Winrock’s business “Records” are assets of Winrock and must be managed properly to preserve their value and to protect Winrock from risks associated with improper records management. Examples of business Records can be found in the Retention Schedule table. This policy addresses the management, storage, retention, and destruction of Winrock Records. It applies to all employees and all Records, no matter where the Records are located (including, without limitation, on devices owned by Winrock employees) or how they are stored (e.g., paper vs. electronic form). Unless expressly stated otherwise in this Policy, Records shall be managed according to their content, not the form in which they were created or stored. 

Winrock is committed to effective records retention to preserve its history, ensure that critical records are available to meet organization needs, comply with legal requirements, optimize the use of space, minimize the cost of record retention, and ensure that outdated and useless records are destroyed.

This Policy also states Winrock employee’s obligations in retaining records, including but not limited to: paper records, photographs, sound or video recordings, emails, word processor documents, spreadsheets, databases, HTML documents, scanned or imaged documents, and any other type of file warehoused online or on the cloud, on a mainframe, server, computer hard drive or any external storage medium.        

Implementation

Each department and project will review this policy periodically to determine any special circumstances that necessitate changes in the retention periods. Request for changes in retention periods or deviations from specified retention duration should be made to the Chief Risk and Compliance Officer.

In addition, each department and project will ensure its staff are fully informed of this policy and confirm that they agree to comply with it. Employees will conduct periodic reviews of all Records, including text/formatted files (e.g., Microsoft Word documents) and will purge all those they consider unnecessary or outdated.  Each department and project will use an indexing system to ensure timely and convenient access to Records.

In accordance with the Retention Schedule, after three years, all text files not marked for retention (such as “Permanent”) will be purged from the network and repositories/collaboration sites by the IT Department. Text/formatted files the staff deems vital to the performance of their job should be stored in a folder marked “Permanent” to avoid routine destruction.

Applicability

This policy applies to all Winrock business records, including but not limited to: paper records, photographs, sound or video recordings, emails, word processor documents, spreadsheets, databases, HTML documents, scanned or imaged documents, and any other type of file warehoused online or on the cloud, on a mainframe, server, computer hard drive, or any external storage medium.

To the extent that there are multiple copies of records in electronic form, only one copy of each record needs to be retained. Likewise, if there are multiple drafts of a particular record, only the final record needs to be retained.

Original paper Records may be imaged so long as the image is accurate, remains readable, preserves the integrity of the Records, including but limited to signatures, writing, and or graphic images, and is reliable and secure against alteration.  Original paper Records that are imaged must be retained for one year to permit periodic validation and quality control reviews.

General Rule

Generally, Records should be destroyed as soon as possible after they no longer serve a business purpose, unless (1) the Record is specified on the Retention Period Schedule, in which case the Record should be maintained per that retention period; or (2) the Record falls into one of the three exceptions. To serve a business purpose, a Record must be actively used, and for a specific purpose; keeping Records merely because the Records may come in handy, when there is no clear reason for retaining them, is not appropriate. Drafts (non-final versions of Records) should be destroyed as soon as reasonably possible once the Record is finalized and the drafts no longer serve a business purpose.

Exceptions to the business need rule are if the Record:

  1. Is subject to a Legal Hold
  2. Must be retained to satisfy a contractual obligation or other notice by an awarding agency
  3. Must be retained to comply with applicable law

Destruction

Subject to the exceptions, retained Records shall be destroyed after expiration of the business need, or applicable retention period set forth in the Retention Schedule. IT will purge Records from the network as noted, above, in accordance with the Schedule, with approval from the CFO for financial Records. Records containing sensitive information should be disposed of in a manner that makes them unreadable (e.g., shredding paper records or disposing of them in approved containers, using secure deletion software for electronic records stored on magnetic media).

For retention periods, refer to the Retention Schedule posted on Winshare.

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