DOCUMENT RETENTION POLICY

PREAMBLE

Ministries of Jesus, Inc. (“MOJ”) is a not-for-profit corporation duly organized under the laws of the State of Oklahoma and recognized as a tax-exempt public charity under the provisions of Section 501(c)(3) of the Internal Revenue Code.  As such, MOJ desires to promote accountability, transparency and good governance in support and fulfillment of the mission of MOJ.

PURPOSE

The purpose of this Document Retention Policy (the “Policy”) is to provide and establish guidelines for the proper retention, protection and disposal of documents and records generated or received by MOJ to ensure the efficient management of documents and records in compliance with applicable federal and Oklahoma legal and regulatory requirements

APPLICATION

This Policy applies to all records, regardless of format (i.e., paper, electronic, audio, etc.), created or received by MOJ or any director, officer, employee, contractor or volunteer on behalf of MOJ in the course of its operations.

RETENTION SCHEDULE

1. Permanent Retention Period:

• Certificate of Incorporation and any amendments thereto
• By-Laws and any amendments thereto
• Board of Directors minutes and resolutions
• Committee minutes
• IRS Determination Letter and related correspondence
• Independent Audit Reports
• Annual Financial Statements
• Major Gift Agreements
• Insurance records, policies, accident reports, claims
• Deeds, mortgages and bills of sale

1. Retention Period – Seven (7) Years:

• Annual strategic reports and plans
• General financial records (i.e., ledgers, journals, bank records, etc.)
• Payroll records
• IRS Form 990 (or applicable related form) and supporting documents
• Grant records and supporting documents
• Contracts and legal documents
• Dental clinic records
• Counseling services records
• Employee and volunteer records
• Donor and fundraising records and acknowledgments
• Retention Period – Five (5) Years:
• Health clinic records (adult patients – five (5) years from date patient last seen / minor patients – three (3) years from the date patient attains majority age) – However, certain federal, state or other grant programs may require a longer retention period which will be followed by MOJ

1. Retention Period – Three (3) Years:

• Routine correspondence
• Internal reports and memoranda
• Miscellaneous administrative records

RECORD STORAGE AND SECURITY

All paper records shall be stored in the MOJ administrative office area and confidential documents (e.g. patient records, counseling notes, Protected Health Information, donor information) must be securely stored in locked cabinets located in the MOJ respective department’s office area.  Electronic records, including confidential records, shall be maintained in encrypted digital systems on a cloud-based server off site. Access to such confidential documents is limited to authorized MOJ personnel. Electronic records must be backed up routinely and protected by appropriate cybersecurity protocols.

PUBLIC INSPECTION REQUIREMENTS

As required under federal law, MOJ will retain and make available for public inspection the following records: (i) IRS Form 1023 (Application for Recognition of Exemption), (ii) IRS exemption determination letter (iii) IRS Form 990 or 990 EZ (Annual Information Returns) for the immediately preceding three (3) years.  MOJ will make such records available for public inspection at its offices and provide copies to the public upon request or in the alternative MOJ will make such records available on its website.

RECORD DESTRUCTION PROCEDURES

Records that have met their retention period shall be destroyed in a manner that ensures confidentiality and security.  Paper records shall be shredded, and electronic records shall be permanently deleted.

All MOJ directors, officers, employees and volunteers are responsible for adhering to this policy.  Any destruction of paper or electronic records must be documented.

When litigation, audit or investigation is initiated or reasonably anticipated, a legal hold on the relevant records will be issued by the Executive Director.  All relevant records must be preserved and destruction suspended until the hold is lifted by the Executive Director in writing.