Policy/Procedure
Kalamazoo County Republican Committee (KGOP), herein known as the Party, records are a valuable asset. The Party is committed to the effective management and retention of its records as necessary to fulfill its education al mission, comply with legal requirements and preserve its history.
The purpose of this policy is to assist the organization in its efforts to:
- Comply with legal, contractual and accreditation requirements for the retention, privacy and security of records
- Retain records for which there is continuing administrative and/or operational need and establish mechanisms for ensuring the authenticity, reliability and usability of such records
- Destroy records no longer necessary to the operation of the Party in order to optimize the use of space, both physical and electronic, and minimize the cost of record storage
- Retain records that are valuable to the preservation of the party’s history
Definitions
Electronic Records
Any Party owned record that is created, received, maintained and/or stored on Party workstations, servers and system/service provider resource, both local and cloud based. As well as any record maintained in any non-paper format.
Examples of electronic records include, but are not limited to, email, Faculty, administrative or student personal documentation, spreadsheets, databases, videos, photographs and audio recordings.
Official Repository
The Party, committees, office, center or unit designated as having responsibility for retention and timely destruction of the party records subject to a required retention period.
Paper Record
Any Party record maintained in a hard copy paper format.
Preservation Notice
If the Party becomes involved in a legal action, a preservation notice may be issued by the Office of the General Counsel. A preservation notice compels the Party to retain any and all records that may be relevant to a legal action that has been filed. Sometimes referred to as a “litigation hold”, a preservation notice suspends normal record retention periods and requires that records be maintained and not altered from that point forward until the notice is removed.
Required Retention Period
The retention period set forth in the Party’s records retention schedule, Appendix A.
Party Record
Electronic and paper records, collectively.
Official Repository and Retention Periods
Appendix A to this Records Management and Retention Policy list the general types of Party records, the official repository of such records within the Party and the retention period for such records maintained by the official repository.
Once the retention expires, the covered record maintained by the official repository should be properly destroyed.
Federal and state laws, regulations and best practices require that the Party adhere to certain record retention requirements and periods of retention. The appropriate time periods for record retention are record specific and are subject to ongoing modification from time to time by government statute, judicial and administrative consent order, and private or government contract, pending litigation or audit requirements. Such modifications supersede the retention period for the applicable record stated in Appendix A. A temporary modification of a required retention period or suspension of record destruction required for any of these reasons will be accomplished by notification from the President’s Office, Office of the General Counsel the Provost Office and/or the Finance and Operations Division. No list of Party Records is exhaustive. Questions regarding the retention period for any specific Party record or category of records not included in Appendix A should be directed to the Office of the General Counsel.
Departmental Records Management
Each Party department should designate a records manager who is familiar with Records Management and Retention Policy, the Data Classification and Handling Policy and who assume responsibility for:
- Restricting access to sensitive records and information, as outlined in the Data Classification and Handling Policy, to those who need access to such records and information for the appropriate performance of their job responsibilities
- Information and educating staff within the department on the proper record management practices
- Coordinating the destruction of records as by provided by this policy
The Office of the General Counsel and the Director of Infrastructure Systems and Information Security are available to advise and assist individual departments to implement these requirements.
Safeguarding Records Containing Sensitive Information
Many Party records subject to record retention requirements contain sensitive information (non- public information including, but not limited to, name, address, social security number, bank account numbers, financial or financial aid information, student identification numbers, medical information, employment information, etc.). Such records are protected by federal and state statutes including the Family Educational Rights and Privacy Act (FERPA), the Gramm-Leach- Bliley Act (GLBA) the Health Insurance Portability and Accountability Act (HIPAA) and the EU General Data Protection Requirement (GDPR). Any record that contains sensitive information should also be treated in accordance with the Party’s Data Classification and Handling Policy.
The records manager of a department should ensure that active and inactive financial records (paper and electronic) are stored in a secure location. The storage location must provide appropriate confidentiality and protection from unauthorized inspection, theft, and physical damage due to a fire, water, natural disaster. The records manager should use sound judgment in restricting access to financial records.
Electronically Stored Information
The ease with which electronically stored information may be created and the number of places where such information may be stored requires that the Party manage its electronically stored information effectively, efficiently, and consistent with its legal obligations. System and service providers that maintain and process Party records must conform to the same retention periods and data classification and handing of Party records as outlined in the Party’s policies.
Disposal and Destruction of Records
If it is determined that, consistent with this Records Management and Retention Policy, it is appropriate to dispose of any records, they can be destroyed in one of the following ways:
- Recycle paper records that do not contain sensitive information
- Shred paper records that may contain paper records
- Erase or destroy electronically stored information. The Director of Infrastructure Systems and Information Security can advise and recommend solutions to effectively dispose of these records.
- Physical destroy audio or video media.
Party departments that are not official repositories of a Party record but must have access to and that retain duplicate or multiple copies of such records should dispose of them when there is no longer and administrative or operational need for such records.
| APPENDIX A | ||
| O = As Needed for Operations | ||
| Type of Record | Official Repository | Duration |
| COMMITTES | ||
| Executive Committee meeting minutes | Secretary of the Party | Permanent |
| Governance records (Bylaws, Charter, etc.) | Secretary of the Party | Permanent |
| COMPLIANCE AND ENTERPRISE RISK MANAGEMENT | ||
| Accident/Accident Reports | Compliance and Enterprise Risk Management | 5 years |
| Fire Incident Reports | Compliance and Enterprise Risk Management | 5 years |
| Safety Incident Investigation Reports | Compliance and Enterprise Risk Management | 5 years |
| Certificates of Insurance | Compliance and Enterprise Risk Management | 5 years |
| Indemnifications Agreements | Compliance and Enterprise Risk Management | Permanent |
| Insurance Policies | Compliance and Enterprise Risk Management | Permanent |
| DEVELOPMENT | ||
| Annual Fund Reports | Development | Permanent |
| Call Reports | Development | O |
| Capital Campaign Records | Development | Permanent |
| Cash Gift Records | Development | Permanent |
| Endowment Agreements | Development | Permanent |
| Planned Gift Agreements | Development | Permanent |
| Pledges | Development | Permanent |
| Wills/Bequests | Development | Permanent |
| FACILITIES MANAGEMENT | ||
| Building/Site Plan Specifications | Facilities Management | Permanent |
| Building/Zoning Permits | Facilities Management | Permanent |
| Capital Construction Materials Info/Correspondence | Facilities Management | Permanent |
| Capital Construction Project Information | Facilities Management | Permanent |
| Maintenance Records | Facilities Management | 10 years |
| Operating Permits (i.e. elevators) | Facilities Management | 10 years |
| Volunteers | ||
| Volunteer Records | Volunteer / Membership | 7 years |
| Membership Records | Volunteer / Membership | 7 years |
| FINANCE AND ADMINSTRATION | ||
| Subsidiary ledgers (accounts payable, accounts receivable, etc.) | Treasurer | 7 years |
| Bank records, including deposits and withdrawal records | Treasurer | 7 years |
| Annual financial reports | Treasurer | Permanent |
| Bond documents | Treasurer | Permanent |
| Donor records | Treasurer | Permanent |
| Investment records and reconciliations | Treasurer | 7 years |
| Procurement card applications, authorizations | Treasurer | 3 years after account closure |
| Procurement card records | Treasurer | 9 years |
| Travel reimbursement documentation | Treasurer | 9 years |
| Depreciation records | Treasurer | life of asset |
| Information returns filed with federal, state and local authorities (Merts, W-2, 1099, 1042-S, etc.) | Treasurer | 7 years |
| Audit reports | Treasurer | Permanent |
| Charitable solicitation registrations and annual returns | Treasurer | 7 years |
| Fringe benefits (taxable) supporting documentation | Treasurer | 9 years |
| Income tax returns (990, 990-T, state returns, etc.) | Treasurer | Permanent | ||||
| Benefit plan audits (F/S, 990, 5500) | Treasurer | Permanent | ||||
| Sales and use tax returns | Treasurer | 7 years | ||||
| Tax exemption documentation – IRS determination letter, state exemptions, etc. | Treasurer | 9 years | ||||
| Accounts receivable statements | Membership | 7 years | ||||
| Billing records | Membership | 7 years | ||||
| Timesheets | Membership | 9 years | ||||
| Planning and budget minutes/documents | Planning and Budget | Permanent | ||||
| Budget to actual projections | Planning and Budget | 15 years | ||||
| Budget work files | Planning and Budget | 15 years | ||||
| GENERAL COUNSEL | ||||||
| Contracts | Office of the General Counsel | Length of contract + 7 years | ||||
| Litigation files/claims | 10 years from termination of litigation | |||||
| Opinion letters | 10 years | |||||
| Policy documents | Permanent | |||||
| Member/Volunteer settlement & benefits documents | 7 years after the benefits period outlined in the agreement has ceased or 50 years total | |||||
| Waivers and other release of liability forms | 4 years after signed or, in the case of a minor, 4 years after 18th birthday | |||||
| INFORMATION SERVICES | ||
| Network access and account | Infrastructure Systems | Disabled 1st day of the following month of end of employment. Deleted at the close of the fiscal year |
| Infrastructure Systems | 4 Years | |
| Backup Tapes | Infrastructure Systems | 10 years |
Responsible Person/Office: General Counsel / Chair
Date: March 1, 2023
Effective Date: March 1, 2023
Last Amended Date: June 26, 2023
Next Review Date: January 1, 2024