Sample policy language can streamline the policy adoption process and is a good starting point. But it is never a good idea to simply insert your organization’s name and present the document to the board for approval. The policy MUST be discussed and tailored to reflect your organization’s culture and to conform to your other policies.

This sample policy is distributed with the understanding that Active Technologies, LLC is not engaged in rendering legal or accounting counsel. We urge you to seek professional services to address your specific concerns.

I. Purpose

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 Arts Organization in connection with the transaction of organization business. 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, to eliminate accidental or innocent destruction of records and to facilitate Arts Organization’s operations by promoting efficiency and freeing up valuable storage space.

II. Document Retention

Arts Organization follows the document retention procedures outlined below. Documents that are not listed, but are substantially similar to those listed in the schedule will be retained for the appropriate length of time.

III. Corporate Records

IV. 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.

V. Emergency Planning

Arts Organization’s records will be stored in a safe, secure and accessible manner. Documents and financial files that are essential to keeping Arts Organization operating in an emergency will be duplicated or backed up at least every week and maintained off site.

VI. Document Destruction

Arts Organization’s chief financial officer is responsible for the ongoing process of identifying its records, which have met the required retention period and overseeing their destruction. Destruction of financial and personnel-related documents will be accomplished by shredding.

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.

VII. Compliance

Failure on the part of employees to follow this policy can result in possible civil and criminal sanctions against Arts Organization and its employees and possible disciplinary action against responsible individuals. The chief financial officer and finance committee chair 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.