Fulcrum Foundation Records Retention Policies
The Records Retention Schedule is a diocesan policy that lists all the records commonly maintained by archdiocesan parishes and describes how long they must be kept and what to do with them at the end of that period.
- It applies to records in all formats (paper, photographs, electronic files, etc.) and in all storage locations (including file cabinets, cloud storage, email servers, web applications, and mobile devices).
- The following guidelines are meant to help you understand how to apply retention policies to the records of your office or work area.
1. Orient Yourself
a) First familiarize yourself with how the retention schedule is organized. Records are grouped together by the administrative functions they relate to, not by the type/format of records (i.e., correspondence, reports) or by office or ministry creating them. For example, there are sections of the schedule devoted to financial administration, personnel management, liturgy, etc.
b) Each of these 15 functional areas is broken down into sub-categories to make it easier to find the exact policies that apply to the records you are looking up. From the example below, you can see that records produced through the Financial Administration function are divided into 7 sub-categories.
c) Policies relating to individual records series are found within these sub-categories.
Example: FINANCIAL ADMINISTRATION
- Accounting
- Authorization
- Banking
- Budget Development
- Development & Fundraising
- Payroll
- Tax
2. Match Records to the Appropriate Policy in the Schedule
a) Think about the records you have a question about in terms of the work function they relate to, and then match them to the closest sub-category within that area.
Example: Wondering how long to keep old time sheets? These have to do with paying employees (a financial activity), so you would first refer to the Financial Management section of the schedule. Drilling down a bit, which sub-category within the Financial section do they specifically pertain to? (ANSWER: Payroll)
b) Once you’ve identified the right section, scroll down to that part of the schedule until you find the correct record category ("series”). Don’t just rely on series titles though. In a lot of cases, you will need to read the series descriptions because often several types of related records have been grouped together into one series.
Example: Continuing from the example above, there are 5 types of payroll records listed in the schedule. Read through them, and you will find the last one is “Timecards.” Eureka!
c) Now refer to the retention period (how long to keep the records) and disposition policy (what to do with the records when they’ve expired) for that particular record series.
3. Understand the retention periods and disposition types
a) Retention periods have 2 parts. Think of them as the “trigger” and the “countdown.”
- The trigger, the first part, tells you when to start counting down to the expiration date. These are usually time-based (end of fiscal year; end of calendar year), but sometimes they’re event-based (sale of building, end of project, etc.).
- The second part of the retention period is the countdown. This just tells you how many years after the trigger you need to keep the records.
Examples:
- Fiscal year + 6 means retain for 6 years after the fiscal year in which record was created.
- Calendar year + 1 Retain for 1 year after the calendar year in which record was created.
b) Dispositions policies tell you what to do with the records after their retention period has expired. There are 5 disposition types for school records.
-
- Shred: Records contain private/sensitive information.
- Recycle: Records do not contain private/sensitive information.
- Delete: Means just that!
- Archives: Records have long-term value to the Archdiocese and need to be securely stored in your archives, whether physical or electronic.
- Archival Review: Consult someone in Chancery Archives to make a final determination.
There are no retention requirements for the following types of materials. These can be disposed of as soon as they have served their immediate purpose. Shred, recycle, or delete as appropriate.
Document Errors
- Incorrect versions of documents, forms, or reports that had to be recreated to correct errors in typing, data entry, spelling, grammar, or format
Drafts and Working Materials
- Preliminary or incomplete drafts that do not contain significant comments, approvals, or substantial changes that give insight into the development of the final version. Can be disposed of when a subsequent draft or finished records has been developed.
Duplicates
- Extra copies used only for reference or informational distribution
- Electronic documents which are used to produce a hard copy (official) version which is maintained in the hard copy files
- Email CCs (carbon copies) and BCCs (blind carbon copies) where you have been copied for informational purposes only and are not expected to take action yourself
External Materials
- Publications, promotional material, etc. from external sources once these have served their purpose.
Information or Forms Used to Create or Update another Record
- Will become obsolete once the update or data entry is validated.
- Includes paper forms where the data is entered into an electronic system, spreadsheet, or database.
Informal Communications or Notifications
- Can take many forms (e.g. email messages, chat messages in online collaboration tools, social media postings, facsimile [fax], voice/video message recordings).
- Acknowledgements, form-letter thank you notes
- Announcements of meetings or social events
- Answers to routine requests for information do not require administrative action or policy decisions
- Memos and postings that do not relate to the main purpose or responsibilities of an office
- Personal communications
- Requests to call someone
- Reservations, confirmations, itineraries
When litigation, an audit, or investigation occurs or is reasonably anticipated, a written notice (referred to as a “Litigation Hold Notice” or “Legal Hold”) will be issued to appropriate staff. All records, whether official records, information copies, working documents, or transitory records, potentially relevant to the matter must be retained until the Litigation Hold is terminated. The effect of this notice is to freeze or suspend the destruction or alteration of records, electronically stored information, and other materials identified in the notice.
Records relevant to the matter may not be destroyed – even if the retention period in this retention schedule has expired or expires during the Litigation Hold – until the action is resolved and a notice terminating the Hold has been issued. There are serious legal consequences for individuals that destroy or alter records under a Litigation Hold or know of a pending issue and do not halt destruction.
This is an at-a-glance tool to help staff, volunteers, and IT support quickly identify the permanent records of your organization. It is NOT a substitute for using the Fulcrum Foundation Records Retention Schedule, which describes retention and disposal requirements for all of your organization's records.
For more information, please refer to the Fulcrum Foundation Retention Schedule or contact a records manager at archives@seattlearch.org.
Board, Committee, Council & Lay Group Records
- Constitutions & bylaws
- Meeting agendas, minutes, handouts, surveys, and audio or video recordings.
Establishing Records
- Articles of incorporation
- Canonical appointments
- Decrees of establishment
- Power of attorney
Financial Records
- Audit Reports
- Bequests, Trusts, and Endowments
- Budgets, final
- General Ledgers
- Payroll Registers (predating the era of a centralized payroll system)
Legal Records
- Legal counsel’s advice and opinions
- Litigation work product files
Marketing Records - For programs, services, and events
- Advertisements
- Audio/Video recordings
- Brochures
- Catalogs
- Direct Mailings
- Films and presentations
- Fliers
- Logo designs
- Posters
- Print and digital Images
Publications & Memorabilia
- Anniversary books and videos
- Historical newspaper clippings
- Historical photographs
- Newsletters, bulletins, newspapers, periodicals, and mass mailings
- Websites (capture before major content change)
Personnel Files, Employees & Volunteers – May include, but not limited to the following:
- Academic transcripts
- Background Checks, positive criminal history results
- Confidentiality agreements
- Continuing education certificates
- Correspondence and memos
- Employee dispute resolution records (if employee is terminated)
- Employee policy agreements
- HIPAA training certificates
- Lay off/severance notification letter
- Letters of reference
- Pay rate/history
- Performance evaluations
- Personnel action forms
- Personnel status tracking records
- Resume/application materials
- Safe environment training proof of completion (before July 2015)
- Terminated employee checklist & supporting documentation
Policies, Guidelines, Procedures
- Final approved policy documents
Public Statements
- Press Releases
Records Destruction Certificates
- Records certifying the physical disposal/deletion of records that have completed their retention period.
Research & Planning Records
- Census data
- Annual Reports
- Surveys, studies, reports, & recommendations
Training Records
- Training materials, final version – (for workshops, classes, orientations, or seminars put on by the organization. May include, but not limited to course curricula and reference publications).
>Click here for a printable pdf copy of the current schedule<
The schedule is periodically updated, so please ensure you are using the most current version.
100 ADMINISTRATION, GENERAL
Records that document or support administration of the Fulcrum Foundation programs, offices, board, and events.
Series Number: FF100-05
Retention: Calendar year + 5 years, then arrange for appraisal by archives
Disposition: Archival Review
Series Number: FF100-10
Retention: Permanent (Obsolete or superseded, then arrange for transfer to archives)
Disposition: Archives
Records documenting the decisions and actions of consultative bodies within the Archdiocese.
May include, but not limited to: transcribed minutes, audio/video recordings, sign-in sheets, reports, administrative correspondence, adopted by-laws and mission statements, and attached reference material.
Series Number: FF100-15
Retention: Calendar year + 3 years, then arrange for appraisal by archives
Disposition: Archival Review
May include: promotional materials, event planning materials, prospective donor lists, photographs, and sample pledge cards and forms.
Series Number: FF100-20
Retention: End of campaign + 6 years
Disposition: Shred/Delete
Records documenting obligations with third parties under contracts, licenses, and other agreements not covered elsewhere on this schedule.
Series Number: FF100-25
Retention: Completion of contract + 6 years
Disposition: Shred/Delete
May include: thank you letters, donation worksheets, completed pledge cards, letters of intent, pledge reminders and general correspondence.
Series Number: FF100-30
Retention: Fiscal year + 6 years
Disposition: Shred/Delete
Series Number: FF100-35
Retention: Date of report + 6 years
Disposition: Shred/Delete
Includes: contact information, demographic information, educational and business information, how donators wish to be recognized, donation amount, history of gifts, attendance at activities, as well as other attributes relevant to the donator's relationship with the Archdiocese of Seattle.
Series Number: FF100-40
Retention: Fiscal year + 6 years or obsolete or superseded, whichever is longer
Disposition: Delete
May include, but not limited to: agendas, temporary use permits, invitations, attendance rosters, time and action plans, agendas, notifications, reservations, gifts, photographs, thank-you notes, talking points, promotional materials, and educational resources.
Series Number: FF100-45
Retention: Obsolete or superseded, then arrange for transfer to archives for appraisal
Disposition: Archival Review
May include, but not limited to: payments, enrollment records, contact information, attendance lists, and correspondence.
Series Number: FF100-50
Retention: End of event + 2 years
Disposition: Shred/Delete
Information received from external sources and is no longer needed for diocesan business.
Includes, but is not limited to:
- Catalogs, external reports, multi-media presentations (videos, CDs, DVDs, etc.);
- Informational copies, notices, bulletins, announcements;
Unsolicited information (junk mail, spam, advertisements, etc.).
Series Number: FF100-55
Retention: Obsolete or superseded
Disposition: Recycle/Delete
May include: editor comments, photographs, drafts, proofs, and advertisements.
Series Number: FF100-60
Retention: Obsolete or superseded, then arrange for appraisal of final published copy by archives
Disposition: Archival Review
Records of routine meeting such as departmental check-ins and office staff meetings.
Series Number: FF100-65
Retention: Current year + 2 years
Disposition: Shred/Delete
Records pertaining to the development, drafting, adoption, and amendment of policies, procedures, and guidelines for Chancery offices.
May include, but not limited to: final document as well as all related correspondence and substantial comments and drafts.
Series Number: FF100-70
Retention: Permanent (Obsolete or superseded, then transfer final copy to archives)
Disposition: Archives
Requests for information made by the public, parishes, and parishioners.
Series Number: FF100-75
Retention: Resolution of request + 3 years
Disposition: Shred/Delete
Collections of resources related to research done by departments or programs.
May include, but not limited to: correspondence, photographs, external and internal publications, biographical files, vendor catalogs, reports, external advertising and marketing information, legislation information, presentation preparation, document drafts, newspaper clippings, working files, and issue files.
Series Number: FF100-80
Retention: Review annually and retain until obsolete or superseded, then arrange for appraisal by archives
Disposition: Archival Review
Created by or on behalf of the Fulcrum Foundation.
Series Number: FF100-85
Retention: Obsolete or superseded, then arrange for appraisal by archive
Disposition: Archival Review
200 GRANTS AND SCHOLARSHIPS
The activity of awarding grants and scholarships to students, teachers, and schools.
Records pertaining awarded funds to the Fulcrum Foundation.
May include, but not limited to status updates, application materials, reports, information about the granting institution, and financial statements.
Series Number: FF200-05
Retention: End of grant period (and any subsequent renewal period) + 6 years
For denied grant applications: Calendar year + 1 year
Disposition: Shred/Delete
Includes: application and report of income and expenses.
Series Number: FF200-10
Retention: Grants issued: grant period + 6 years
Applications denied: calendar year + 1 year
Disposition: Shred/Delete
Include: project proposals, teacher's personnel information, statements of commitments, and budget proposals.
Series Number: FF200-15
Retention: Grants issued: grant period + 6 years
Applications denied: calendar year + 1 year
Disposition: Shred/Delete
Series Number: FF200-20
Retention: Grant period + 6 years
Disposition: Shred/Delete
Include: application forms, principal's authorizations, tax information, supplemental evidence, and evidence for special circumstances.
Series Number: FF200-25
Retention: Grants issued: grant period + 6 years
Applications denied: calendar year + 1 year
Disposition: Shred/Delete
300 FINANCIAL
The function of managing the foundation’s financial resources, obligations, and monetary infrastructure.
May include: deadline sheets, forecasts, calculations, revisions, schedules, salaries worksheets, notes, and correspondence.
Series Number: FF300-05
Retention: Obsolete or superseded
Disposition: Shred/Delete
May include: deadline sheets, forecasts, calculations, revisions, schedules, salaries worksheets, notes, and correspondence.
Series Number: FF300-10
Retention: Obsolete or superseded
Disposition: Shred/Delete
400 MARKETING MATERIALS
The activity of promoting programs and fundraising drives.
Records documenting permission for the school to use student images recorded during official school activities/events, by staff or students in an official capacity (e.g. school newspaper, annual staff, etc.).
Includes: annual student identification/class pictures taken by school-contracted photographer. Student images include, but are not limited to, photos, video, and audio recordings.
Series Number: FF400-05
Retention: Retain for 6 years after image/ recording no longer being used then Destroy.
Disposition: Shred/Delete
Series Number: FF400-10
Retention: Obsolete or superseded
Disposition: Shred/Delete
Series Number: FF400-15
Retention: Permanent (Obsolete or superseded, then arrange for transfer to Archives)
Disposition: Archives
Records regardless of format produced by the Fulcrum foundation for marketing or promotional purposes.
May include, but not limited to:
- Advertisements
- Brochures
- Manuals
- Catalogs
- Flyers
- Pamphlets
- Direct Mailings
- Posters
- Films and Presentations
- CD-ROMs
- Photographic Prints and Negatives
- Digital Photographs
- Audio/Video tape cassettes
Series Number: FF400-20
Retention: Obsolete or superseded, then arrange for appraisal by Archives
Disposition: Archival Review
May include, but not limited to: editor comments, photographs, drafts, proofs, and advertisements.
Series Number: FF400-25
Retention: Obsolete or superseded, then arrange for appraisal of final published copy by Archives
Disposition: Archival Review
Records documenting the publishing of online (internet and intranet) content.
Includes, but is not limited to:
- Requests/approvals to upload/update/remove content;
- Confirmations of content upload/update/removal;
- Point-in-time record of webpage/site (screenshot, snapshot, site map).
Series Number: FF400-30
Retention: Capture before major content change
Disposition: Archives
Extensive research has been done before assigning retention periods to diocesan records series in order to assure compliance with government regulations and best business practices. CCAS has used the following statues and/or acts as resources in creating this retention policy, even if the provisions of those statutes and acts do not apply.
• 29 C.F.R. § 1607.4 (RET); 29 C.F.R. § 1602.13 (NS) – Records as to racial or ethnic identity of employees. Employers may acquire the information necessary for completion of items 5 and 6 of Report EEO-1 either by visual surveys of the work force, or at their option, by the maintenance of post-employment records as to the identity of employees where the same is permitted by State law. In the latter case, however, the Commission recommends the maintenance of a permanent record as to the racial or ethnic identity of an individual for purpose of completing the report form only where the employer keeps such records separately from the employee's basic personnel form or other records available to those responsible for personnel decisions, e.g., as part of an automatic data processing system in the payroll department.
• 29 C.F.R. § 1620.32 (2 years) – Employer subject to The Equal Pay Act must maintain records to the payment of wages, wage rates, job evaluations, job descriptions, merit systems, seniority systems, and description of practices or matter explaining basis for wage differential between employees of
opposite sex.
• 29 C.F.R. § 1904.33 and § 1904.44
• ADEA 29 C.F.R. § 1627.3(b)(1) (CR+01) – Job applications, promotions, demotions, test papers, transfer records; Title VII of the Civil Rights Act §790(c); 29 C.F.R. § 1602.14.
• Civil Rights Act of 1964 (Title VII) 29 C.F.R. § 1602.7 (NS) – Copy of most recent EEO-1 report filed for each reporting unit must be retained at each such unit; 29 C.F.R. § 1607.4 (RET); 29 C.F.R. § 1602.13 (NS) – Records as to racial or ethnic identity of employees. Employers may acquire the information necessary for completion of items 5 and 6 of Report EEO-1 either by visual surveys of the work force, or at their option, by the maintenance of post-employment records as to the identity of employees where the same is permitted by State law. In the latter case, however, the Commission recommends the maintenance of a permanent record as to the racial or ethnic identity of an individual for purpose of completing the report form only where the employer keeps such records separately from the employee's basic personnel form or other records available to those responsible for personnel decisions, e.g., as part of an automatic data processing system in the payroll department.
• FMLA 29 C.F.R. § 825.500(b) (CR + 3) – Documents describing employee benefits or employer policies/practices concerning taking paid/unpaid leave.
• Immigration and Nationality Act 8 U.S.C.A. § 1342a; 8 C.F.R. § 274a.2(b)(2)(A), (B), (c)2 (3 years after hire date or one year after termination; whichever is later).
• RCW 4.16.080 (2) Limitation of action for EEO discrimination complaints is 3 years.
The ADA, Rehabilitation Act, Title VII of the Civil Rights Act, and ADEA require employers to keep all resumes and job applications on file for one year.
Because the ADEA further stipulates a two-year retention period for paperwork for individuals over the age of 40 (something that may be difficult to determine and is, of course, illegal to ask), retain all resumes and applications 2 years.
Version 1.0 | 06/07/2012 | Implemented Records Retention Schedule
Version 2.0 | 05/05/2014 | Annual Audit
Version 3.0 | 03/13/2015 | Annual Audit
Click here for a printable pdf copy of the current schedule.
The schedule is revised throughout the year so please ensure you are using the most current version.
Have questions?
Please contact us at archives@seattlearch.org
or call (206) 382-4352