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55 HB Fiscal Polices a Procedures <br /> ,Section - • • Retention <br /> A. Overview <br /> This section applies to the retention, maintenance and destruction of HB's records and <br /> documents. In accordance with the Sarbanes-Oxley Act, which makes it a crime to alter, cover up, <br /> falsify, or destroy any document with the intent of impeding or obstructing any official <br /> proceeding, this policy provides for the systematic review, retention, and destruction of <br /> documents received or created by HB in connection with the transaction of organization business. <br /> B. Policies <br /> 1. Maintain records as required by government regulations, grant requirements, audit <br /> requirements, and other legal needs as may be determined. <br /> 2. Obtain Board approval for any exceptions to the record retention requirements. <br /> 3. Protect data and information from unauthorized access, use, modification, disclosure, and <br /> destruction. <br /> C. Process Description <br /> User Access <br /> Prior to being given access to any confidential information, incoming employees are required to <br /> sign a Privacy Policy concerning access to and use of confidential information. HB full implements <br /> authorization and privilege controls for the network operating system and applications, as well as <br /> specific applications and information. <br /> Maintenance of Accounting Records <br /> The design and implementation of a file structure is critical to having a fully documented, <br /> completely traceable, and fully usable accounting system. The types of accounting records the <br /> organization maintains include all original documentation submitted to substantiate transactions <br /> recorded on the general ledger and the financial reports issued to management, the Board of <br /> Directors, and the public. <br /> Accounting File <br /> Maintain electronic and hard copy files which contain the accounting files listed above. Maintain <br /> all current hard copies of accounting documents, contracts, and funder agreements at the <br /> organization's main office with access is limited to authorized users only. <br /> Permanent File <br /> Maintain a permanent file including audits, incorporation papers, personnel policies, corporate-by- <br /> laws, board reports and other documents that span calendar and fiscal periods in the main office <br /> with access limited to authorized users only. Maintain electronic back-up copies and hard copies <br /> off-site. <br /> Electronic Financial Records <br /> Access to electronic financial records is available to authorized users on a shared and limited <br /> basis. HB incorporates the internal control concept of separation of duties in assigning access to <br /> its electronic financial records. Electronic records are backed-up daily and stored on a virtual <br /> server. <br /> Last updated September 2022 <br />