizes cloud-based services for file storage, which meet or exceed industry standards for managing protected data. As a standard practice, IT creates encrypted backups that can be used for recovery from an adverse event; but these backups are not to be relied upon for document retention.
The following procedures should be followed by users:
- Electronic documents:
- Should be stored in the applicable storage location, with appropriate attention given to consistent labeling and assignment of access rights.
- Should NOT be saved to a local hard drive. Files may be synced with local hard drive using approved system software (e.g. Microsoft OneDrive).
- Should NOT be stored on removeable media (such as thumb drives) except as necessary for file transfer, in which case an encrypted device should be utilized.
- Paper or hard copies of documents:
- Should be scanned or digitized and retained as directed above in electronic format.
- If a paper copy is required, it should be kept in a locked file cabinet or an otherwise secured location.
Employees and departments are responsible for appropriately purging their documents according to the Record Retention Schedule. The following procedures should be followed by users:
- Electronic documents:
- Users should dispose of or delete documents with expired retention periods by moving the file to the Microsoft “Recycle Bin” or Apple “Trash Can.”
- Items marked for deletion are kept in a queue and purged after 30 days to prevent accidental permanent deletion, based on policy settings on the server.
- If it is necessary to delete items immediately, a request should be sent to IT.
- Paper or hard copies of documents:
- Users should dispose of documents with expired retention periods as directed by the local Office Manager.
Upon notification of a governmental investigation or anticipated litigation, the Administrator will suspend document destruction of all related documents until such investigation or litigation is concluded. The Administrator will promptly inform those who may be affected of the hold on document disposal.
Brado may engage contractors in the provision of client services and other business activities. The Independent Contractor Agreement states that all copies of information shared by Brado shall be returned upon termination of the Agreement.
Contracts with third parties (clients, partners and vendors) include clauses regarding confidential information that may supersede standard policies and procedures. Client MSAs, Non-Disclosure Agreements (NDAs) and/or vendor contracts may detail definitions and processes required for data retention in a specific relationship. For example, clients often request that protected data be deleted (or returned) as soon as the reason for its existence has expired.
Employees are advised to consult with the Client Partner, Account Manager or Project Manager regarding unique terms and conditions possibly imposed by third parties.
The Record Retention Schedule is organized as follows:
- Accounting and Finance
- Corporate Records
- Correspondence and Internal Memoranda
- Human Resources Records
- Insurance Records
- Legal Files and Papers
- Payroll Documents
- Property Records
- Tax Records
- Client Records
|Accounts Payable Ledgers, Schedules, and Invoices||7 years|
|Accounts Receivable Ledgers, Schedules, and Bank Deposit Reports||7 years|
|Account Reconciliations||7 years|
|Account Write-‐off Detail||7 years|
|Annual Audit Records, including related work papers and documents||7 years after completion of audit|
|Bank Statements, Check Registers, Outstanding Check List, Voided Checks, and Canceled Checks||7 years|
|Client Credit Rating Files||Active|
|Credit Requests and Applications||Active|
|Employee Expense Reports||7 years|
|Fixed Asset Listings and Depreciation Schedules||Permanent|
|Financial Statements and Audit Reports||Permanent|
|Inactive Customer Information||7 years|
|Investment Records||7 years after sale of investment|
|Notes Receivable Ledgers and Schedules||7 years|
|Purchase Orders||7 years|
|Support for Reserves and Allowances||7 years|
|Wire Transfers & ACH||7 years|
|Contracts or Statements of Work (including any proposal that resulted in the contract and other supportive documentation)||7 years after expiration or termination|
|Independent Contractor Agreements||Separation + 7 years|
|Data Privacy, Protection, and Security Agreements||7 years after expiration or termination|
|Corporate Records (minute books, signed minutes of the Board and all committees, corporate seals, articles of incorporation, amendments, bylaws, stock certificates, annual corporate reports)||Permanent|
|Licenses and Permits||Permanent|
|Policy and Procedures Manuals -‐ Original||Current version with revision history|
|Policy and Procedures Manuals -‐ Copies||Retain current version only|
Email and other correspondence should be retained for the same period as the underlying matter supported. For example, a letter pertaining to a contract would be scanned and retained for the same period as the contract (seven (7) years after expiration). Records that support a specific project should be kept with the project and take on the retention time of the project file.
Email and correspondence that do not pertain to documents having a prescribed retention period may be discarded after they are no longer useful. Those pertaining to routine matters and having no significant, lasting consequences should be discarded within three (3) years.
General HR Record Type
|EEO-‐ I Employer Information Reports||2 years after superseded/filing (whichever is longer)|
|Employee Handbooks / Bulletin Boards||1 copy kept indefinitely|
|Employee Personnel Records (job or status change records, performance evaluations, termination papers)||Separation + 6 years|
|Employee Workers Compensation claims files||Separation + 6 years|
|Background Checks||Separation + 6 years|
|Employee Training Documentation||Separation + 6 years|
|Employee PII/PHI Disclosures||Separation + 6 years|
Hiring and Recruiting Record Type
|Employment Records||2 years after the hire/no hire decision|
|Applications and Resumes for Hired and Non-‐ Hired|
|Results of Post Hire|
|‐Non-‐Hired Pre-‐employment physicals & drug tests|
|Non-‐Hired Results of background investigations/credit reports|
|Advertisements for Job Openings|
|Employment Agency correspondence|
|Job Descriptions||Keep as long as current|
|I-9 Forms||Separation + 1 year or 3 years after hire date, whichever is longer.|
|Annual Loss Summaries||3 years|
|Audits and Adjustments||3 years after final adjustment|
|General Liability Claims Files||7 years after close of matter|
|Group Insurance Plans -‐ Active Employees||Until Plan is amended or terminated|
|Group Insurance Plans -‐ Retirees||6 years after death of last eligible participant|
|Insurance Policies (including expired policies)||Permanent|
|Loss Runs||10 years|
|Releases and Settlements||25 years|
|Legal Memoranda and Opinions (including all subject matter files)||7 years after close of matter|
|Litigation Files||7 years after close of matter|
|Employee Deduction Authorizations and W-‐4 (in an employee file)||Same as employee file|
|Garnishments and Wage Assignments||5 years after completion date|
|Payroll Registers (gross and net)||7 years|
|Tax reports||7 years|
|Unclaimed Wages (tied to employee record)||7 years|
|Real Estate Documents (Loan and mortgage contracts, Property Deeds, Assessments, Licenses, Rights of Way)||Permanent|
|Original Purchase/Sale Agreement||Permanent|
|Real Property Leases||Expiration + 10 Years|
|Property Insurance Policies||Permanent|
General Principle: Books and records must be kept establishing amount of gross income, deductions, credits, or other matters required to be shown in any such return. These documents and records must 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.
|Depreciation Records-‐Tax Depreciation||7 years|
|Excise Tax Records||7 years|
|Tax Bills, Receipts, Statements||7 years|
|Tax Returns -‐ Income, Franchise, Payroll, Property||Permanent|
|Tax Workpaper Packages -‐ Originals||7 years|
|Transfer Pricing Documentation||Permanent|
|Sales/Use Tax Records||7 years|
|Annual Information Returns -‐ Federal and State||Permanent|
|IRS or other Government Audit Records||Permanent|
|Records of Contributions||Permanent|
|Documents evidencing terms of gifts||Permanent|
General Principle: Client relationships are defined by Master Service Agreements (MSA) which vary greatly in requirements. These retention periods are Brado’s standards, but employees are directed to consult with the Client Partner, Account Manager, or Project Manager regarding specific client agreements that may state varying requirements.
|Informed Consent Agreements||3 years (minimum)|
|Participant Opt-out Requests||3 years (minimum)|
|Employee Training, Client specific||3 years (minimum)|
|Pharmacovigilance Adverse Events / Safety Information, including primary source data and employee training||7 years (minimum)|
|Client Materials||See MSA|
|Client Deliverables||3 years (minimum)|
|SOW related protected data (recruiting lists, for example)||Delete upon completion of SOW|