RECORDS RETENTION AND DISPOSITION POLICY Adopted May 21, 2008

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1 RECORDS RETENTION AND DISPOSITION POLICY Adopted May 21, 2008 Policy It IS the Lawrenceville Housing Authority s (LHA) policy regarding the retention and disposition of records to comply with local, state and federal laws. The LHA will retain records in a manner consistent with HUD s proscribed retention schedules. Date may be retained in electronic or paper format. The LHA will secure data in a manner so as to restrict access to only personnel authorized by the Executive Director, and at no time shall such records, regardless of format, be left available for public inspection. At all times EIV data will be protected in accordance with HUD s EIV PHA Security Procedures Guidebook, hereby incorporated into this policy by reference. Purpose The purpose of this policy is to ensure that necessary records and documents are adequately protected and maintained and to ensure that records that are no longer needed or of no value are discarded at the appropriate time. Records management and retention policies apply to all records, regardless of format, whether they be paper, electronic, or microform (e.g., microfilm, microfiche, magnetic tapes, and CD-ROM), and other more traditional media. The LHA encourages record retention in an electronic format whenever feasible. Administration The Executive Director is charged with the retention and disposition of LHA records. The Executive Director may delegate this role to other staff. Records designated as permanent should specify a storage location. For example, the Annual Contributions Contract (ACC) should state,, fireproof storage cabinet. Adoption of this policy does not relieve or otherwise affect the pre-existing obligation to maintain records relating to a matter under litigation, government, or investigation. Record Retention and Disposition Policy 1

2 All such records should be preserved until the matter to which they relate has been finally resolved and the Executive Director and/or legal counsel has approved their disposition. RECORDS RETENTION Electronic Records Electronic records shall be kept permanently or until such time that the LHA is assured that those records are no longer necessary. Electronic records, pas and present, shall be maintained in a manner consistent with HUD s EIV PHA Security Procedures Guidebook. Electronic records shall be periodically archived (at least once per fiscal year) from hard disk storage to removable storage such as CD, DVD, portable hard drives, etc. Paper Records Paper records shall be periodically archived as needed (at least once per fiscal year) and placed in a secure location. The following record retention schedule shall be observed for paper records: Adjustment Slips Record Type Administrative Contracts, including amendments, waivers, and related correspondence Analytical Tenant Ledger Control Minimum Retention Length Dispose 2 years following Dispose of 4 years following Annual Contributions Contract, including amendments, waivers and related correspondence Application files (admission), other than copies in tenant files: 1. Pending and eligible applications. Disposal not recommended while so classified 2. Selected applications. Disposal not recommended while so classified 3. Withdrawn and ineligible applications. Disposal 2 years from time applications are classified, withdrawn, or ineligible Application for reservation of Low-Income Public Housing funds and for Preliminary Loan Bank statements, reconciliations and cancelled checks Budgets; operating and supporting schedules for each fiscal year of operation; revision, other budget data, and related records Cash disbursement and cash receipts register Cash receipts (rent, security deposits, other income, etc) Certificate of cremation bonds and interest coupon Construction, demolition, and equipment contract records 1. Bid forms, notice to proceed, progress reports, photos and other related records, except those in item 2 Dispose when 6 years old Dispose when 6 years old close of fiscal year end Dispose 3 years following report of date Transfer to storage after final contract settlement final contract settlement Record Retention and Disposition Policy 2

3 2. Contract forms, specifications, plans and addenda, including change orders, guarantee bonds, and special warranties 3. Contractor s payroll Dispose 3 years following date of completion of contract 4. Architects and Engineers Contracts Same as item 1 Contract register, development Dispose 2 years following of development costs or 3 years following issuance of Actual Development Cost Certificate, whichever is latter. Contract register, management Dispose 3 years following contract settlement Contracts for financial assistance including amendments, waivers, and related correspondence Cooperation agreements and amendments Correspondence files pertaining to routine management and Disposal 2 years following maintenance matters Correspondence which involves no policy matters Disposal 2 years following Correspondence which involves policy and procedure matters Development cost records Expense ledger close of fiscal year Financial Reports LOW INCOME PUBLIC HOUSING For Preliminary Loan Contracts Balance Sheet Preliminary Loan Period, Form HUD Statement of Preliminary Planning Cost, Form HUD ACC and Administration Contracts Balance Sheet, Form HUD Statement of Income and Expenses and Changes in Accumulated Surplus or Deficit from Operations, Form HUD Statement of Voucher for Accruing Annual Contributions, Form HUD Analysis of Nonroutine Expenditures, Form HUD Statement and Voucher for Accruing Annual Contributions, Form HUD Statement of Initial Operating Income and Expenses, Form HUD Computation of PILOT, Form HUD Section 23 Projects Forms HUD-52595, 52596, 52598, 52599, 52981, Financing Records Preliminary Loan Notes, including related documents and correspondence and payment of note Advance Notes including related documents and correspondence and payment of note Temporary Notes including related documents and correspondence Dispose 7 years following and payment of note Records relating to permanent financing: Bonds and Notes, including Record Retention and Disposition Policy 3

4 related documents and correspondence Fiscal Agents Agreements General Depository Agreement General Ledger in a binder Income Ledger Initial operating ledger Insurance and fidelity bonds Insurance register Inventory of Expendable Equipment, Materials, and Supplies, or Nonexpendable equipment Management Reports Project reports, Report on families moving into Low-Income Public Housing Report on occupancy Report on Regular Reexamination of families in PHA Report on Initial Occupancy of Low-Income Public Projects, Form HUD Regional Office Reports Coordinated management reports Individual Management Reports 1. Management Review 2. Occupancy Audit 3. Utilities Review 4. Project Engineering Survey 5. Maintenance Operations Review 6. Review by Specialists Regional Office Reports Audit reports Minutes of Meetings of PHA, complete with resolutions, motions, notices of meetings, certificates of the Secretary and other related documents Motor Vehicle Titles Nonexpendable Equipment Record Cards close of fiscal year. expiration date Dispose 6 years after Dispose 5 years after Dispose 4 years after Dispose 4 years after Dispose 4 years after Dispose 4 years after Dispose of all but the two latest Dispose of all but the two latest Disposal when PHA disposes of vehicle Dispose 3 years after item is disposed of Personal Property Disposition Records: Bid and contract forms, bills of sale, other documents evidencing sale 1. Transaction amount $1,000 or less Dispose 5 years after final payment 2. Transaction amount between $1,001 and $25,000 Dispose 5 years after final payment 3. Transaction amount $25,001 and over Dispose 10 years after final payment Personnel Records 1. Employee records of PHA employees Dispose 10 years after employee separation 2. Individual earning records of PHA employees 3. Leave records of employees Record Retention and Disposition Policy 4

5 4. Position Description of PHA employees Dispose 3 years after position is abolished or position description is suspended 5. Payrolls Dispose 4 years after 6. Unsuccessful Applications for employment Dispose 6 months following date of application Petty Cash vouchers Preliminary Planning Cost Ledger Property Ledger Real Property Disposition Records Rent Roll Control and analysis of dwelling rent charges Request for refund of security deposit and unearned rent Revolving fund, including general ledger, cash receipts, register and cash disbursements register Schedules of Auditor s Adjustments Schedule of Maximum Income Limits Related Material Schedules of Rents Demonstration of Financial Feasibility and Related Materials Schedule of Tenant Accounts Receivable Summaries of Daily Time Reports Tenant Account Receivable and Security Deposit Ledger Sheets Tenant Files transfer from preliminary planning cost to general ledger end of fiscal year involved Dispose 5 years following Dispose 5 years following Dispose 15 years following end of fiscal year Dispose 1 year after schedule is suspended Dispose 1 year after schedule is suspended Dispose 2 years after Dispose 4 years after Dispose 3 years after for accounts with zero balances of where the claims amount to $25 or less. For claims amounting to more than $25, dispose after conclusion of the case Dispose five years after RECORDS DISPOSITION AND DESTRUCTION Following the schedule listed above, confidential records shall be destroyed in a manner consistent with measures to protect data. Records may be retained for a longer duration than the schedule listed above but must be retained for a minimum of the schedule. The LHA may, at its discretion, retain documents indefinitely. Acceptable destruction methods for paper records include: 1. Shredding through a properly bonded shredding agency, and 2. Shredding on-site and burning the shredded documents. Record Retention and Disposition Policy 5

6 Acceptable destruction methods for electronic records include: 1. Shredding CDs, DVD s, etc. 2. Use of US Department of Defense-approved data erasure software. Record Retention and Disposition Policy 6