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unrwa usa’s financial policies

Records Retention and Destruction Policy

UNRWA USA National Committee (“UNRWA USA”) takes seriously its obligations to preserve information relating to litigation, audits, and investigations.

The information listed in the retention schedule below is intended as a guideline and may not contain all the records the Organization may be required to keep in the future. Questions regarding the retention of documents not listed in this chart should be directed to the Executive Director.

From time to time, the Executive Director may issue a notice, known as a “legal hold,” suspending the destruction of records due to pending, threatened, or otherwise reasonably foreseeable litigation, audits, government investigations, or similar proceedings. No records specified in any legal hold may be destroyed, even if the scheduled destruction date has passed, until the legal hold is withdrawn in writing by the Executive Director.

File CategoryItemRetention Period
Corporate RecordsBylaws and Articles of IncorporationPermanent
 Corporate resolutionsPermanent
 Board and committee meeting agendas and minutesPermanent
 Conflict-of-interest disclosure forms4 years
Finance and AdministrationFinancial statements (audited)7 years
 Auditor management letters7 years
 Payroll records7 years
 Check register and checks7 years
 Bank deposits and statements7 years
 Chart of accounts7 years
 General ledgers and journals (includes bank reconciliations)7 years
 Investment performance reports7 years
 Equipment files and maintenance records7 years after disposition
 Contracts and agreements7 years after all obligations end
 Correspondence — general3 years
Insurance RecordsPolicies — occurrence typePermanent
 Policies — claims-made typePermanent
 Accident reports7 years
 Claims (after settlement)7 years
 Group disability records7 years after end of benefits
Real EstateLeases (expired)7 years after all obligations end
TaxIRS exemption determination and related correspondencePermanent
 IRS Form 990s7 years
 Charitable Organizations Registration Statements7 years
Human ResourcesEmployee personnel filesPermanent
 Retirement plan benefits (plan descriptions, plan documents)Permanent
 Employee handbooksPermanent
 Workers comp claims (after settlement)7 years
 Employee orientation and training materials7 years after use ends
 Employment applications3 years
 IRS Form I-9 (store separate from personnel file)Greater of 1 year after end of service, or three years
 Withholding tax statements7 years
TechnologySoftware licenses and support agreements7 years after all obligations end

Electronic Documents and Records

Electronic documents will be retained as if they were paper documents.

Therefore, any electronic files 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 e-mail message, the message should be printed in hard copy and kept in the appropriate file or moved to an “archive” computer file folder. Backup and recovery methods will be tested on a regular basis.

Emergency Planning

The Organization’s records will be stored in a safe, secure, and accessible manner. Documents and financial files that are essential to keeping the Organization operating in an emergency will be duplicated or backed up at least every week and maintained on-site.

Document Destruction

The Executive Director 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 indication 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 the Organization and its employees and possible disciplinary action against responsible individuals. The Executive Director will periodically review these procedures with legal counsel or the organization’s certified public accountant at least every two years and recommendations for amendments will be approved by the board.