Schedule (Minimums, Confirm Counsel)

Record Keep
Tax returns + K-1s + 1099/W-2 7 years
Payroll registers + returns 7 years
Bank recs, GL, close binders 7 years
AP/AR support 7 years
Board minutes, charters, ledgers Permanent
Audit reports + workpapers 7+ years
Privacy DSAR logs Per policy, 3+ years

Pair with Record Retention Tax, Payroll Year-End, Year-End Close, and Board Minutes.

Controls

  • Owner per category, central index, access roles.
  • Annual review + hold check before destruction — see Internal Controls.
  • Backup tested — see NIST.
  • Destruction log with dual approval — see Audit Procedures.

Link to Compliance Checklist and Month-End Close.

Retention by System (Where It Actually Lives)

Record System of record Format
Tax returns, K-1s CPA portal + immutable archive PDF + workpapers
Payroll registers Payroll provider + GL tie Export + rec — see Payroll Year-End
Bank recs, close binders Close drive, versioned Signed PDFs — see Month-End Close
Contracts, minutes Diligence vault (data room) Executed copies — see Board Minutes
Email/Slack holds eDiscovery export on hold notice Preserved, not auto-deleted
HR files HRIS vault, restricted Access-logged

“Stored in someone’s inbox” is not retention. Each row needs one owner, one location, and one backup — tested per NIST. Map it once in a retention matrix; auditors and acquirers both ask for it (see Due Diligence).

  1. Issue in writing within 24 hours of trigger (letter, subpoena, investigation, credible threat). Name the matter, custodians, scope, and “do not delete, do not auto-archive” instruction.
  2. Collect acknowledgments. Every custodian confirms receipt; chase non-responders daily. An unacknowledged hold is an unenforced hold.
  3. Suspend auto-destruction. Pause mailbox retention policies, Slack/Drive auto-delete, and scheduled shredding for in-scope custodians — document the IT ticket numbers.
  4. Preserve broadly, review narrowly. Image or export liberally; counsel decides relevance later. Over-preservation costs storage; under-preservation costs cases.
  5. Release in writing. When the matter closes, release custodians explicitly and resume schedules. Holds left open for years rot into ignored background noise.

Coordinate whistleblower-related holds with the Whistleblower protocol and the audit committee — never the subject’s chain of command.

Destruction Run (Annual, Supervised)

Once a year, with no open holds confirmed in writing: pull the eligible list from the matrix, dual-approve each category, witness shredding/wipe with certificates, and log date, method, approvers, and certificate IDs. File the log permanently — proof of routine, policy-based destruction defeats spoliation claims far better than ad-hoc deletions. Train every custodian on holds before the run, not during it.

FAQ

Where to store?

Immutable finance archive plus access-restricted HR/payroll vault; no local desktops as record.

What triggers hold fastest?

Litigation letter, subpoena, whistleblower investigation — see Whistleblower.

Next Steps

  1. Approve schedule with counsel this month.
  2. Index existing files to schedule.
  3. Train holds before year-end destruction run.