Record Retention Policy

Article 1: Introduction and Purpose

1.1 Purpose

This Record Retention and Destruction Policy (the “Policy”) is adopted by the Board of Directors of the Bitcoin District Initiative (hereinafter “the Corporation”) to ensure compliance with federal and state laws, including IRS requirements for tax-exempt organizations under Section 501(c)(3) of the Internal Revenue Code and the District of Columbia Nonprofit Corporation Act (D.C. Code § 29-401 et seq.). The Policy outlines responsibilities for directors, officers, employees, volunteers, and agents in maintaining, storing, and destroying the Corporation’s records. Proper record-keeping supports the Corporation’s fiduciary duties, promotes transparency, and aids its mission to empower individuals through Bitcoin education and personal sovereignty.

1.2 Scope

This Policy applies to all physical and electronic records, including emails, digital files, and databases. Records relevant to litigation, audits, or investigations must be preserved until resolution, superseding any retention periods below.

Article 2: Retention Schedule

2.1 Retention Periods

The following schedule outlines minimum retention periods for key record categories. Permanent retention means records are kept indefinitely. All periods begin from the end of the fiscal year in which the record was created or the event occurred, unless otherwise noted.

2.1.1 Governance and Organizational Records

• Articles of Incorporation, Bylaws, and amendments: Permanent
• IRS Form 1023 (exemption application) and determination letter: Permanent
• Board and committee meeting minutes, including actions taken without a meeting (e.g., unanimous written consents): Permanent
• Board and committee materials (other than minutes): 3 years
• Annual or biennial reports filed with the District of Columbia: Permanent
• Conflict of interest disclosures and questionnaires: 7 years
• Whistleblower reports and investigations: 7 years

2.1.2 Financial and Tax Records

• IRS Form 990 returns (including schedules and attachments, with donor information redacted from public copies): Permanent
• Financial audits, reviews, or compilations: Permanent
• Annual budgets and financial statements: Permanent
• Accounting records (ledgers, journals, invoices, receipts): 7 years
• Bank statements, reconciliations, and deposit records: 7 years
• Checks (canceled, except for significant payments like taxes or property purchases): 7 years
• Donor records and acknowledgment letters: 7 years
• Grant applications and reports: 7 years (or as required by grantor)
• Contracts and leases (after expiration): 7 years

2.1.3 Employment and Personnel Records

• Personnel files for current and former employees (including performance reviews, disciplinary actions, and termination records): 7 years after termination
• Payroll records, timesheets, and withholding records: 7 years
• Employment applications (rejected applicants): 3 years
• I-9 forms: 3 years after hire or 1 year after termination, whichever is later
• Retirement and pension records: Permanent

2.1.4 Insurance and Legal Records

• Insurance policies (all types, including directors and officers liability, general liability, and property): Permanent
• Claims and incident reports: Permanent
• Legal correspondence and litigation files: Permanent (or until statute of limitations expires plus 7 years)

2.1.5 Program and Operational Records

• Educational materials, workshop records, and event documentation: 7 years
• Partnership agreements and collaboration records: 7 years (after termination)
• Correspondence (general business): 3 years
• Marketing and public awareness materials: 3 years

2.1.6 Electronic Records and Backups

• Email and electronic communications (if constituting official records, e.g., board approvals or financial transactions): Retain according to the relevant category above
• Backup files: Maintain current backups; retain historical backups for 1 year

Article 3: Destruction Procedures

3.1 Procedures

When a record’s retention period has expired, it shall be destroyed securely to protect confidential information:

• Paper records shall be shredded or incinerated.
• Electronic records shall be permanently deleted in a manner that ensures data security, following the Corporation’s standard procedures for data disposal.

The Corporation shall ensure that records are destroyed in accordance with this Policy. The Board may establish procedures for documenting destruction as deemed necessary.

Article 4: Compliance

4.1 Oversight

The Board of Directors shall oversee the implementation of this Policy. The Board may designate a person or committee to assist with monitoring compliance and addressing inquiries. Inquiries about retention or destruction should be directed to the designated person or committee, or to any member of the Board if no such designation has been made.

4.2 Policy Review

The Board shall regularly review this Policy and update it as needed to reflect the Corporation’s needs or legal requirements.

4.3 Violations

Violations of this Policy may result in disciplinary action, up to and including removal or termination.