1. Purpose

This policy provides for the systematic review, retention, and destruction of documents received or created by the Junior League of Cleveland (JLC) in connection with the transaction for JLC’s business. This policy covers all records and documents, regardless of physical form, contains guidelines for how long certain documents should be kept and how records should be destroyed. The policy is designed to ensure compliance with federal and state laws and regulations, to eliminate accidental or innocent destruction of records and to facilitate JLC’s operations by promoting efficiency and freeing up valuable storage space.

1. Document Retention

JLC follows the document retention procedures outlined below. Documents that are not listed but are substantially similar to those listed in the schedule, will be retained for the appropriate length of time.

• Corporate Records

Refer to Appendix A

1. Glossary of Terms
   1. Board and Board Committee Materials – Meeting minutes should be retained in perpetuity in the JLC’s records.
   2. Fundraiser – A fundraiser for charitable purposes must maintain during each solicitation campaign, and for not less than 10 years following the completion of each solicitation campaign, records including any electronic records, containing information regarding:
      1. The date and amount of each contribution received as a result of the solicitation campaign and, for non-cash contributions, the name and mailing address of each contributor.
      2. The name and residence address of each employee, agent or other person involved in the solicitation campaign.

• Records of all revenue received, and expenses incurred in the course of the solicitation campaign.

1. For each account into which the fundraiser deposited revenue from the solicitation campaign, the account number and the name and location of the bank or other financial institution in which the account was maintained.
   1. If fundraiser sells tickets to events and represents that they will be donated for use by another, then he or she must keep the number of tickets purchased and donated by each contributor, name address or all orgs receiving donated tickets.
2. Contracts – Final, executed copies of all contracts entered into by the JLC should be retained. JLC should retain copies of the final contracts for at least seven years beyond the life of the agreement, and longer in the case of publicly filed contracts.
3. Development/Intellectual Property and Trade Secrets – Development documents are often subject to intellectual property protection in their final form (e.g., patents and copyrights). The documents detailing the development process are often also of value to JLC and are protected as a trade secret where JLC:
   1. Derives independent economic value from the secrecy of the information; and
   2. JLC has taken affirmative steps to keep the information confidential.

• JLC should keep all documents designated as containing trade secret information for at least the life of the trade secret.

1. Legal Files – Legal counsel should be consulted to determine the retention period of particular documents, but legal documents should generally be maintained for a period of ten years.
2. Personnel Records – State and federal statutes require the Company to keep certain recruitment, employment, and personnel information. JLC should also keep personnel files that reflect performance reviews and any complaints brought against JLC or individual employees under applicable state and federal statutes. JLC should also keep all final memoranda and correspondence reflection performance review and actions taken by or against personnel in the employee’s personnel file. Personnel records should be retained for seven years.
3. Press Releases/Public Filings – JLC should retain permanent copies of all press releases and publicly filed documents under the theory that JLC should have its own copy to test the accuracy of any document a member of the public can theoretically produce against JLC.
4. Tax Records – Tax records include, but may not be limited to, documents concerning payroll, expenses, proof of deductions, business costs, accounting procedures, and other documents concerning JLC’s revenues. Tax records should be retained permanently. Payroll tax returns can be retained for only seven years.

1. Electronic Documents and Records

Electronic documents will be retained as if they were paper documents. Therefore, any electronic files, including records of donations made online, that fall into one of the document types on the above schedule will be maintained for the appropriate amount of time. If a user has sufficient reason to keep an email message, the message moved to an “archive” computer file folder. Backup and recovery methods should be tested on a regular basis.

1. Emergency Planning

JLC’s records will be stored in a safe, secure, and accessible manner. Documents and financial files that are essential to keeping JLC operating in an emergency should be backed up at least every week and maintained off site.

• Document Destruction

JLC’s Treasurer is responsible for the ongoing process of identifying its records, which have met the required retention period and overseeing their destruction. Destruction of financial and personnel-related documents will be accomplished by shredding.

Document destruction will be suspended immediately, upon any ideation of an official investigation or when a lawsuit is filed or appears imminent. Destruction will be reinstated upon conclusion of the investigation.

• Compliance

Failure on the part of employees to follow this policy can result in possible civil and criminal sanctions against JLC and its employees and possible disciplinary action against responsible individuals. The Treasurer and finance committee chair will periodically review these procedures with legal counsel or the JLC’s certified public accountant to ensure that they are in compliance with new or revised regulations.

Appendix A