Document Retention and Destruction Policy Draft

I — Purpose

This Document Retention and Destruction Policy establishes guidelines for the retention and destruction of documents and records of Access100 (the “Corporation”). Proper document retention is essential for legal compliance, efficient operations, and protection of the Corporation’s interests.

II — Scope

This policy applies to all documents and records created, received, or maintained by the Corporation, whether in paper or electronic form. This includes, but is not limited to, correspondence, financial records, contracts, meeting minutes, personnel files, and electronic communications.

III — General Guidelines

A. Document Creation and Maintenance: All documents should be clearly dated and organized for easy retrieval. The Corporation shall maintain a systematic filing system for both physical and electronic documents.

B. Original Documents: Original documents should be retained where required by law or where they have significant legal or historical value. High-quality copies may be substituted for originals in other cases.

C. Electronic Records: Electronic documents are subject to the same retention requirements as paper documents. Regular backups of electronic records should be maintained.

D. Confidentiality: All documents containing sensitive or confidential information must be stored securely and destroyed in a manner that ensures confidentiality.

IV — Document Retention Schedule

The following table outlines the minimum retention periods for various categories of documents. Documents should be retained for the longer of the period specified or any period required by applicable law.

V — Document Destruction

A. Destruction Schedule: Documents that have met their retention period and are not subject to a litigation hold may be destroyed. The Corporation shall conduct document destruction on an annual basis.

B. Methods of Destruction: Documents containing confidential or sensitive information must be shredded or otherwise destroyed in a manner that prevents reconstruction. Electronic records must be permanently deleted or destroyed.

C. Documentation: A log of destroyed documents shall be maintained, including the document type, date range covered, and date of destruction.

VI — Litigation Hold

A. When to Implement: When litigation, a government investigation, or an audit is pending, threatened, or reasonably anticipated, a litigation hold must be implemented. This suspends all document destruction that may be relevant to the matter.

B. Responsibility: The Chair of the Board or designated officer is responsible for issuing litigation holds and ensuring compliance.

C. Scope: The litigation hold shall specify the types of documents to be preserved and shall be communicated to all relevant individuals.

D. Duration: The litigation hold shall remain in effect until the matter is resolved and the hold is formally lifted by the Chair or designated officer.

VII — Responsibilities

A. Board of Directors: The Board is responsible for overseeing compliance with this policy and approving any amendments.

B. Officers and Staff: All officers and staff are responsible for understanding and complying with this policy with respect to documents under their control.

C. Designated Officer: The Secretary or other designated officer shall be responsible for the day-to-day administration of this policy, including maintaining the filing system, coordinating annual destruction, and maintaining destruction logs.

VIII — Exceptions

Exceptions to the retention periods set forth in this policy may be made only with the approval of the Board of Directors. Requests for exceptions should be submitted in writing with a justification for the requested deviation.

IX — Policy Review

This policy shall be reviewed annually by the Board of Directors and updated as necessary to ensure compliance with applicable laws and best practices.