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Document Retention Policy

Last Updated and Effective: September 4, 2026

1. Purpose and Scope

The records of the Healthcare Industry Resilience Collaborative, Association (“HIRC”) are critical organizational assets. This policy establishes requirements and guidelines for retaining and destroying HIRC records to support legal compliance, operational efficiency, and protection of HIRC’s rights.

This policy applies to all records created, received, or maintained by HIRC, whether in paper or electronic form, and whether maintained by employees, officers, directors, contractors, or other persons acting on HIRC’s behalf.

“Records” include, but are not limited to, memoranda, emails, contracts, financial documents, calendars, appointment books, and expense records.

2. Legal Compliance and Risk

Federal and state laws require HIRC to retain certain records for specified periods. Failure to do so may result in penalties, loss of rights, adverse litigation outcomes, or sanctions for obstruction of justice.

Accordingly, records must be retained in accordance with this policy and any applicable law.

3. Litigation Hold Requirement (Override Rule)

No record may be destroyed if it is relevant to actual or reasonably anticipated litigation, an audit, an investigation, or a dispute.

Any person subject to this policy who believes a record may be relevant to such a matter, or who receives notice from HIRC that a litigation or other records hold is in effect, must preserve all related records regardless of any otherwise applicable retention or destruction schedule.

Records subject to a hold must be preserved until the Executive Director or Secretary, after consultation with legal counsel when appropriate, confirms in writing that the hold has been lifted. Any delegation of this authority must be made in accordance with HIRC’s Bylaws.

A hold supersedes all otherwise applicable retention and destruction schedules.

Questions regarding the applicability of a hold must be directed to the Executive Director or Secretary.

4. General Retention Principles

Subject to the direction and control of the Board, the Executive Director may establish administrative procedures and supplemental retention schedules consistent with this policy to:

  1. Ensure legal compliance;
  2. Preserve intellectual property; and
  3. Manage storage and administrative costs.

A supplemental schedule may identify additional record categories or require longer retention but may not shorten a minimum retention period established by this policy unless the change is approved by the Board after consultation with legal counsel.

Minimum retention periods are provided below. Final retention decisions should also consider legal, operational, historical, and risk-management factors.

If a record falls within more than one category, it must be retained for the longest applicable retention period. Records must also be retained longer when required by applicable law, contract, records hold, or written direction from legal counsel. When the applicable retention period has expired and HIRC no longer has a legal, contractual, operational, or historical need for the record, the record should be securely destroyed in a manner appropriate to its format and sensitivity. No record may be destroyed contrary to this policy or an applicable records hold.

5. Record Categories and Retention Periods

(a) Tax and Financial Records

Includes tax filings, payroll records, expense documentation, accounting records, audits, financial statements, general ledgers, and revenue documentation.

Retention:

  1. Organizational tax returns; records establishing or documenting HIRC’s tax-exempt status; audits; financial statements; general ledgers; payroll registers; and other foundational tax and financial records: Permanent
  2. Other tax and financial records: At least seven (7) years

(b) Employment and Personnel Records

Includes recruitment records, personnel files, employment agreements and offer letters, performance reviews, disciplinary actions, complaints, and employee benefit records.

Retention:

  1. Employment offer letters, confirmation-of-employment letters, employee-specific benefit descriptions, and retirement and pension records: Permanent
  2. Other employment and personnel records: At least seven (7) years after termination of employment or final action, as applicable

(c) Board, Committee, and Governance Records

Includes meeting minutes, governing documents, Board policies, resolutions, tax-exempt status records, required corporate filings, and other official governance records.

Retention:

  1. Meeting minutes and official governance records: Permanent
  2. Other Board and committee materials: At least three (3) years

(d) Press Releases and Public Filings

Includes all documents publicly released or filed on HIRC’s behalf.

Retention: Permanent

(e) Legal Records

Includes legal opinions, litigation files, and correspondence with counsel.

Retention: Generally ten (10) years, unless legal counsel advises otherwise.

(f) Marketing and Sales Materials

Includes final versions of marketing, communications, and sales-related documents.

Retention:

  1. General marketing, communications, and sales materials: Three (3) years
  2. Sales invoices and other financial records: As provided in Section 5(a)
  3. Leases, licenses, and other agreements: As provided in Section 5(h)

(g) Intellectual Property, Development Materials, and Trade Secrets

Includes records relating to HIRC’s proprietary processes, copyrighted works, patents, trademarks, development activities, and confidential business information.

Retention:

  1. Records necessary to establish, document, license, protect, or enforce HIRC’s intellectual property rights: For the life of the applicable rights
  2. Records designated as containing trade-secret information: For at least as long as the information remains a trade secret
  3. Other development records: For the retention period applicable to their subject matter under this policy

(h) Contracts

Includes final, fully executed agreements entered into by HIRC.

Retention: At least eight (8) years after expiration or termination, and longer where legally required (including publicly filed contracts).

(i) Electronic Mail

Emails that qualify as records must be retained in a manner that preserves their content and context, either by:

  1. Printing and filing in the appropriate paper file, or
  2. Saving electronically in a designated storage system

Retention: Based on the subject matter of the email, consistent with this policy.

(j) Insurance Records

Includes insurance policies and records relating to insurance claims, coverage determinations, claim payments, and claim denials.

Retention: Permanent

6. Enforcement

Failure to comply with this policy may result in corrective or disciplinary action, as applicable, including termination of employment, removal from office, restriction of access to HIRC records or systems, or termination of a contractual or other working relationship. Any action must be taken in accordance with HIRC’s Bylaws, applicable agreements, and applicable law.

7. Questions

Questions regarding this policy or record retention obligations should be directed to the Executive Director.