Purpose
The Baltimore Council on Foreign Affairs (BCFA) is committed to effective records management to ensure the preservation, organization, and accessibility of records in compliance with legal, regulatory, and operational requirements. This Records Retention Policy establishes guidelines for the retention, storage, and disposal of BCFA records.
Scope
This policy applies to all records created, received, and maintained by the BCFA, including electronic and paper documents, generated in the course of BCFA activities. The policy is applicable to all Board of Trustees members, officers, employees, and volunteers.
Definition of Records
Records include, but are not limited to:
- Governing Documents: Articles of incorporation, bylaws, and amendments.
- Meeting Records: Minutes of board and committee meetings, agendas, and supporting documentation.
- Financial Records: Budgets, financial statements, audit reports, bank statements, and tax filings.
- Legal and Compliance Documents: Contracts, agreements, licenses, and compliance documents.
- Personnel Records: Employment and personnel files, including timesheets and payroll records.
- Programmatic Records: Records related to BCFA’s programming, events, research, and grants.
- Communications: Significant correspondence, including email, related to official BCFA business.
Retention Periods
Records will be retained for at least the specified duration, after which they may be securely disposed of:
- Articles of Incorporation: Permanent
- Bylaws and Amendments: Permanent
- Board Meeting Minutes: Permanent
- Financial Statements: 7 years
- Tax Filings (IRS Form 990): Permanent
- Bank Statements: 7 years
- Audit Reports: 7 years
- Contracts and Agreements: 7 years after expiration or termination
- Personnel Records: 7 years after termination
- Payroll Records: 7 years
- Programmatic Records: 3 years
- Grants Documentation: 3 years after grant closure
- Compliance Documents: 5 years
- Correspondence (Significant): 3 years
- Electronic Communications: As needed, based on content and significance
Storage and Security
- Physical Records: Stored in secure locations with controlled access to authorized personnel only.
- Electronic Records: Stored on secure servers with appropriate data backup and access controls to ensure confidentiality and integrity.
- Archiving: Records deemed important but inactive may be archived in secure storage, with access limited to authorized personnel.
Disposal of Records
- Confidentiality: All records shall be disposed of in a manner that maintains confidentiality, including shredding of paper records and permanent deletion of electronic files.
- Approval: Before disposal, records should be reviewed by the designated officer (e.g., Board Secretary or President) to ensure compliance with this policy.
- Documentation: A record of disposed documents should be maintained, noting the type of document and disposal date.
Legal Holds
In the event of litigation, government investigations, or audits, any relevant records must be retained until the hold is lifted. All Board members, officers, and staff will be notified of such a hold, and any scheduled disposal will be suspended.
Policy Compliance
All BCFA Board of Trustees members, officers, employees, and volunteers are responsible for adhering to this policy. Non-compliance may result in disciplinary action, as outlined in BCFA’s governance policies.
Policy Review and Amendments
This Records Retention Policy shall be reviewed every three years or as necessary to ensure compliance with applicable laws and best practices. Amendments to this policy require a majority vote by the Board of Trustees.