BAMBEE, INC. USER DOCUMENT RETENTION AND DESTRUCTION POLICY
1. Policy and Purpose
2.1 Responsibilities of the Administrator. The Company’s CTO shall be the administrator (“Administrator”) in charge of the administration of this Policy. The Administrator’s responsibilities shall include supervising and coordinating the retention and destruction of User documents pursuant to this Policy and particularly the Document Retention Schedule included below. The Administrator shall also be responsible for documenting the actions taken to maintain and/or destroy Company documents and retaining such documentation. The Administrator is also authorized to periodically review this Policy and Policy compliance with legal counsel. The Administrator may also appoint one or more assistants to assist in carrying out the Administrator’s responsibilities, with the Administrator, however, retaining ultimate responsibility for administration of this Policy.
3. Suspension of Document Destruction; Compliance.
The Company becomes subject to a duty to preserve (or halt the destruction of) documents once proper notification of litigation has been received. Proper notification must be made in writing, and mailed with tracking information available to verify delivery to the address below. Additional notification or tracking information may be electronically mailed to the below email address, although is not effective until written notification is received.
Santa Monica, CA 90401
Attention: Legal Administrator
4. Electronic Documents; Document Integrity
Documents in electronic format shall be maintained just as hard copy or paper documents are, in accordance with the Document Retention Schedule. Due to the fact that the integrity of electronic documents, whether with respect to the ease of alteration or deletion, or otherwise, may come into question, the Administrator shall attempt to establish standards for document integrity, including guidelines for handling electronic files, backup procedures, archiving of documents, and regular checkups of the reliability of the system; provided, that such standards shall only be implemented to the extent that they are reasonably attainable considering the resources and other priorities of the Company.
It shall be the responsibility of the Administrator, after consultation with counsel, to determine how privacy laws will apply to the Company’s documents from and with respect to employees and other constituencies; and to establish reasonable procedures for compliance with such privacy laws.
6. Emergency Planning
Documents shall be stored in a safe and accessible manner. Documents which are necessary for the continued operation of the Company in the case of an emergency shall be regularly duplicated or backed up and maintained in an off-site location. The Administrator shall develop reasonable procedures for document retention in the case of an emergency.
7. Document Creation and Generation
The Administrator shall discuss with staff the ways in which documents are created or generated. With respect to each employee or Company function, the Administrator shall attempt to determine whether documents are created which can be easily segregated from others, so that, when it comes time to destroy (or retain) those documents, they can be easily culled from the others for disposition.
8. Document Retention Schedule
-Accounting and Finance-
Annual Financial Statements and Audit Reports
Bank Statements, Reconciliations & Deposit Slips
Canceled Checks – routine
Canceled Checks – special, such as loan repayment
Credit Card Receipts
Employee/Business Expense Reports/Documents
Interim Financial Statements
-Corporate and Exemption-
Articles of Incorporation and Amendments
Bylaws and Amendments
Minute Books, including Board & Committee Minutes
Annual Reports to Attorney General & Secretary of State
Other Corporate Filings
IRS Exemption Application (Form 1023 or 1024)
IRS Exemption Determination Letter
State Exemption Application (if applicable)
State Exemption Determination Letter (if applicable)
Licenses and Permits
Employer Identification (EIN) Designation
-Correspondence and Internal Memoranda-
Hard copy correspondence and internal memoranda relating to a particular document otherwise addressed in this Schedule should be retained for the same period as the document to which they relate.
Hard copy correspondence and internal memoranda relating to routine matters with no lasting significance
Correspondence and internal memoranda important to the Company or having lasting significance
-Electronic Mail (E-mail) to or from the Company-
Electronic mail (e-mails) relating to a particular document otherwise addressed in this Schedule should be retained for the same period as the document to which they relate, but may be retained in hard copy form with the document to which they relate.
E-mails considered important to the Company or of lasting significance should be printed and stored in a central repository.
E-mails not included in either of the above categories
-Electronically Stored Documents-
Electronically stored documents (e.g., in pdf, text or other electronic format) comprising or relating to a particular document otherwise addressed in this Schedule should be retained for the same period as the document which they comprise or to which they relate, but may be retained in hard copy form (unless the electronic aspect is of significance).
Electronically stored documents not included in either of the above categories
-Employment, Personnel and Pension-
Personnel Records employment ends
10 years after
Employee contracts termination
10 years after
Retirement and pension records
Property, D&O, Workers' Compensation and General Liability Insurance Policies
Insurance Claims Records
-Legal and Contracts-
Contracts, related correspondence and other supporting documentation
10 years after
Termination legal correspondence
-Management and Miscellaneous-
7 years after expiration
Disaster Recovery Plan Replacement
7 years after
Policies and Procedures Manual
Current Version with Revision History