Record retention schedule and destruction log

Your document retention and destruction policy is the board-approved rule: who's responsible, how records are destroyed, and the "stop everything" rule when a legal matter comes up. This template is the working tool that goes with it. It's a table of the records your charity actually has, where each one lives, who looks after it, how long you keep it, and when it was last reviewed, plus a log of what you destroy and a list of anything on hold.

Fill it in once, then check it each year. Our guide to organizing files and records helps you set up the folders this schedule points to.

Where the minimum periods come from

The schedule includes the federal minimums we could confirm on agency pages. Many records have no federal rule at all, so the period you choose is a decision for your board, guided by your accountant, insurer, funders and lawyer.

• Tax records. The IRS says to keep records for 3 years in most cases, with longer periods in some situations (for example, 6 years if income that should have been reported, and was more than 25% of the gross income shown, was left off, and indefinitely if no return was filed or a return was fraudulent). It also says to keep employment tax records "for at least 4 years after the date that the tax becomes due or is paid, whichever is later," and to keep property records until the period of limitations expires for the year you dispose of the property.
• Not only tax. The IRS adds that before you throw away records you no longer need for tax purposes, you should check whether you need them for other purposes. Insurers and creditors, for example, may require you to keep them longer.
• Payroll and time records. The Department of Labor's Fact Sheet #21 says employers must keep payroll records for at least three years, and records on which wage computations are based, such as time cards and work schedules, for two years.
• Form I-9. USCIS says to keep a Form I-9 for each person you hire for three years after the date of hire, or one year after employment ends, whichever is later, and to be able to show them within three business days of an inspection request.
• Personnel records. The EEOC says employers covered by federal anti-discrimination laws must keep all personnel or employment records for one year, and, for an involuntary termination, for one year from the date of termination. If a charge of discrimination is filed, keep the relevant records until the charge and any lawsuit are finally resolved.

Where a federal minimum is shorter than your policy's period, follow your policy. Where your state, a grant agreement, a lease or an insurance policy requires longer, follow the longest rule.

How to fill it in

• List what you really have. Walk through your shared drive, email, donor database, accounting system, payroll provider and any paper files. Add rows for anything missing; delete rows you don't need.
• Name an owner for each row, usually a role (Treasurer, Secretary, Volunteer Coordinator), not a person, so it survives people leaving.
• Write the trigger. "7 years" means nothing without a start date. Say "7 years after the end of the fiscal year," "4 years after the tax is due or paid," or "3 years after the grant closes."
• Mark legal holds. If a lawsuit, audit, investigation or complaint is possible, nothing related is destroyed until the hold is lifted, whatever the schedule says.
• Review it every year, ideally at the same time as your Form 990, and log what you destroy.