These policies cover all records regardless of physical form or characteristics which have been made or received by the Local Journalism Foundation (LJF) while doing business. 

I. Purpose of Policies 

These policies provide for the systematic review, retention and destruction of records received or created by the LJF in connection with the transaction of business. These policies cover all records, regardless of physical form, contain guidelines for how long certain records should be kept and how records should be destroyed. These policies are designed to ensure compliance with federal and state laws and regulations, to eliminate accidental or innocent destruction of records and to facilitate The LJF’s operations by promoting efficiency and freeing up valuable storage space. Included in the federal laws necessitating compliance with these policies is the Sarbanes-Oxley Act ("The American Competitiveness and Corporate Accountability Act of 2002"), which makes it a crime to alter, cover up, falsify, or destroy any document with the intent of impeding or obstructing any official proceeding. 

II. Records Covered 

These policies apply to all records in any form, including electronic documents. A record is any material that contains information about LJF’s plans, results, policies, or performance. Anything that can be represented with words or numbers is a business record for purposes of these policies. Electronic documents must be retained as if they were paper documents. Therefore, any electronic files, including information received online, that fall into one of the document types on the schedule must be maintained for the appropriate amount of time. For example, if a user has sufficient reason to keep an email message, the message should be printed in hard copy and kept in the appropriate file or moved to an “archive or cloud” computer file folder. Backup and recovery methods will be tested on a regular basis.

III. Record Retention 

The Local Journalism Foundation follows the document retention procedures outlined below and includes documents listed in Appendix A. Documents that are not listed but are substantially similar to those listed in Appendix A will be retained for the appropriate length of time. 

A. Permanent Retention 

Permanent records—Permanent records are records required by law to be permanently retained and which are ineligible for destruction at any time for any reason. These records are necessary for the continuity of business and the protection of the rights and interests of the organization and of individuals. These include records such as organizational documents (Articles of Incorporation and Bylaws), Board minutes and policies, federal and state tax exempt status and independent audits. No record, whether or not referenced, may be destroyed if in any way the records refer to, concern, arise out of or in any other way are involved in pending or threatened litigation. 

B. Non-permanent Retention 

Non-permanent records—Certain records are not required by law to be permanently retained and may be destroyed after the passage of certain years or upon the passing of events as defined by these policies. No record, whether or not referenced, may be destroyed if in any way the records refer to, concern, arise out of or in any other way are involved in pending or threatened litigation. 

IV. Emergency Planning 

The Local Journalism Foundation’s records will be stored in a safe, secure and accessible manner. All documents and financial files that are essential to keeping the LJF operating in an emergency will be duplicated or backed up and maintained off site (physically or via “cloud”). All other documents and financial files will be duplicated or backed up periodically as identified by the Executive Director or other designated person and maintained off-site as stated above. 

VI. Document Destruction 

The Local Journalism’s Executive Director or other designated person 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 or claim, whichever is latest. 

VII. Compliance 

Failure on the part of employees to follow this policy can result in possible civil and criminal sanctions against the LJF and its employees and possible disciplinary action against responsible individuals. The Executive Director or designated individual and Finance Committee chair will periodically review these procedures with legal counsel or the organization’s certified public accountant to ensure that they are following new or revised regulations. 

Questions concerning these policies, the applicability of certain records to the retention or destruction policies, must be addressed to the Executive Director or other designated individual other way are involved in pending or threatened litigation.