Software Freedom Conservancy Document Retention Policy

1 Purpose

Software Freedom Conservancy (“Conservancy”) has adopted a 

document retention and destruction policy (“Policy”) in order to 

define the record retention responsibilities of Conservancy 

officers, staff, and board members for maintaining and 

documenting the storage and destruction of Conservancy's 

documents and records.

2 General Guidelines

Records should not be kept if they are no longer needed for the 

operation of the business or required by law. Unnecessary records 

should be eliminated from the files. The cost of maintaining 

records is an expense which can grow unreasonably if good 

housekeeping is not performed. A mass of records also makes it 

more difficult to find pertinent records.

From time to time, Conservancy may establish retention or 

destruction policies or schedules for additional categories of 

records in order to ensure legal compliance, and also to 

accomplish other objectives, such as cost management. Conservancy 

has identified several categories of documents that warrant 

special consideration; these categories are listed below. While 

Conservancy has established minimum retention periods for these 

categories, the retention of these documents - and of records not 

included in the identified categories - should be determined 

primarily by the application of the General Guidelines affecting 

document retention in this Section, as well as the exception for 

litigation-relevant records described in the next Section and any 

other pertinent factors.

3 Document Storage Methods

All Conservancy documents are stored electronically in a 

version-controlled repository on a remote server that is backed 

up to drives on our local premises, with the following 

exceptions: 

• Conservancy stores all e-mails on a separate e-mail server

• Conservancy retains hard copies of all contracts executed with 

  parties outside of the United States for at least the full term 

  of each contract

4 Minimum Retention Periods for Conservancy Documents

4.1 Organizational Documents 	

The following records should be retained permanently:

• Conservancy Articles of Incorporation

• Conservancy By-laws

• Conservancy's IRS Form 1023 - which is also to be made 

  available for public inspection upon request

• Board meeting minutes and supporting materials presented at Board meetings

4.2 Tax Records

Tax records should be retained for at least seven years from the 

date of filing the applicable return. These records include:

• IRS Form 990 and related schedules

• Financial audit letter and supporting documents

• Employment tax records

• Documents concerning payroll, expenses, proof of donor 

  contributions

• Documented accounting procedures

4.3 Financial Records

In general, Conservancy's financial records should be kept for at 

least seven years. These records include:

• Accounts payable ledgers and schedules

• Accounts receivable ledgers and schedules

• Bank reconciliations, bank statements, deposit slips and checks 

  (except for as stated below)

• Donation records

• Expense reimbursement requests and supporting receipts and 

  documentation

Certain important financial records are to be kept permanently. 

These records include: 

• Checks and/or proofs of payment for expenditures over 

  US$100,000

4.4 Employment/Personnel Records

All employment and personnel records should be kept for at least 

seven years, with the following exceptions:

• Employment applications and related documents (including 

  correspondence and CVs from prospective candidates): at least 

  three years

• Employee offer letters, and confirmations of acceptance: kept 

  permanently

4.5 Other Corporate Records

Other corporate records shall be kept according to the schedule 

below:

• Insurance policies (both current and expired), claims, and 

  related reports: retained permanently

• Press releases: retained permanently

• Trademark and copyright applications and registration 

  materials: retained permanently

• Executed fiscal sponsorship agreements: retained permanently

• Internal strategic documents: at least three years

incurred by Conservancy staff, Project Leadership Committee (``PLC'')

members, and project volunteers while engaged in business on behalf of, or

at the behest of Conservancy and/or a Project (``Travelers'').

This Policy includes an Easy Reference Guide that can be used as a 

template for most of the travel covered under this Policy.  When in doubt,

refer to the more detailed sections below.  

== Purpose

Conservancy must maintain effective control of business-related expenses

in order to maintain its financial viability and tax exempt status.  

Conservancy and each Project is also accountable to our donors to ensure 

that we manage their contributions wisely and maximize our ability to 

pursue our charitable mission.  As such, Conservancy expects Travelers to 

use good judgment and to claim reimbursement for only those expenses that 

are necessary and reasonable.  Excessive expenses, including but not 

limited to luxury accommodations and services unnecessary for, or unrelated 

to the furtherance of Conservancy's charitable mission are not eligible for 

reimbursement. 

Any travel expense that adheres to this Policy is considered In-Policy

and does not require special approval, so long as the trip itself

has been approved in writing by Conservancy's Executive Director or

by a Project's Leadership Committee (``PLC'') in a regular and documented

PLC vote.  Conservancy and/or a PLC can limit allowable travel expenses

to an amount less than what would otherwise be considered acceptable

according to this Policy. If so, the smaller budget is the maximum

allowed expense. 

PLC's may, in fact, have their own travel policy that is more restrictive

than this one.  Please consult the PLC for your Conservancy project before

incurring an expenses to ensure you understand what expenses can be

reimbursed.

== Easy Reference Guide

Travelers should adhere to the following guidelines to stay In-Policy. 

* Flights.  

	* Book 14 days in advance. 

	* Air fares within $100 of the lowest fare (using standard 

	  airfare search tools) are In-Policy.  Fares > $750 domestically 

	  and > $1,500 internationally require Conservancy's pre-approval. 

* Hotels. 

	* Hotel fares < GSA rates are In-Policy.  Visit 

          http://www.gsa.gov/perdiem to determine the rate for your 

	  destination.

        * Be sure the receipt from your hotel includes the dates of your

          stay, not just a total.

* Receipts.  Keep and submit PDFs of the following, as applicable:

	* Your fare search (i.e., a screen shot)

	* Your plane/rail ticket (e-confirmation of purchase is sufficient)

	* Your hotel/lodging invoice

* Per Diem. 

	* Use your per-diem to cover meals and incidental expenses.

	* Your per-diem is based on GSA guidelines.  Visit 

	  http://www.gsa.gov/perdiem to the determine the per-diem for your

	  destination. 

	* Try to be frugal - GSM per-diem rates are rather generous. 

	* When attending a conference where food is included, Do The Right

	  Thing and claim a lower per-diem.   

* Reimbursement.

	* To receive reimbursement, send hotel and flight/rail receipt, 

	  along with a list of Per Diem days and totals to 

          accounting@sfconservancy.org.  Refer to the Expense Report 

          section below for details.  

== Reimbursement Procedure

Note that reimbursements are only processed once per week.  While we usually

can turn around reimbursements in about two weeks' time, please be advised

that Conservancy officially does reimbursements on a NET-30 basis, starting

from the date that complete materials are received.  If this is an issue,

Conservancy is available to prepurchase expensive items like airline tickets

on your behalf, so that you don't need to be reimbursed.

If you seek to be reimbursed for Conservancy Project expenses, please send

the following, in a self contained email (with attachments as necessary),

cc'ing your Project Leadership Committee address (PROJECT@sfconservancy.org)

for Project approval:

  * a brief paragraph explaining what was accomplished for the project

    during your travel and/or with the funds being reimbursed.  This can

    be informal; it's just for our records to confirm the travel advanced

    the not-for-profit mission of both Conservancy and the project.

  * A brief report listing the items to be reimbursed.

  * Full receipt(s) for everything, unless the travel policy does not

    require receipts (e.g., for per diem expenses).

    for reimbursement, include documentation of the rate conversion (e.g., a

    redacted credit card statement in your preferred currency).  Otherwise,

    Conservancy will use the prevailing rate for the date of the expense for

    conversion.

    Please verify that the receipts that you submit are within the attached

    travel policy requirements.  Note, however, that your Project Leadership

    Committee may have set a stricter budget than what the general

    Conservancy policy allows.

  * How you'd liked to be reimbursed. The four payment options, in order of

    Conservancy's preference, are:

    * Paypal.  For this, we need an email address that is valid for the

      Paypal account be paid.  Note that sometimes PayPal fees are

      assessed.  Usually we're taking funds from our PayPal balance, which

      means no fees appear on our side, but they may appear on yours.  It

      might be worth it to check the fee schedule before choosing this

      method.

    * Issue you a check in USD from a USA bank, sent to you via post.

      For this option, I just need your postal address.

    * Wire the amount in your local currency to your bank account in your

      country.  For this option, I need as much of the following information

      as it's possible for you to collect.  While some of this information

      isn't always needed, the more I have, the less likely there will be

      problems with your wire.  I note below in parenthesis which fields are

      mandatory, which varies based on where you are in the world.

                  SWIFT and/or BIC Code (mandatory for non-USA wires)

                  ACH or ABA routing number (mandatory for USA wires)

                  Account Number  (absolutely mandatory)

                  Full Name of the Account Holder  (absolutely mandatory)

                  Full Address of Account Holder

                  Bank Name

                  Bank Address

                  Tax ID of account holder (mandatory for Colombia)

                  Phone Number of account holder (mandatory for Colombia)

                  IBAN (if available, *required* for EU countries)

                  BSB Code (mandatory for Australia, not required elsewhere)

                  Preferred Currency (absolutely mandatory)

      Note that if there is an intermediary bank involved in the USA, you

      should provide all this information for both the intermediary bank

      and the final bank.  Note in particular that if the intermediary

      bank is in the USA, an ACH or ABA routing number is absolutely

      mandatory.

    * Issue you a check in your local currency, sent to you via post.  For

      this option, I just need your postal address and what currency you

      want.

Project Leadership Committees: when you see emails of this nature, please

be sure to have your designated Representative review the materials and

send an approval message to Conservancy.

== Project Leadership Committee Review

Conservancy foresees the need for periodic reasonable exceptions to

this Policy.  Persons working on behalf of a specific Project seeking

an exception to this Policy must petition their PLC to obtain written

approval from Conservancy authorizing the exception.  Persons working

directly on behalf of Conservancy must seeking an exception to the

Policy must obtain written approval from Conservancy authorizing the

exception. 

PLCs are responsible for creating procedures for requesting exceptions, 

and submitting to Conservancy reimbursement requests associated with

their respective Projects.  PLCs are also responsible for making available

a list of required response times for inquiries, including but not

limited to, the following two cases

* a specific number of days to respond to regular reimbursement requests,

and

* a specific number of days to respond to pre-authorization requests.

PLCs are also responsible for monitoring the available balance in their

Project Fund, and for granting or refusing approval for travel expense 

outstanding contracts payable.  PLCs are not to approve travel expense 

requests when their Project does not have sufficient funds to cover the 

expense.  If a PLC has any questions regarding whether their Project has 

sufficient funds to cover a Traveler's expense request, the PLC should 

contact Conservancy.

== Transportation

=== Overall transportation Cost

Domestic transportation costs greater than US$750 requires Conservancy 

approval prior to booking, even if all other Policy conditions have been 

met.  International transportation costs greater than US$1,650 requires 

Conservancy approval prior to booking, even if all other Policy conditions 

have been met.

=== Advance Purchase

Tickets for travel by air or rail (excluding commuter train and subway) 

should be booked at least 14 days in advance; any travel booked less than 

14 days in advance requires written pre-authorization by Conservancy.  

Tickets for travel by air or rail beyond 365 days in advance also require 

written pre-authorization by Conservancy.

=== Air Travel

==== Class of Service

Coach and/or Economy Airfare is the only acceptable class for all flights

(domestic and international) unless a PLC provides a special exception and

a valid reason (such as a need for business class due to a documented

medical reason) to Conservancy for written approval.  Travelers may select

their airline of choice (e.g., for the purpose of collecting airline miles

and rewards), provided that the resulting air fare otherwise meets the

requirements of this Policy.  Travelers should not book out-of-Policy trips

(and thus pay a higher fare) in order to qualify for a mileage upgrade.

==== Advance Purchase

Air travel should be booked at least 14 days in advance; any travel booked

less than 14 days in advance requires written pre-authorization by

Conservancy.  Flights beyond 365 days in advance also require written

pre-authorization by Conservancy.

==== Low Fare

Conservancy aims to balance cost savings with convenience and considers

flights that are within US$100 of the lowest logical fare to be within

Policy.  Any flights greater than US$100 over the lowest logical fare

require written pre-authorization by Conservancy. PLCs shall use standard

air fare search sites for determining the baseline lowest fare.

==== Reasonable Flights

Conservancy asks that Travelers allow for flexibility with respect

to departure times during a desired day of travel, as well as longer

trips in order to reduce cost.  However, Conservancy does consider

flights with two or more connections as unreasonable and does not

expect Travelers to consider those flight options to be reasonable.

==== Excess Baggage

Should a team member travel on an airline that charges for a single piece

of checked baggage, such a baggage expense is eligible for reimbursement.

Team members are responsible for charges on any baggage beyond a single

piece, unless that additional baggage is materials specifically related to

the Project's and Conservancy's mission (i.e., bringing t-shirts and other

promotional materials to an event).

==== Out-of-Policy Bookings

All air travel not adhering to the above Policies are considered Out-of-Policy

and require written pre-authorization by Conservancy's Executive Director.

==== Cancellation Fees

Cancellation fees and other penalties incurred result of a change

of plans are reimbursable at Conservancy's discretion.  In general,

Conservancy shall reimburse such fees if the Traveler can submit a

valid reason for the change of plans.  Acceptable reasons include Conservancy

and/or the PLC canceling or altering the trip or unexpected delays

in flight connections.  In instances where these fees are incurred

without adequate explanation, Conservancy reserves the right to refuse

to reimburse the cost of the fees. 

=== Other Transportation

==== Ground Transportation

Ground transportation necessary as part of authorized Project trips

is considered to be a reasonable expense.   Public ground transportation,

such as taxis, shuttles, buses and municipal transit, are generally

the most cost-effective options and are the standard for eligible

ground transportation reimbursements.  All car rentals require pre-authorization

by the PLC or by Conservancy's Executive Director.  When car rentals

have been pre-approved, the rental of compact cars is encouraged;

For groups of Travelers on an In-Policy trip, each Traveler should

pay for his/her own meals, seeing as all participants will have an

opportunity to submit for separate per diems after the trip. 

For clarification purposes, this Policy does not relate to planned

group events that include meals and/or refreshments (e.g., a PLC-organized

conference that includes lunch for all attendees).  Further, PLCs and/or

Conservancy retain the right to allocate a separate budget for anticipated

large group meals beyond the individual per diem limits of each Traveler,

provided that they are within the PLC's technical objectives and/or

Conservancy's mission.  Travelers anticipating a need to cover such

a large group meal should seek pre-approval from his/her PLC and/or Conservancy

for such expenses before the trip. 

For any such group meal, Conservancy will require a written paragraph

summary of the meeting, indicating what was accomplished for the Project's

and Conservancy's mission.

==== Meals For Organizational Development

Travelers may occasionally have the need to invite third parties,

e.g., prospective donors, contributors, community members, etc., to

meals in order to further a PLC's technical direction and/or Conservancy's

mission.  Conservancy recommends that Travelers seek pre-approval from

their PLC and/or Conservancy for such meals.

For any such organizational development meal, Conservancy will require a

written paragraph summary of the meeting, indicating what was accomplished

for the Project's and Conservancy's mission.

==== Phone Call Charges Part of Per Diem

Charges for personal phone calls (e.g., made from a hotel, or via

a mobile phone in international travel) are not reimbursable as an

expense separate from the allocated per diem. 

==== Currency Conversion Charges Part of Per Diem

Any fees associated with currency conversion are not reimbursable as a

expense separate from the allocated per diem.

=== Conference Registration Fees

Conservancy will reimburse conference registration fees up to $100 per day

for Travelers on approved Project business and/or approved Conservancy 

business.  For example, a $250 registration fee for a 3-day conference is

In-Policy; however, a $225 registration fee for a 2-day conference is not. 

Travelers seeking reimbursement for registration fees that exceed $100 per 

day must obtain prior approval from Conservancy's Executive Director.  

=== Internet Access

Internet access/wi-fi fees charged by a hotel are reimbursable, provided

that they are listed on the hotel/lodging invoice submitted for 

reimbursement.  Other internet access fees (e.g., airport internet 

services, personal wi-fi hotspots, internet cafes) are not reimbursable 

except as incidental expenses to be covered by a Traveler's per-diem.  

== Additional Days of Travel

Travelers often seek to add extra days before or after an approved trip

(e.g., the weekend before a conference). A Traveler may seek approval for

the expenses associated with an extended stay prior to booking the trip,

provided that the additional days are solely to enable a Traveler to

conduct work within the PLC's objectives and Conservancy's charitable

mission, or to get a particular airfare that *reduces* the overall cost of

the trip.  Travelers may seek approval to book travel itineraries that

include extra days for personal reasons, so long as the cost of the flight

meets the other requirements of this Policy.  Other expenses incurred

during extra personal days beyond transportation costs are not reimbursable.

== Non-reimbursable Expenses

Non-reimbursable expenses are identified throughout this policy.  The

following items are typically non-reimbursable expenses: 

* Partner, spouse, and/or companion travel

* First class travel (unless medically necessary)

* Upgrades to air travel, car rentals, or hotel rooms

* Purchase of clothing, luggage, toiletries and other miscellaneous

personal items 

* Supplemental travel or car rental insurance

* Fines, penalties, or legal fees

* Personal entertainment or recreational expenses beyond the allotted per

diem

Travelers are permitted to pay for their own upgrades, or use bonus

programs to upgrade Conservancy-reimbursed expenses.  However, Travelers

for any such transaction.

== Satisfaction of IRS Requirements

Reimbursed travel expenses are subject to examination by the USA Internal

Revenue Service (IRS).  Travelers are responsible for retaining documentary

evidence that all expenses are strictly for Project- and/or

Conservancy-related purposes, not personal in nature, and therefore not

includable as taxable income to the Traveler.  Receipts are required for

all expenses, no matter the amount.

== Currency Exchange Rates

Expenses incurred in foreign currencies will be converted to US dollars

based on the exchange rate on the date of incursion.  The currency

exchange rate of record shall be done using

http://www.bankofcanada.ca/rates/exchange/10-year-converter/[The Bank of Canada 10-year currency converter].

== Approvals

Travelers traveling on behalf of a Project must seek approvals and

submit expense reports to their PLC.  PLCs are to review those expense

reports and pass them along to Conservancy's Executive Director for

final approval and reimbursement. 

Travelers traveling on behalf of Conservancy must seek approvals and

submit expense reports to Conservancy's Executive Director.  Conservancy

staff must seek approvals and submit expense reports to Conservancy's

Treasurer or to another Conservancy Board Member designated by Conservancy's

Board. 

== Expense Reporting

Travelers seeking reimbursement must submit an expense report to the

appropriate channel with the following information:

* Name of Traveler 

* Brief description of trip and trip's purpose (e.g., ``August 2011

trip to XYZ conference for ABC project, served as planning committee

member''; ``Feb. '12 FOO hackfest in Portland, OR; contributed code'')

* A brief paragraph explaining what was accomplished for the project

during your travel.

* Number of days traveled (with documentary evidence, e.g., conference

itinerary, etc.) and associated per diem

* List of expenses not covered by per diem (e.g., transportation, lodging)

with substantiating receipts (or scans of receipts).

** In the event that it is impractical to obtain a required receipt and/or

if such receipt has been inadvertently destroyed or lost, the Traveler should

furnish a written statement to that effect, as well as an explanation

of the expenditure involved.  When possible, secondary documentation (such

a redacted credit card bill) should be provided instead of the

lost/destroyed receipt.

Any expense without a substantiated receipt and/or a supporting written

statement will not be reimbursed. 

Conservancy requests that all expense reports be submitted within two

weeks of travel.  Expense reports filed more than 90 days after expenses

are incurred will not be reimbursed without the approval of Conservancy's

Board.  Reimbursements are paid by Conservancy on a NET-30 basis, from the

date of receipt by Conservancy of the fully complete report and supporting

documentation for the travel.

== Consequences of Policy Violations

Failure to comply with this policy may result in the denial of, or delay

in payment for, reimbursement requests.

== Policy Changes 

The Conservancy reserves the right to change any terms of this Policy

from time to time. The Policy of record shall be the Policy most recently

distributed by the Conservancy. 

To book the flight, I'll likely need the following info.  Feel free to send

it to me in an GPG-encrypted email (or plain text, if you don't care ;):

  * Exact itinerary, including specific flights, airports and time, and be

    sure the total is within the travel policy requirements.

  * Passport Information

      - Full Name, as it appears on the Passport

      - Issue Date

      - Expiration date

      - Country of Issue

      - Gender

      - Date of Birth

  * Frequent flyer numbers for major airlines (if you want the miles credited)

  * Seat Preference (either specific seats, or "Aisle vs. Window" preference)

  * Meal Preference (if a meal is included in the coach flight)