Document Destruction
The Document Retention and Destruction Policy identifies the record retention responsibilities of NFID staff, volunteers, members of the Board of Directors, and others for maintaining and documenting the storage and destruction of NFID documents and records.
NFID staff, volunteers, members of the Board of Directors, committee members, and others (independent contractors via agreements) are required to comply with this Policy and honor the following rules:
a. Paper or electronic documents indicated under the terms for retention in the following sections will be transferred and maintained by appropriate staff;
b. All other documents may be deleted from all individual computers, databases, networks, back-up storage, and paper files after 1 year;
c. No paper or electronic documents will be destroyed or deleted if pertinent to any ongoing or anticipated government investigation or proceeding or private litigation (check with legal counsel or NFID management for any current or foreseen litigation if employees have not been notified); and
d. No paper or electronic documents will be destroyed or deleted as required to comply with government auditing standards.
e. The unauthorized alteration, use or disclosure of a Record is prohibited. Anyone who falsifies or inappropriately alters a Record, or removes, uses, or discloses a Record without authorization may face disciplinary action, up to and including termination of employment.
f. All Records remain the property of NFID and may not be taken upon termination of employment.
g. Confidential Records will be securely maintained, controlled, and protected to prevent unauthorized access or disclosure. Unauthorized use or disclosure of a confidential Record may result in disciplinary action, up to and including termination of employment.
h. The appropriate method of destruction depends on the Record’s physical form or medium and subject matter or content. Destroyed Records should not be placed in unsecured trash or recycling receptacles. Paper Records shall be redacted or shredded and electronic Records shall be destroyed or erased.
Failure to comply with this Policy may subject NFID and individuals representing the organization to serious civil and/or criminal liability. Failure of staff to comply with this Policy may result in disciplinary action, up to and including termination. NFID is committed to enforcing this Policy as it applies to all forms of Records. Any violations should be reported immediately to NFID leadership. NFID prohibits any form of discipline, reprisal, intimidation, or retaliation for reporting incidents of inappropriate conduct of any kind, pursuing any Record destruction claim, or cooperating in related investigations.
Definitions
a. Records. Any type of information created, received or transmitted in the ordinary course of NFID business, regardless of physical format or medium, including, but not limited to, documents, correspondence, meeting minutes, memos, reports, contracts, receipts, requisitions, invoices, general ledgers, financial statements, blueprints, charts, maps, drawings, presentation slides, photographs, website pages, audio or video recordings. and microfilm. Records do not include materials or information that does not have value to NFID or is short-lived (such as informal personal notes, or publications, trade journals, or magazines not issued or distributed by NFID). Such materials do not constitute Records, are not covered by this Policy, and should be routinely discarded when their usefulness has terminated.
b. Electronic Records. Electronic documents shall be either printed and stored as tangible evidence or downloaded to a computer file and kept electronically or on a disk as a separate file.
c. E-mail. E-mail is a system of communication, not a records management system in its own right. E-mail messages (and any attachments) should be reviewed to determine if it contains significant business or legal value that warrants retention. If the email would qualify as a Record in paper form, then the e-mail (and any attachment) should be retained for the applicable retention period, either in paper form or an electronically approved manner. Senders and receivers of e-mail messages should each determine whether an e-mail qualifies as a Record and, accordingly, whether to save or delete an e-mail that does not qualify as a Record.
d. Investigations. It is illegal for any person to knowingly alter, destroy, mutilate, conceal, cover up, or falsify any Record with the intent to impede, obstruct, or influence the investigation or administration of any matter within the jurisdiction of a federal or State department or agency or any bankruptcy proceeding. Staff who are advised by NFID leadership of an investigation or audit or who independently learn of one, must immediately segregate the Record in question and must not, under any circumstances, alter, destroy, mutilate, or falsify the Record.
e. Original Record. A Record generally consists of a single copy. Duplicate copies of Records created for short-term reference should be discarded after they are of no further use.
Record Retention
The following table* indicates the minimum requirements and is provided as guidance. In addition, federal awards and other government grants may provide for a longer period than is required by other statutory requirements.
Continuing Medical Education (CME) Documentation
The following statements serve as guidelines for the retention of files (paper and electronic) related to CME activities, as prescribed by the Accreditation Council for Continuing Medical Education (ACCME).
Attendance/Participation Records: NFID must be able to verify participation of attendees of NFID-accredited education activities for 6 years from the date of the activity. To meet this requirement, NFID requires that a final registration list and any other attendance or registration documentation is saved for a period of 6 years from the date of the activity.
Activity Documentation: Activity files and records must be retained for all continuing education activities conducted during the current accreditation period or for the preceding 12 months, whichever is longer. NFID is accountable for any complaints or inquiries received by the ACCME about an NFID activity for 12 months from the date of the activity.
*Adapted from National Council of Nonprofits
Updated December 2024