Record Retention Policy Guidelines for record retention June 30, 2015 5420 Old Orchard Road Skokie, Illinois 60077-1083 847.966.6200 Fax 847.966.9781 www.cement.org
Purpose 1. Ensure that the Records (as defined below) of the Portland Cement Association (PCA) are maintained and protected in accordance with applicable laws and in support of the interests of PCA and of the cement and concrete industries, and that Records no longer required are disposed of appropriately. 2. Provide uniformity in PCA practices of filing, retaining, and discarding written and electronic records and other materials. Definition of Record 1. A Record is any recorded information or document, regardless of its format or the storage media upon which it has been recorded, that is created, received, or maintained as information in conducting business. 2. Examples of records include: Official Records Employment Records Policies and procedures Contracts Minutes of meetings of the Board, committees, councils, subcommittees, and task groups Budgets Reports and presentations Electronic mail and related files Reference materials Historical documents and artifacts Voicemail 3. A Record may be used as evidence in a legal proceeding and PCA may be compelled as part of such a proceeding to produce Records. 4. Records may be contained in physical containers (boxes, cabinets, etc.) or electronic devices. Removal or disposal of such containers and devices may constitute disposal of Records and shall in such cases be subject to this Policy. 2
Official Records 1. An Official Record is a complete (final) and authoritative record of business activity whose retention is required for legal or business reasons. 2. Official records provide documentation of PCA s organization, business activities, decisions, procedures, operations, and internal or external transactions. 3. The Records deemed by PCA to be Official Records are explicitly defined by PCA. Records presently deemed to be Official Records are listed in the retention schedule at the end of this document. 4. Official records are not to be stored on removable storage devices such as CDs, floppy or zip disks, or USB devices. References and Archives 1. References are Records in the form of books, journals, and other materials maintained by PCA as part of its responsibility to maintain a comprehensive library for its own use and as a resource to the cement and concrete industries. 2. Archives are Records and artifacts maintained by PCA as part of its responsibility to chronicle its own history and that of the cement and concrete industries. Unofficial Records 1. Unofficial Records are Records deemed by PCA not to be subject to any specific legal or business retention requirement. 2. Unofficial Records include, but are not limited to, drafts, duplicates, and convenience copies of official records and records used exclusively for reference purposes. 3. Unofficial Records should be disposed of as soon as they have fulfilled their business need. Record Disposal 1. Security Record disposal shall be conducted in a manner that preserves the security of personal, confidential, and business-sensitive information ("Controlled Information"). Disposal of hard copy Records containing Controlled Information shall be by physical shredding prior to leaving PCA's control. 3
Disposal of electronic Records containing Controlled Information shall be by use of specialized software designed to government standards that overwrites the Controlled Information. 2. Suspension of Record Disposal in Event of Audit, Investigation, or Litigation In the event of an official audit or investigation, or in response to litigation, the PCA President will consult with legal counsel regarding record disposal activities normally conducted under this policy. Following such consultation the PCA President may direct, in writing, that disposal of certain Records or types of Records be suspended immediately. Immediately upon such suspension being directed by the PCA President, no further disposal of the designated Records or types of Records shall be conducted anywhere within the PCA organization. Following any such suspension, Record disposal may be resumed only upon the written direction of the PCA President. General Guidelines 1. Specific Record retention periods are set forth in the Record Retention Schedule and are based upon applicable laws and regulations and upon PCA's business interests. Record types marked "" (Administrative Decision) in the Record Retention Schedule represent cases where the retention period is to be governed by normal business judgment. Retention periods for Record types marked "" shall be decided by the department director or officer responsible for retaining the Record in question. 2. The following general guidelines are provided for situations not clearly addressed in the Record Retention Schedule. Personnel and financial Records: Retain in accordance with State statutes and Federal laws and regulations. Records of Board and committee meetings: Retain final agendas and approved minutes permanently; all other documentation, including any unofficial meeting notes, should be discarded upon approval and distribution of final minutes. Records of engineering judgments or opinions rendered to outside parties: Retain as long as legal claims are permitted under the applicable statute of limitations. Technical: Files containing technical substantiation used to support or oppose criteria in the development of model building codes and referenced standards. The retention period is to be governed by normal business judgment. Many issues are recurring, 4
Retention Requirement: KEY TO ABBREVIATIONS AC AE AF AT OBS NR P SUP Discard after completion of project Discard after expiration Discard after fiscal year Discard after termination Discard when obsolete No minimum retention criteria Keep permanently Discard when superseded Authority for Disposition: CFR FLSA Administrative decision (based on business need) Code of Federal Regulations Fair Labor Standards Act 6
Record Type Retention Basis MINISTRATION General correspondence 3 years Administrative policies Work programs 3 years Documents related to industry responses and actions on 5 years public issues Testimony before public agencies and committees OBS COMMUNICATIONS Publications P (one copy) News releases 1 year Economic research reports 4 years Films, photographs OBS PowerPoint presentations OBS Newsletters 4 years CORPORATE AFFAIRS Annual Reports P Articles of Incorporation, P Bylaws Meeting Minutes: Board P Annual meeting of Members P Council & Committee P Subcommittee & Task Force 6 years Member company mailing lists SUP Membership presentations 3 years Registration (federal, state, local) AT 7
Record Type Retention Basis FINANCIAL Accounts payable 7 years IRS Accounts payable ledger 7 years IRS Accounts receivable ledger 7 years IRS Audit reports P P Budgets 5 years Capital asset records (after asset disposal) 7 years IRS Depreciation schedule, equipment and property 7 years IRS Expense accounts 7 years IRS Financial statements, audited P Financial statements, unaudited 7 years Insurance policies P Inventory records, equipment 7 years IRS Payroll checks 7 years FLSA State Payroll records 7 years FLSA State Requisitions, purchase orders, lease records AE Tax/exempt organization return data and related information P HUMAN RESOURCES Applications, changes, terminations (employees) 5 years, CFR Applications of persons not hired 3 years CFR Employee handbooks 5 years Employee contracts 10 years after contract termination Employee Records 7 years after termination CFR Employee safety Duration of employees job CFR records/accident reports tenure plus 30 years Family Medical Leave 3 years CFR documents Forms I-9 3 years after termination CFR Individualized employee medical records 30 years after termination CFR Insurance records (employee) As long as relevance to benefit entitlement determination is possible CFR 8
Record Type Retention Basis HUMAN RESOURCES (Continued) Job descriptions OBS or SUP CFR Timesheet records Length of employment CFR Benefit plan documents (such as plan amendments, summary plan descriptions, summary material modifications, summary annual reports, etc.) Plan-related documents filed with government (including work papers) Retirement plan and 401(k) plan participant records Other plan records plus 5 years P 7 years 10 years after death of participant or last payment 10 years after termination, claim denial, or final payment on claim CFR CFR LEGAL Copyright and trademark P registrations Lawsuits, other litigation 10 years Licenses P Property deeds P Patents and related data P LIBRARY Acquisition records 5 years Research papers, abstracts, OBS bibliographies, etc. Photographic Images OBS Any Records deemed Archival P OFFICE AND BUILDING SERVICES Maintenance and repairs 10 years (building) Maintenance and repairs 5 years (equipment) Postal & UPS 3 years, CFR 9
Record Type Retention Basis TECHNICAL Codes, specifications, standards, OBS or SUP recommended practices Special projects AC Technical service 5 years 10