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DOCUMENT RETENTION PROGRAM POLICY: SAMPLE 1..................................................................................2

DOCUMENT RETENTION PROGRAM POLICY: SAMPLE 2..................................................................................4

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 DOCUMENT RETENTION PROGRAM POLICY: SAMPLE 1

INTRODUCTION

All organizations should establish a companywide document retention policy to ensure that records are
maintained for a uniform period and to avoid the undue accumulation of documents that are no longer needed in
business operations. Auditing requirements, government regulations, and business and legal needs dictate that
certain records need to be kept for specific periods to reconstruct transactions. Periods for which particular
documents will be kept are prescribed in this policy manual.

It is management’s responsibility to route, distribute or otherwise make available this policy manual to employees
who are not directly provided with a copy. It is important that the retention periods prescribed in this policy manual
are adhered to so that noncompliance with this policy may be reflected in individual employee and system
reviews.

RETENTION PERIODS

Records must not be destroyed before the prescribed retention period has expired. Records must also not be
retained for longer than the prescribed times without first contacting the inactive file administrator (presently a
member of the facilities department in the corporate office). Each box sent to storage must have a destruction
date.

Retention periods are specified for original documents only unless otherwise specified. Duplicates of records
should generally be discarded after reading except when it is necessary to retain them for a specific purpose
supportive of current operations. If duplicates are retained, they should be discarded after they have served their
purpose, but in no event should they be saved longer than the retention period of the document category into
which they fall.

Data processing should be retained no longer than the periods prescribed for the source data and output data.

Retention periods are listed in years unless otherwise indicated. The following codes are also used throughout:
• P: This means permanent (25 years).
• PS: This means purpose served. Destroy after the record’s use is no longer required. “PS” generally means
that the record is for information only and can be discarded after a matter is resolved or it is no longer relevant
(e.g., records should not be kept after the issue, which generated it is inactive and in no event should they be
kept for more than one year.
• UTC: This means until IRS and relevant state close tax audit for the year in which the document was created
and the court appeals are exhausted. Documents with the code UTC should not be destroyed without the
consent of the tax department head.
• TA: This means the term of the agreement, contract, franchise, license, permit, or similar documents, or until
said document is replaced by a similar document.
• US: This means until superseded by a similar document or when the next draft is created.
• Plus: This means add the specified number of years to the retention period (e.g., TA+7 – Keep for the term of
the agreement plus seven years).

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 DEFINITIONS

The following definitions apply to the record retention program.

• Record: A record is any paper, letter, report, book, ledger, journal, photograph, microfilm, microfiche, map,
drawing, chart, card, magnetic tape or any other form of record, any copy or printout of these items generated
or received by the company during business.
“Personal” files or documents that pertain to personal or company business should not be kept in your office or
desk unless you can lock your office or desk.
• Active Record: A record is “active” if it is needed to evaluate or substantiate current ongoing business activity
or is required in legal or court action. Do not assign retention periods to active records.
• Inactive Record: A record is “inactive” if it is no longer needed to evaluate or substantiate current ongoing
business activity and is not required in legal or court action.
If an inactive record is reactivated (usually because of legal action), assign a new retention period beginning
with the final disposition of the activity causing the reactivation.

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 DOCUMENT RETENTION PROGRAM POLICY: SAMPLE 2

HOW TO USE THIS POLICY

A record will normally be kept in your department so long as it is active. Retention periods should be assigned to
records that are no longer active.

Documents that carry a permanent retention period should be either stored in the department or sent to the
inactive file administrator for safekeeping.

After a retention period is assigned for documents without permanent retention periods, put records with the same
retention periods in the same boxes.

EXCEPTIONS

Exceptions to this program will be made only after consultation with the legal department.

DISPOSAL

Records kept in files maintained in your office should have a destruction date listed on the tab of the file folder.
This should make compliance with this policy easier. When records reach the end of their retention period, they
should be promptly destroyed. When the destruction date arrives for records, destroy such records and note their
destruction date for future reference.

INVESTIGATIONS AND LAWSUITS

Destruction procedures should immediately cease with respect to documents that are the subject of a
governmental investigation or a lawsuit:
• Upon receipt of service of legal processes requiring production of documents
• Upon learning of a relevant government inquiry
• During voluntary cooperation with government authorities

The corporate secretary, in consultation with the company's legal counsel, has primary responsibility to promptly
notify all company managers of such events to ensure that a proper “hold” is placed on the destruction of any
such documents. If there is any question as to whether a particular document is, or should be, subject to a “hold”
designation, approval of the corporate secretary should be obtained prior to the destruction of any such
document.

PRIVILEGED AND OTHERWISE PROTECTED DOCUMENTS

(Company) is entitled legally to keep certain documents confidential, even against the powers of the court to
require disclosure. These documents are commonly referred to as privileged. (Company)'s policy is to maintain
the confidentiality of privileged documents.

There are several types of protections against disclosure, including the attorney-client privilege, the work-product
doctrine and, perhaps, the self-evaluation privilege. In general, the attorney-client privilege applies to confidential

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communications between a client (in this instance, the company) and its counsel. The work-product doctrine
usually will protect documents, which are prepared as part of litigation, or in anticipation of litigation, and which
reflect strategies and thought processes. The self-evaluation privilege may protect environmental compliance
audits and similar documents.

To maintain a document’s privilege, the rules, which define the privilege, should be observed without fail. One rule
common to all privileges requires that documents be kept confidential from third parties. If an otherwise privileged
document is shared with an outside party, the privilege is forever lost.

If you are the custodian of documents, which are or might be privileged, please ensure to:
• Notify the legal department.
• Ensure that the documents are segregated in your files and marked as confidential.

The legal department will work with you to identify the privileges applicable and the detailed rules that should be
followed to make sure privileges are maintained.

INFORMATION COPIES OF DOCUMENTS FROM OTHER DEPARTMENTS

To maintain the confidentiality of our documents, information documents should be distributed only to those with a
“need to know.” Copies of information sent to your department by another department should be kept only if
needed for work papers then destroyed but in no event kept longer than 90 days.

WORK FILES

Work files may be maintained so long as a matter is pending. Once a matter is concluded, documents contained
in a work file can likely be categorized and retained in accordance with prescribed periods outlined in this policy
manual. You should distribute documents to proper individuals or corporate departments for inclusion in the
proper file(s). Documents left “without a home” should be destroyed.

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