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Advocating for people with intellectual, developmental, and other disabilities to lead full and equitable lives.
AHRC New York City

Advocating for people with intellectual, developmental, and other disabilities to lead full and equitable lives.

Section 4.17: Record Retention and Destruction

Section: 4.17
Issued: 05.01.2009
Updated: 03.20.2023

Purpose

The purpose of this policy is to describe the AHRC NYC process regarding record retention and destruction.

Policy Overview

This record retention and destruction policy applies to each department of AHRC NYC. Each department must establish a policy, procedure and schedule (described below) for the retention and destruction of its paper, and electronically stored records. Each department must ensure that they provide the vice president of Corporate Compliance with the most updated version of their policy, procedure and schedule. Each department must strictly adhere to its approved schedule in maintaining and disposing of its records.

Requirements for Department Record Retention / Destruction Schedules

At a minimum, each department’s schedule must contain the following information:

  • Document name and/or number.
  • Whether the document is confidential either by law, regulation, or agency directive.
  • Period for which the document is to be maintained on site.
  • General location of onsite documents (e.g., Main Office storage room; Mayflower day program site, storage room).
  • Period for which the document is to be maintained offsite at the designated AHRC NYC record storage company (if applicable).
  • Total period the document is to be maintained.

Onsite Storage

All files maintained onsite must be placed in a commercial grade cabinet, safe from water or any other potentially damaging elements. Confidential files containing Protected Health Information must be contained in locked file cabinets, desks, closets or file rooms (including mechanical keys, ID swipes or electronic keypad systems). AHRC NYC has controls in place through Administrative Services for mechanical and electronic access management.

Off Site Record Storage

AHRC NYC maintains a contract with an offsite document storage company. Documents must be stored based on each department’s Record Retention and Destruction Policy, Procedure and Schedule. Each department is responsible for maintaining a record of stored documents, date sent and storage tracking information.

Record Destruction

At least once in a calendar year, each department will be responsible for the destruction of records in accordance with its Record Retention/Destruction Schedule. The documents must be destroyed in an appropriate manner, i.e., confidential records are shredded, others are recycled. Confidential records must be destroyed with knowledge by the department head or designee. The department must retain a written record of each record destroyed.

Documents needed for litigation or investigation purposes, or determined by senior management to be “in anticipation of litigation” must be retained in special files maintained by either the vice president of Corporate Compliance or the vice president of workforce development and talent acquisition, depending on the circumstance. The department will be advised where to send them. The department should maintain copies of the files at their site.

These documents are not subject to the department’s normal records destruction process. In the case of potential or actual litigation due to a death, see the policy on Post Death Record Keeping. For all other potential or actual litigation, records will be kept onsite at the main office by either the vice president of Corporate Compliance or the vice president of workforce development and talent acquisition, who will either return them to the site after a year if there is no litigation or, if there is litigation, the original file will be maintained at the main office until litigation is settled. Once litigation is settled the department will be notified and the original files will be sent to offsite storage in the offsite storage account maintained by either the vice president of Corporate Compliance or the vice president of workforce development and talent acquisition.

Department Head Responsibility

The implementation of this policy is the direct responsibility of the department head.

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