Approved by Senior Management Team on June 10, 2008
Under federal privacy legislation, organizations are required to develop detailed procedures to govern the retention of documents in our possession that contain personal information including personal health information. In addition, good business practices call for retention procedures to ensure that we keep personal information and sensitive business documents for the appropriate length of time for reference and continuity, but that we do not retain such information beyond the period required to fulfill the purpose for which it was collected or developed. The Multiple Sclerosis Society of Canada is a complex organization which carries out numerous activities under its mission. To make record retention as easy as possible the recommended time for record retention is seven years. After that time, records can be destroyed as outlined in the Record Destruction section below. In a few instances, record retention requirements will vary, as required by law.
Note: Electronic documents are subject to the same Retention of Records procedures as paper documents, dependent upon content. This procedure applies to all MS Society-related e-mails regardless of whether they were sent or received using the MS Society network or by using another system or account.
Note: While privacy law requires that personal information and personal health information be kept only as long as needed to carry out appropriate services or programs associated with that information, it is permissible to use anonymous data from MS Society records for statistical purposes.
Note: Documents on the Mercury knowledge management and collaboration system will be kept for three years and then automatically deleted, unless they are specified in the list below or if the person posting the document has specified another date.
Exception: If the MS Society is notified that its records are subject to litigation or potential litigation, then those records must be preserved until legal counsel determines the records are no longer needed.
| Record Retention | Time Frame |
|---|---|
| GOVERNANCE | |
| FINANCE | |
| HUMAN RESOURCES | |
| VOLUNTEER MANAGEMENT (BOARD AND NON-BOARD) | |
| CLIENT SERVICES | |
| MEMBERSHIP | |
| RESEARCH | |
| FUNDRAISING | |
| MARKETING & COMMUNICATIONS | |
| By-laws & Regulations | Indefinitely 1 |
| Board minutes | Indefinitely 1 |
| Board committee minutes | Indefinitely 1 |
| Annual general meeting minutes | Indefinitely 1 |
| Policies & procedures | Indefinitely 1 |
| Official donation receipts for Income Tax purposes | 2 years from the end of the calendar year in which the donations were made |
| Records for 10-year gifts (donations that are subject to a donor’s written trust or direction) | Indefinitely 1 |
| Paid invoices | 7 years from the time of payment |
| Accounts receivable | 7 years from time of issue |
| Pledge sheets and pledge books | 2 years form date on sheets or books |
| General ledgers and other final summaries | CRA requirement: 6 years from end of the last tax year to which they relate while charity is registered, and for 2 years after the date the registration of the charity is revoked. |
| Audited financial statements | Indefinitely |
| T3010 filing information | CRA requirement: 6 years from end of the last tax year to which they relate while charity is registered, and for 2 years after the date the registration of the charity is revoked. |
| Former employee records | 7 years from the time the person ceased to be an employee or as required by law |
| Payroll records | 7 years or as required by law |
| Inactive volunteer records | 7 years, from the time the volunteer ceased to be active |
| Inactive client records (funding files, registration documents, support counseling, information and referral correspondence (e-mail & printed) | 7 years from the time the client ceased to receive services |
| Deceased client records | 2 years from the time of death |
| Inactive member records | 7 years from the time the person ceased to be a member |
| Inactive research grantee records | 7 years from the time of the last grant |
| Inactive donors 2 | 7 years from time of last donation |
| Inactive event participants 3 | 7 years from time of last participation |
| Planned giving-expectancies | Until notification that gift has been received/realized |
| Planned giving-realized | Until 7 years after final gift in donor’s will received |
| Fundraising strategy documents and plans (final versions) | Indefinitely |
| Do not call lists | Indefinitely |
| Do not mail lists | Indefinitely |
| Annual reports | Indefinitely |
| Official newsletter, e.g., MS Canada, division newsletters | Indefinitely |
Record Destruction
MS Society records that contain personal information and sensitive information as outlined above must be destroyed in such a manner so that information cannot be reconstructed or retrieved. Paper documents must be shredded.
Electronic files must be permanently and thoroughly deleted from all online and offline storage media using existing digital shredding techniques to prevent data reconstruction. If detailed historical transactions are to be retained, all personal identifiable data (name, home address, home telephone number) must be destroyed. Contact the Information Technology Department for detailed information or for assistance.
Definitions
- Canada Revenue Agency regulations require records be kept as long as the charity is registered and for a minimum of two years after the date the registration of the charity is revoked. For simplicity sake, this period is referred to as "indefinitely" in this documents.
- Includes inactive donors through the direct marketing program, inactive major gift planned donors, inactive donors through other programs including gift planned donors, inactive donors through other programs including in memoriam and in honour at all levels of the MS Society.
- Includes inactive participants in core events (MS Walk, MS Bike Tour) and in other events at all levels of the MS Society.