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\begin{document}

\title{Software Freedom Conservancy Document Retention Policy}

\maketitle

\section{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.

\section{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.

\section{Exception for GPL Compliance and Litigation-Relevant Documents}

Conservancy expects all staff, officers, board members, and PLCs to

comply fully with this Policy and any other written document retention

policies, with the following notable exception to any stated destruction

schedule: if you believe, or if Conservancy informs you, that certain

Conservancy and/or Project records relate to efforts to bring companies

into compliance with the General Public License, enforcing the GPL,

or in some way relates to litigation or potential litigation (i.e.,

a dispute that could result in litigation), then you \textbf{must}

preserve those records until it is determined that the records are

no longer needed. That exception supersedes any previously or subsequently

established destruction schedule for those records.

\section{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: 

\begin{itemize}

\item Conservancy stores all e-mails are stored on a separate e-mail server

\item Conservancy retains hard copies of all contracts executed with parties

outside of the United States for at least the full term of each contract

\end{itemize}

\section{Minimum Retention Periods for Conservancy Documents}

\subsection{Organizational Documents 	}

The following records should be retained permanently:

\begin{itemize}

\item Conservancy Articles of Incorporation

\item Conservancy By-laws

\item Conservancy's IRS Form 1023 - which is also to be made available for

public inspection upon request

\item Board meeting minutes

\end{itemize}

\subsection{Tax Records}

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

of filing the applicable return. These records include:

\begin{itemize}

\item IRS Form 990 and related schedules

\item Financial audit letter and supporting documents

\item Employment tax records

\item Documents concerning payroll, expenses, proof of donor contributions

\item Documented accounting procedures

\end{itemize}

\subsection{Financial Records}

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

least seven years. These records include:

\begin{itemize}

\item Accounts payable ledgers and schedules

\item Accounts receivable ledgers and schedules

\item Bank reconciliations, bank statements, deposit slips and checks (except

for as stated below)

\item Donation records

\item Expense reimbursement requests and supporting receipts and documentation

\end{itemize}

Certain important financial records are to be kept permanently. These

records include: 

\begin{itemize}

\item Checks and/or proofs of payment for expenditures over US\$100,000

\end{itemize}

\subsection{Employment/Personnel Records}

All employment and personnel records should be kept for at least seven

years, with the following exceptions:

\begin{itemize}

\item IRS Form 990 and related schedules: at least seven years from the

date of filing the applicable return

\item Financial audit letter and supporting documents: at least seven years

from the date of filing the applicable return

\item Employment applications and related documents (including correspondence

and CVs from prospective candidates): at least three years

\item Employee offer letters, and confirmations of acceptance: kept permanently

\end{itemize}

\subsection{Other Corporate Records}

Other corporate records shall be kept according to the schedule below:

\begin{itemize}

\item Insurance policies (both current and expired), claims, and related

reports: retained permanently

\item Press releases: retained permanently

\item Trademark and copyright applications and registration materials: retained

permanently

\item Executed fiscal sponsorship agreements: retained permanently

\item Internal strategic documents: at least three years

\item Correspondence from Member Project liaisons re: Member Project matters,

including disbursement requests: at least seven years

\end{itemize}

\subsection{Correspondence}

\begin{itemize}

\item Except as classified above, letters received in hard copy shall be

kept for at least one year.

\item Except as classified above, e-mail correspondence in Conservancy e-mail

accounts shall be archived for at least one year, with the exception

of the correspondence sent to the ``compliance@sfconservancy.org''

account, which shall be archived for at least seven years. 

\end{itemize}

\subsection{Reports from Projects}

\subsection{Blogs and Press Releases}

Conservancy should retain permanent copies of all official Conservancy

blogs, press releases and 

\subsection{Contracts}

Except as classified above, all contracts entered into by Conservancy

should be retained for at least seven years from the date of filing

the applicable return. These records include:

\begin{itemize}

\item IRS Form 990 and related schedules

\item Financial audit letter and supporting documents

\item Documents concerning payroll, expenses, proof of donor contributions

\item Documented accounting procedures

\end{itemize}

\subsection{Software Development Contract Deliverables}

All code and supporting documentation written by a developer in fulfillment

of a contract with Conservancy should be archived electronically for

at least three years. 

\subsection{Presentations}

All presentations, including slides, charts, and supporting visual

aids, prepared for use by a Conservancy officer or staff member shall

be kept for at least two years. 

\subsection{Drafts}

Notwithstanding the above, once the final copy of a document has been

completed, the drafts may be recycled or deleted, unless they are

documents of legal value. For documents determined to be of legal

value, drafts containing comments shall be saved for at least two

years, and drafts without comment may be destroyed once the final

version is complete. 

\section{Destruction of Documents}

Conservancy reserves the right to destroy hard copies of documents

by shredding or fire after the expiration of the applicable document

retention schedule. Conservancy reserves the right to destroy electronic

copies of documents by fire or other proven means to destroy such

media after the expiration of the applicable document retention schedule.

All permitted document destruction shall be halted if the organization

is being investigated by a governmental law enforcement agency, and

routine destruction shall not be resumed without the written approval

of Conservancy's General Counsel or Executive Director. No documents

will be concealed, altered, or destroyed with the intent to obstruct

a legal investigation or litigation. 

\end{document}

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 Exception for GPL Compliance and Litigation-Relevant Documents

Conservancy expects all staff, officers, board members, and PLCs 

to comply fully with this Policy and any other written document 

retention policies, with the following notable exception to any 

stated destruction schedule: if you believe, or if Conservancy 

informs you, that certain Conservancy and/or Project records 

relate to efforts to bring companies into compliance with the 

General Public License, enforcing the GPL, or in some way relates 

to litigation or potential litigation (i.e., a dispute that could 

result in litigation), then you must preserve those records until 

it is determined that the records are no longer needed. That 

exception supersedes any previously or subsequently established 

destruction schedule for those records.

4 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 are stored 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

5 Minimum Retention Periods for Conservancy Documents

5.1 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

5.2 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

5.3 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

5.4 Employment/Personnel Records

All employment and personnel records should be kept for at least 

seven years, with the following exceptions:

• IRS Form 990 and related schedules: at least seven years from 

  the date of filing the applicable return

• Financial audit letter and supporting documents: at least seven 

  years from the date of filing the applicable return

• 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

5.5 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

• Correspondence from Member Project liaisons re: Member Project 

  matters, including disbursement requests: at least seven years

5.6 Correspondence

• Except as classified above, letters received in hard copy shall 

  be kept for at least one year.

• Except as classified above, e-mail correspondence in 

  Conservancy e-mail accounts shall be archived for at least one 

  year, with the exception of the correspondence sent to the “

  compliance@sfconservancy.org” account, which shall be archived 

  for at least seven years. 

5.7 Reports from Projects

5.8 Blogs and Press Releases

Conservancy should retain permanent copies of all official 

Conservancy blogs, press releases and 

5.9 Contracts

Except as classified above, all contracts entered into by 

Conservancy 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

• Documents concerning payroll, expenses, proof of donor 

  contributions

• Documented accounting procedures

5.10 Software Development Contract Deliverables

All code and supporting documentation written by a developer in 

fulfillment of a contract with Conservancy should be archived 

electronically for at least three years. 

5.11 Presentations

All presentations, including slides, charts, and supporting 

visual aids, prepared for use by a Conservancy officer or staff 

member shall be kept for at least two years. 

5.12 Drafts

Notwithstanding the above, once the final copy of a document has 

been completed, the drafts may be recycled or deleted, unless 

they are documents of legal value. For documents determined to be 

of legal value, drafts containing comments shall be saved for at 

least two years, and drafts without comment may be destroyed once 

the final version is complete. 

6 Destruction of Documents

Conservancy reserves the right to destroy hard copies of 

documents by shredding or fire after the expiration of the 

applicable document retention schedule. Conservancy reserves the 

right to destroy electronic copies of documents by fire or other 

proven means to destroy such media after the expiration of the 

applicable document retention schedule.

All permitted document destruction shall be halted if the 

organization is being investigated by a governmental law 

enforcement agency, and routine destruction shall not be resumed 

without the written approval of Conservancy's General Counsel or 

Executive Director. No documents will be concealed, altered, or 

destroyed with the intent to obstruct a legal investigation or 

litigation.