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Records Retention and Destruction Policy

Wounded Warriors d/b/a Warriors Fund · EIN 86-1336741
Adopted by the Board of Directors: January 15, 2024 · Reviewed annually.

1. Purpose

This policy establishes guidelines for the retention and destruction of records held by Wounded Warriors (the "Organization"). It ensures the Organization complies with federal and state law, preserves essential records, and disposes of records that no longer have administrative, legal, or historical value.

2. Scope

This policy applies to all records created, received, or maintained by the Organization, regardless of format — paper, electronic, audio, video, or other media. It binds every director, officer, employee, volunteer, contractor, and agent acting on the Organization's behalf.

3. Record Retention Schedule

The following retention periods begin at the end of the fiscal year in which the record was created or last amended, unless otherwise specified.

Record CategoryRetention Period
Articles of Incorporation, Bylaws, CharterPermanent
IRS 501(c)(3) Determination Letter, Exemption ApplicationsPermanent
Board and Committee Minutes, ResolutionsPermanent
Form 990, Form 990-T, state annual filingsPermanent
Audited financial statementsPermanent
General ledger, journal entries, trial balances7 years
Bank statements, reconciliations, canceled checks7 years
Accounts payable/receivable records, invoices, purchase orders7 years
Payroll records, W-2s, 1099s, tax deposits7 years
Employee files (after termination)7 years
Contracts, leases, insurance policies (after expiration)7 years
Grant agreements and supporting documentation (after closeout)7 years or funder requirement, whichever is longer
Donor records, acknowledgment letters, pledge agreements7 years
Litigation recordsPermanent or as required by counsel
General correspondence3 years
Website content and marketing materials3 years
Volunteer records3 years after service ends
Data privacy records (deletion requests, consent logs)3 years after request

4. Electronic Records

Electronic records — including email, database records, backups, and cloud-stored files — are subject to the same retention schedule as paper records. The Organization maintains encrypted backups and version history where technically feasible. Electronic records scheduled for destruction must be deleted from primary storage, backups, and any replicated copies.

5. Destruction of Records

Records that have met their retention period must be destroyed in a manner appropriate to their sensitivity:

The Treasurer maintains a Destruction Log recording the category of records destroyed, the method, the date, and the authorizing officer.

6. Litigation Hold

If litigation, government investigation, audit, or subpoena is reasonably anticipated or pending, all destruction under this policy is immediately suspended for records potentially relevant to the matter. A litigation hold is lifted only by written notice from the Organization's counsel or the Board.

7. Responsibility and Enforcement

The Treasurer has primary responsibility for implementing this policy. The Executive Director ensures all staff are trained on record-handling obligations. The Board reviews this policy annually. Violations may result in disciplinary action up to and including termination, and may trigger reporting to external authorities where required by law.

8. Amendments

This policy may be amended only by a majority vote of the Board of Directors. The current version is published at warriorsfund.org/transparency.

Adopted by the Board of Directors on January 15, 2024. Current version: 2026-04-21.
Dillon Parkes, Executive Director · Warriors Fund · 1790 Hughes Landing Blvd, Suite 400, The Woodlands, TX 77380 · info@warriorsfund.org