Nonprofit Document Retention Policy Compliance Review

Document retention policies protect organizations from legal liability, ensure regulatory compliance, and preserve institutional knowledge. IRS Form 990 Part VI Line 14 asks specifically whether the organization has a written document retention and destruction policy.

  • Industry: Nonprofit
  • Frequency: Annually
  • Estimated Time: 2-3 hours
  • Role: Executive Director / Operations Manager
  • Total Items: 30

Policy Content and Scope

Verify policy content is comprehensive.

  • Written document retention policy formally adopted by board?
  • Policy covers all major record types (financial, legal, program, HR, governance)?
  • Specific retention periods specified for each record type?
  • Secure destruction procedures defined for expired records?
  • Litigation hold procedure defined for suspending destruction when litigation anticipated?

Required Retention Periods

Verify retention periods meet legal requirements.

  • Permanent records identified (incorporation documents, board minutes, 990 returns, audit reports)?
  • Financial records retained minimum 7 years per IRS recommendation?
  • Federal grant records retained per OMB Uniform Guidance 2 CFR 200.333 (3+ years)?
  • HR records retained per applicable employment law requirements?
  • Donor and gift records retained sufficiently to document charitable deductions?

Digital Records Management

Verify digital records management practices.

  • Policy explicitly covers email, electronic documents, and digital records?
  • Regular backup procedures for electronic records in place?
  • Cloud storage and SaaS platforms addressed in retention policy?
  • Secure deletion procedures for expired electronic records defined?
  • Access controls protecting sensitive electronic records?

Policy Implementation

Verify policy is being implemented.

  • All staff trained on document retention policy requirements?
  • Designated person responsible for overseeing policy implementation?
  • Organized file management system in place to facilitate retention?
  • Annual record review and purge process in place for expired records?
  • Litigation hold procedure communicated to all staff?

Board and Governance Records

Verify governance records are properly retained.

  • All board and committee minutes retained permanently?
  • Corporate records (articles, bylaws, 501(c)(3) letter) retained permanently?
  • All Form 990 filings retained permanently?
  • All audit reports retained permanently?
  • Contracts retained for 7 years after expiration?

Policy Compliance Documentation

Verify compliance documentation is maintained.

  • Documentation ready to answer Form 990 Part VI Line 14 affirmatively?
  • Log of records destroyed per policy maintained?
  • Board approval of policy documented in board minutes?
  • Any exceptions to retention policy documented with justification?
  • Annual policy review completed and any updates approved?

Related Nonprofit Checklists

Related Governance Compliance Checklists

Why Use This Nonprofit Document Retention Policy Compliance Review?

This nonprofit document retention policy compliance review helps nonprofit teams maintain compliance and operational excellence. Designed for executive director / operations manager professionals, this checklist covers 30 critical inspection points across 6 sections. Recommended frequency: annually.

Frequently Asked Questions

What does the Nonprofit Document Retention Policy Compliance Review cover?

This checklist covers 30 inspection items across 6 sections: Policy Content and Scope, Required Retention Periods, Digital Records Management, Policy Implementation, Board and Governance Records, Policy Compliance Documentation. It is designed for nonprofit operations and compliance.

How often should this checklist be completed?

This checklist should be completed annually. Each completion takes approximately 2-3 hours.

Who should use this Nonprofit Document Retention Policy Compliance Review?

This checklist is designed for Executive Director / Operations Manager professionals in the nonprofit industry. It can be used for self-assessments, team audits, and regulatory compliance documentation.

Can I download this checklist as a PDF?

Yes, this checklist is available as a free PDF download. You can also use it digitally in the POPProbe mobile app for real-time data capture, photo documentation, and automatic reporting.

Browse More Checklists