Document Retention Policy
First State Educate (FSE) Document Retention and Destruction Policy (2025)
Approved September 21, 2025
Purpose
First State Educate (“FSE”) is committed to responsible recordkeeping that complies with legal, regulatory, and operational requirements. This policy establishes standards for the retention, protection, and proper disposal of documents to ensure transparency, accountability, and efficiency.
Scope
This policy applies to all documents, records, and files created, received, or maintained by FSE in any format, including paper, electronic, audio, and video. It applies to board members, officers, employees, interns, contractors, and volunteers (“Covered Persons”) who handle FSE records.
General Principles
FSE will retain documents for the periods required by law, contract, or operational necessity.
Records may be stored in paper or electronic form, provided that they are secure, accessible, and reproducible.
At the end of the retention period, records will be destroyed in a secure manner, unless subject to a legal hold.
No one may destroy, alter, or conceal documents relevant to an actual or anticipated government investigation, litigation, or audit.
Retention Schedule
The following categories set minimum retention periods: Electronic Records (email, digital files): same retention as paper equivalent
Permanent
Governing Records (Articles of Incorporation, Bylaws, Board minutes, IRS determination letters)
Tax Returns (IRS Form 990 and supporting documents)
Insurance Claims Related Records
Seven Years
Financial Statements & Audits: 7 years
Insurance Policies: 7 years after expiration (claims-related records: permanent)
Board and Committee Materials (agendas, packets, policies):
Accounts Payable/Receivable Ledgers, Invoices, Expense Reports:
Payroll Records:
Grant Agreements and Reports: 7 years after completion
Donor Records and Acknowledgments:
Contracts and Leases: 7 years after expiration
Personnel Records: 7 years after separation
Administration
The Executive Director is responsible for overseeing this policy and ensuring compliance.
Staff and volunteers are expected to follow retention practices relevant to their roles.
Secure destruction methods (e.g., shredding, permanent deletion) will be used to dispose of records.
Legal Holds
If litigation, government inquiry, or audit is pending or reasonably anticipated, all relevant records must be preserved until the legal hold is lifted, regardless of the retention schedule.
Review
This policy will be reviewed periodically by the Board of Directors and updated as needed to reflect legal or operational changes.