Cotton Branch policies

Records Retention & Destruction

Responsible recordkeeping, retention periods, secure disposal, and legal holds.

Published: November 13, 2026

Cotton Branch Refuge Project keeps reliable records to support animal care, sound decisions, accountability, and legal obligations. We retain information for a defined purpose and dispose of it securely when that purpose and applicable requirements have ended. This policy covers paper, email, electronic files, databases, messages used for organizational business, and records held by service providers.

Responsibility and access

The Executive Director coordinates recordkeeping, identifies a responsible custodian for each record category, and maintains a documented retention schedule with Board oversight. Staff, directors, volunteers, and contractors must preserve organizational records in approved locations rather than keeping the only copy in a personal account or device.

Access is limited to the role and task. Personal, medical, personnel, donor, safeguarding, security, and disclosure records require particular care. A public policy does not make the underlying records public. Requests for records are reviewed under applicable disclosure obligations, privacy protections, and our governing documents.

Retention schedule

The following are our baseline retention rules. A longer applicable legal, grant, contractual, insurance, veterinary, or professional requirement takes priority. The custodian must resolve uncertainty before deleting a record.

  • Permanent organizational records: governing documents and amendments, tax-exemption determinations, Board and committee minutes, major resolutions, annual financial statements, filed annual information returns, and enduring property and ownership records.
  • Financial and gift records: retain general ledgers and supporting accounting, banking, receipt, expense, payroll, and donation records for at least seven years after the relevant fiscal year closes. Retain accepted gift restrictions and endowment or continuing obligations for as long as they apply and at least seven years after closure.
  • Contracts, grants, and insurance: retain agreements and material supporting records through their term and at least seven years after completion, termination, or final resolution; preserve longer where an ongoing right or claim requires it.
  • Employment and volunteer records: retain active role records during the relationship and generally at least seven years after it ends. Separate sensitive records and check category-specific rules before disposal. Keep serious incident or safeguarding records longer when risk, law, insurance, or professional advice requires it.
  • Animal records: maintain lifetime identification, intake, health, medication, care, placement, and significant incident histories. Retain them for at least seven years after death or final transfer, and longer for an unresolved welfare, ownership, veterinary, or legal issue.
  • Consent and communication preferences: retain evidence of consent and relevant releases while the authorized activity continues and for the period needed to establish its scope. Retain minimal opt-out or suppression information as needed to honor a person's choice.
  • Routine correspondence and duplicate working material: retain only while useful unless it documents a decision, transaction, obligation, incident, or other category above. Classify business email and messages by their substance rather than deleting them simply because they are messages.

Immediately suspend routine deletion when litigation, an investigation, a complaint, an audit, an official request, or another reasonably anticipated proceeding makes records relevant. This includes automated deletion, backups within our control, email, messages, drafts, photographs, and records on personal devices used for the relevant work.

Notify the Executive Director or an unconflicted Board reviewer. Only an appropriately authorized person, with professional advice when needed, may release a hold. No one may alter, conceal, backdate, or destroy records to obstruct a review or avoid accountability.

Secure disposal and review

Before disposal, check the schedule and any hold, obtain the required custodian approval, and use a method suitable for the sensitivity of the information. Shred confidential paper and securely delete or sanitize electronic material through approved procedures. Record significant disposal actions without reproducing unnecessary personal data.

The public website contains policy principles; internal inventories, backup details, and confidential records remain restricted. The schedule is reviewed at least annually and when services or obligations change. Report improper destruction through our Whistleblower Policy; report a loss or exposure under our Data Security & Incident Response Policy.

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