NODA, as part of its day-to-day operations, and for the benefit of its members and others, creates, receives, and retains documents and records. This policy is intended to:
Provide staff and volunteers with procedures to follow with respect to the identification, retention, storage, and disposal of NODA records and documents created, received, maintained, or managed by NODA whether in hard copy or electronically stored (“Records”). The term “Records” does not include published information and other materials readily available to the public from sources other than NODA (e.g., newspapers, vendor brochures, and government regulations).
NODA is committed to the appropriate review, retention, and destruction of Records. Schedule A of this Policy, contains the time periods for which specific types of Records will be kept.
This policy is designed to:
- Ensure that all Records necessary for the conduct of NODA’s operations are available for as long as there is a reasonable need for them;
- Ensure that NODA complies with applicable federal and state legal requirements for retaining Records;
- Ensure that NODA complies with applicable University of Minnesota policy as outlined in the Memorandum of Understanding;
- Minimize the costs of Records retention including the costs of storage and retrieval of retained documents;
- Eliminate accidental or innocent destruction of Records; and
- Ensure that Records for which there is no operational or legal reason to continue to keep are disposed of in a proper manner.
When staff or volunteers create documents, they should bear in mind that such documents are: (i) subject to this Policy; (ii) are potentially eligible for disclosure if demanded by third parties during the course of administrative actions, litigation, or government investigations; and (iii) in the case of documents sent outside of NODA, are potentially subject to the record retention policies of any or all of the Records’ recipients and may be turned over by those recipients to other government agencies or private individuals in response to requests, court orders, or subpoenas directed at them.
Document Retention
NODA follows the document retention procedures outlined below:
- Records to be retained in our electronic information retention system will, in general, be those reflecting the final resolution or completion of the transaction, task, action, or issue, or the latest version of records from uncompleted transactions;
- Records not listed in Schedule A and records not substantially similar to documents listed in Schedule A, will be retained only for the period of their immediate or current use not to exceed one year;
- Records listed in Schedule A will be maintained for the length of time indicated, and Records that are not listed but are substantially similar to those listed in Schedule A, will be retained for the same amount of time as those listed in Schedule A, unless a longer period of retention is required due to a contractual or legal requirement; and
- No Records will be destroyed or deleted if pertinent to any ongoing governmental investigation or proceeding, or private litigation (if you have questions regarding this provision, contact NODA’s Executive Director).
- Volunteers who create Records through the course of their volunteer role will surrender control to a NODA staff member as soon as possible. Volunteer created Records are subject to this policy.
From time to time, staff may be required to determine whether Records in their care, custody, or control are still active and needed, or inactive and therefore eligible for retention/destruction pursuant to this Policy. Records are eligible for destruction once the applicable retention periods identified in Schedule A have lapsed. If the retention period has not lapsed or inactive records are still required for business use or subject to a records hold, then prior to their destruction they should continue to be retained for an appropriate length of time based on Schedule A and on their business use, and in the case of a records hold, for at least the duration of the hold. Staff and volunteers must not abuse this responsibility or conduct their activities in any manner that would violate the purpose of this Policy.
Hard Copy Records
Paper or hard copy Records being held for retention will be stored in the NODA storage facility. Whenever possible, hard copy Records will be digitized for safer storage and ease of access.
Electronic Records
Electronic Records will be retained as if they were paper documents. Any electronic files that are described in one of the Records types listed on Schedule A will be maintained for the required time period in the cloud-based storage system designated by NODA. An electronic reproduction of any document, if available, listed on Schedule A will replace a paper version of the document. Electronic Records should be in the cloud-based storage system and not stored locally on individual staff or volunteer computing hard drives. Any document not listed in Schedule A should default to a retention period of 7 years.
All Records stored in the cloud-based storage system will be backed up according to the procedures of the service provider engaged by NODA and the University of Minnesota. NODA will take reasonable steps to ensure appropriate systems are in place for data backup and recovery.
Document Destruction
The NODA Executive Director is responsible for the ongoing process of identifying Records that have met the required retention period, overseeing the destruction of Records when applicable, and appropriately documenting categories of Records identified for destruction in accordance with this Policy. Destruction of financial, personnel-related, and confidential documents will be accomplished by secured shredding.
Compliance
Failure on the part of staff and volunteers to follow this Policy can result in possible civil and criminal sanctions against NODA, its staff, and/or its Board of Directors. Those responsible for failure to follow this policy may be subject to disciplinary action. The record retention policy will be shared during the volunteer and staff onboarding process.
The NODA Executive Director may authorize longer retention periods than expressly provided in this Policy.
When this policy conflicts with federal, state, or other governmental regulation the retention period with the longer duration will be used.
When this policy conflicts with University of Minnesota policy the retention period with the longer duration will be used.
SCHEDULE A – Schedule of Records
| Corporate Documents | |
| Articles of Incorporation and Amendments | Permanent |
| Bylaws and Amendments | Permanent |
| Minutes of board meetings | Permanent |
| Minutes of committee meetings | Permanent |
| Committee reports | 5 Years |
| Resolutions of board and board committees | Permanent |
| Qualifications to do business | Permanent |
| Current policies and procedures | Permanent |
| Intellectual property records (trademarks, etc.) | Permanent |
| Named Gift and endowment fund records (including relating to establishment, investment, and use of donor-restricted funds) | Permanent |
| Independent contractor agreements | 7 Years from expiration of contract |
| Other contracts for services | 7 Years from expiration of contract |
| Sponsorship agreements | 7 Years from expiration of contract |
| Conflicts of interest disclosure records | Permanent |
| Membership Records | |
| Membership records (name, organization, and year) | Permanent |
| Membership records (all other data) | 7 Years from last activity |
| Event and Program Registration | Permanent |
| Event and Program Registration Form Data | 7 Years |
| Core Competency Course Completion | Permanent |
| Volunteer Application Materials (not elected/not appointed) | 1 Year |
| Volunteer Application Materials (appointed) | Permanent |
| Leadership Appointments and Elected Positions | Permanent |
| Member Disciplinary Reports, Findings & Actions | Permanent |
| Reports and Programs | |
| Annual report – state filings | Permanent |
| Annual report | 10 Years |
| External Review Reports | 3 years |
| Election results | Permanent |
| Survey reports and executive summaries | 5 Years |
| Program Evaluations | 5 Years |
| Program Locations and Dates | Permanent |
| Program Schedules & Offerings | 5 Years |
| Insurance | |
| Policies, certificates, and related records | Permanent |
| Claims, audits or adjustments | 7 Years after later of termination,retirement, or last claim final adjustment |
| Real Estate | |
| Purchase or lease records | Permanent |
| Insurance records | Permanent |
| Appraisals and blueprints | Permanent |
| Maintenance and repair records | 7 Years |
| Accounting | |
| Authorizations for expenditures | 3 Years |
| Cash batches and receipts | 3 Years |
| Bank records (including bank statements, bank deposit slips, canceled checks, and electronic fund transfer documents) | 7 Years |
| General ledgers | Permanent |
| Investment statements and reports | 7 Years |
| Budgets | 7 Years |
| Inventory records | 7 Years |
| Equipment records | 7 Years |
| Fixed asset records | 7 Years |
| Internal audits | 7 Years |
| Invoices (to members/customers and from vendors) | 7 Years |
| Donation Records | 7 Years |
| End-of-year financial statements | Permanent |
| Depreciation schedules | Permanent |
| Audit reports of accountants or auditors | Permanent |
| Policies and Procedures related to financial matters | 7 Years |
| Human Resources | |
| Employee accident records | 7 Years after separation of the employee from employment |
| Personnel Files including performance evaluations | 7 Years after separation of the employee from employment |
| Records relating to employment law charges | 7 Years after separation of the employee from employment |
| Internal complaints or compliance records | 7 Years after separation of the employee from employment |
| Form I-9 | 3 Years after separation of the employee from employment |
| Records relating to applicants not hired | 3 Years after separation of the employee from employment |
| Job postings / Advertisements | 3 Years after separation of the employee from employment |
| Garnishments | Permanent |
| Retirement and pension plan documents | Permanent |
| Employee Handbook | Permanent |
| Tax | |
| Tax and tax-exemption related records (Rulings, Returns, and IRS and state determination letters) | Permanent |
| Property tax records | Permanent |
| 1099 & W-9 Forms | 7 Years |
| Payroll tax records and related records | 7 Years |
| Unemployment compensation claims and records | 7 Years |
| W-2 and W-4 Forms | 7 Years |
| Work Product | |
| Website and user records | 3 Years |
| Publications (including newsletters and press releases) | 3 Years |
| Documents relating to products and services | 3 Years |
| Recorded Meetings | 3 Months |
| Litigation/Legal | |
| Letters or email denying liability | Permanent |
| Litigation work product | 7 Years from close of litigation |
| Materials subject to litigation hold | 7 Years from close of litigation or hold |
| Court orders, judgments, and settlements | Permanent |
| Arbitration and other binding agreements | Permanent |
| Memorandum of Agreement/Understanding | 7 years from expiration of agreement |
| Research & Publications | |
| IRB/Admin approval documents | 7 Years from completion |
| Research data | Permanent |
| Grant applications and agreements | 5 Years from completion |
| NODA Databank | 10 Years |
| NODA Needs Assessment | Permanent |
| JCOTR Issues | Permanent |
| Recorded Webinars | 1 Year |