D4C Records Retention Policy 

1. Purpose 

The purpose of this Records Retention Policy is to ensure compliance with Oregon’s public records laws and ONI standards, facilitate effective management, and enhance accessibility of corporate records, while ensuring efficiency and retaining records only as long as required to comply with legal and regulatory requirements and business needs of the District 4 Coalition (“D4C”).  

2. Introduction 

This policy applies to all records created, received, or maintained by the D4C. Records and documents (hereinafter “records”) should be retained in a manner consistent with this policy. The selective destruction of records or documents in a particular file or with respect to a specific matter should be avoided unless there is a legal and justifiable reason for doing so.  

Please be aware that the same rules apply to all corporate records, whether they are in the office, at an individual’s home, on an individual’s home computer, laptop, cell phone, or elsewhere, and to certain records which may be considered personal, such as desk calendars and work-related notes.  

When unsure whether or not to destroy a record, please contact the Executive Director for clarification.  

Note: Neighborhood Coalitions are subject to Oregon’s Public Records Laws, while neighborhood associations are generally not subject to those laws; however, neighborhood associations still operate under a framework (per the ONI standards and public policy) that encourages transparency and engagement with the community.  

3. Policy 

All records shall be created, secured, and maintained to ensure their integrity, authenticity, and accessibility throughout their lifecycle. Electronic records shall be maintained in formats that ensure long-term access and readability.  

It is D4C’s policy that records be retained only during the period of their business use unless longer retention is required by law or regulation or for internal or historical reference. The policy sets forth recommended times that records should be retained. Records relevant to anticipated or actual legal matters should never be destroyed without the approval of legal counsel.  

It is also the policy that D4C manages its records, including electronic records, according to sound business, legal and ethical practices. D4C recognizes that some corporate records must be retained due to legal and other business requirements. However, most do not and should be routinely destroyed after their usefulness has passed in order to save the Corporation storage and administration costs.  

4. Scope 

This policy applies to all D4C employees, officers and directors. This policy applies to all D4C documents, regardless of whether they are stored on site or off site, including documents that D4C employees, officers and directors might store at their homes or on home computers and other personal electronic devices.  

The disposal of documents or records shall be suspended if at any time D4C is being investigated or audited by any governmental agency or is involved in any litigation for which those documents or records could reasonably be relevant. 

5. Delegation 

D4C shall maintain a person of sufficient seniority and ability to serve as a records administrator to oversee compliance with the policy and the applicable record retention schedules and the timely disposal of records that are no longer needed or required to be maintained.  

6. Non-compliance 
    

Any director, officer, employee, or volunteer who knowingly violates this policy and destroys documents or records before the time period shown in the guidelines below shall be subject to disciplinary action. 

7. Relationship to Laws 

This Policy is intended to supplement and not supersede any applicable federal, state, and City of Portland laws/ONI Standards, or any contracts to which D4C is party, relating to retention and confidentiality of specific documents and information. 

8. Retention Guidelines 

Retain permanently:  

Nonprofit Tax Exemption Documents
Federal and state income tax exemption applications Determination letters from the IRS State and local sales tax exemption documents Correspondence with the IRS during the determination process	EIN confirmation letter Documents evidencing terms of gifts Contribution records
Corporate Governance Documents
Articles of Incorporation (and all amendments) Director resignations Minutes of Board, membership, and committee meetings (including all waivers of notice of meetings) Board policies and resolutions Records pertaining to neighborhood/coalition votes.	Bylaws (and all amendments) Resolutions and written consents Records of any relationships with affiliated organizations Annual reports with the Secretary of State
Grievance Records
Tax Returns
Federal and state tax returns and schedules	Filings with the Oregon Department of Justice
Financial Records
Audited and unaudited financial statements Audit reports and associated documents Special canceled checks, such as loan repayment End of year financial statement General ledger	Asset depreciation schedules Revenue and expense records Accounts payable and receivable records Purchase, procurement, and sale agreements and contracts
Other
Property, D&O, workers’ compensation and general liability insurance policies, and insurance claim records Employee medical records (relating to workers’ compensation, FMLA, ADA, leaves of absence) Records supporting ownership of assets (e.g. deeds, bills of sale, patent and trademark records)	Licenses and permits Legal correspondence State registrations and business licenses Construction documents State unemployment tax records Publications, brochures, press releases
Retain for 7 years:
Employee Records
Payroll Tax withholdings Garnishment records W-2s Travel and expense reports Contractor records IRS 1099s	Employment applications Employee contracts Employee evaluations and personnel records Employee benefits records Contracts (after expiration) Invoices
Financial records
Monthly and quarterly financial statements Business expense records Routine canceled checks Investment reports	Budget and expense reports Bank statements and reconciliations Records relating to loans Donation records
Other
Warranties Grant records, applications, and contracts Leases for equipment Environmental audits Fundraising records and materials	Inventory management records Records of sales MOUs Project records
Retain for 3 years
Financial records
Credit card and cash receipts Budget data	Electronic fund transfer documents
Tax records  Records supporting federal and state tax return income, deductions, and credits	Federal and state tax bills and statements
Correspondence  Correspondence or internal memos on routine matters Correspondence with contractors and vendors	Internal reports

Note: Documents or records that are not listed, but which are substantially similar to those listed in the schedule, will be retained for the same length of time as the similar documents.  

Record Disposal 

Records that have met their required retention period shall be disposed of in a manner that protects sensitive information from unauthorized access. Paper records shall be shredded, and electronic records shall be deleted securely. 

Public Access 

Neighborhood Coalition records deemed public under Oregon’s public records law shall be available for inspection during normal business hours, except those exempt under the law. Requests for access to records shall be responded to within the time frames stipulated by Oregon law. 

Meeting Recordings 

D4C records audio (and/or video, as applicable) of all official meetings as an aid in the accurate creation of meeting minutes. These recordings are intended solely for the administrative convenience of the Secretary or the individual responsible for drafting the official meeting minutes. 

Note: recordings of meetings are not considered the official record of meetings, but are used temporarily to assist in the creation of the official record, which are the meeting minutes. 

Once the meeting minutes are drafted and approved by the Board, recordings are subject to deletion to reduce unnecessary and overly burdensome data retention.  

This policy was adopted by the Board of Directors on April 7th, 2025.