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1 I. Authority The Executive Committee is vested with the power to adopt a policy on behalf of the Interstate Commission during periods when the Interstate Commission is not in session. The Executive Committee oversees the day-to-day activities managed by the Executive Director. II. Applicability This Policy applies to all physical and electronic records produced by ICAOS. Records and documents produced by the Council of State Governments (CSG) on behalf of its Affiliates are maintained in accordance with policies and procedures established by CSG. See Schedule B. This policy is not applicable to records or documents produced by member states that are maintained in accordance with policies and procedures established by their respective states. III. Policy The policy is to ensure that records and documents produced the Commission for are adequately protected. IV. Administration A. The Assistant Executive Director in conjunction with the Council of State Governments is responsible for the implementation and administration of the record retention schedule shown in Schedule A. B. Suspension of Record Disposal In the Event of Litigation or Claims 1. In the event ICAOS becomes party to a court action, a government investigation, or audit the disposal of any and all records and documents shall be suspended until such time as the Executive Director, with the advice of counsel, determines otherwise. C. Record Keeping 1. Whenever an employee disposes of records in accordance with the schedule outlined in Schedule A, the employee shall prepare a written log identifying the records and documents destroyed, the date destroyed and by whom. The logs are to be maintained by the Assistant Executive Director.

2 SCHEDULE A RECORD RETENTION SCHEDULE (ICAOS) A. ACCOUNTING AND FINANCE Budget Worksheets and Plans and Projections Invoices Credit Card Statements Original grant proposal Grant agreement and subsequent modifications All requested IRS/grantee correspondence Final grantee reports, both financial and narrative All evidence of returned grant funds All pertinent formal correspondence Report assessment forms Pre-grant inquiry forms and other documentation for expenditure responsibility grants Grantee work product produced with the grant funds after completion of grant period after completion of grant period after completion of grant period after completion of grant period after completion of grant period after completion of grant period after completion of grant period after completion of grant period after completion of grant period B. CONTRACTS Contracts and Related Correspondence (including any proposal that resulted in the contract and all other supportive documentation) Memorandum of Understanding with CSG Statements of work for ICOTS Hotel vendor contracts 36 months after expiration or termination 36 months after expiration or termination 36 months after completion 36 months after contracted dates C. Commission RECORDS Minutes of all Commission Meetings Corporate Seals Articles of Incorporation Commission Rules and Bylaws

3 Annual Corporate Reports D. CORRESPONDENCE AND INTERNAL MEMORANDA 1. Correspondence and internal memoranda pertaining to routine matters and having no significant, lasting consequences should be discarded within two years. Some examples include: Routine letters and notes that require no acknowledgment or follow-up, such as notes of appreciation, congratulations, letters of transmittal, and plans for meetings. Form letters that require no follow-up. Letters of general inquiry and replies that complete a cycle of correspondence. Letters or complaints requesting specific action that have no further value after changes are made or action taken (such as name or address change). Other letters of inconsequential subject matter or that definitely close correspondence to which no further reference will be necessary. Chronological correspondence files. 2. Correspondence and memoranda pertaining to non-routine matters or having significant lasting consequences should generally be retained permanently. Some examples include: Sensitive or confidential correspondence affecting business processes, responsibilities, or standards. E. ELECTRONIC DOCUMENTS 1. Electronic Mail: shall, unless noted otherwise below, be retained for six months, after which time it can be deleted. Email attachments are to be handled according to topic as set forth in this policy. Administrative Correspondence: Includes, though is not limited to clarification of established company policy, including holidays, time card information, dress code, work place behavior and any general administrative information. Administrative correspondence can be deleted after six months. Fiscal Correspondence: Includes all information related to revenue and expenses. Fiscal correspondence is retained according to the accounting guidelines set forth in this policy. General Correspondence: Includes information as it relates to customer/member interaction and operational decisions. General correspondence is retained according to the guidelines set forth in this policy. Momentary Correspondence: Includes personal email, requests for recommendations and review, carbon copy emails, project development, and status updates. Momentary correspondence can be deleted after six months.

4 2. Electronic Documents: Retention depends on the subject matter. PDF documents PDF files are retained based upon the content of the file and the category under the various sections of this policy. Faxed Documents Fax documents are retained based upon the content of the file and the category under the various sections of this policy. The Council of State Governments runs backup copies of all electronic files (including email) on the Council of State Governments servers, as specified in their Disaster Recovery Plan. This backup is a safeguard to retrieve lost information should documents on the network experience problems. Both email and workstation files can be retrieved for up to one month. In the event an electronic document, as defined above, is maintained in both paper and electronic form, the official document will be the electronic document. For all other documents maintained in both paper and electronic form, the official document will be the paper document. F. LEGAL FILES AND PAPERS Legal Advisory Opinions Dispute Resolutions Mediations Bench Book for Judges Rules Litigation Files Court Orders : Current version/revision history G. MISCELLANEOUS Commission Policies and Procedures Annual Reports Inventory Records Training Curriculum and Presentations Training Bulletins (ICAOS and ICOTS) Newsletters (ICAOS and ICOTS) ICOTS Audit Information and Responses Offender Data Collection Best Practices Documents 5 Years 3 years

5 Self Assessment Audits Surveys H. PERSONNEL RECORDS Commissions/Bonuses/Incentives/Awards Personnel Annual Reviews Personnel Contact Information Disciplinary Documents Personnel Training Plans 1 year after separation 1 year after separation 3 years or upon separation I. INTERSTATE COMPACT OFFENDER TRACKING SYSTEM (ICOTS) All offender records and case information entered in ICOTS by member states is the property of the member states and is maintained according to the laws and policies of the member states. ICOTS entries and attachment will not be disposed of without the express written permission of the member state that provided the information. Request for record disposal will be kept permanently. ICOTS Audits A. PERSONNEL RECORDS SCHEDULE B - RECORD RETENTION SCHEDULE (CSG) Records retained by the Council of State Governments: Personnel files (employee demographic information and compensation records) I-9 s Personnel files (payroll records and summaries including records related to employee s leave) Employee Earnings Records Personnel Records (including individual attendance records, application forms, job or status change records, performance evaluations, termination papers, training and qualification records) Personnel files (terminated employees) 1 year after termination or 3yrs after hire

6 Retirement and pension records Tax Returns and worksheets Timesheets Workers Compensation Personnel Policies Job Descriptions B. INSURANCE RECORDS Annual Loss Summaries Claims Files (including correspondence, medical records, injury documentation, etc.) Group Insurance Plans - Active Employees Group Insurance Plans Retirees Insurance Policies (including expired policies) C. PAYROLL DOCUMENTS Employee Deduction Authorizations Payroll Deductions W-2 and W-4 Forms Garnishments, Assignments, Attachments Labor Distribution Cost Records 8 years Payroll Registers (gross and net) 8 years D. ACCOUNTING AND FINANCE Accounts Payable ledgers and schedules Accounts Receivable ledgers and schedules Audit Reports and Financial Statements Audit Records (Including work papers and other documents that relate to the audit) Bank Statements and Canceled Checks Expense Reports General Ledgers Investment Records 7 years

7 Credit card records Depreciation records E. PROPERTY RECORDS Lease Agreement/Property Deed Property Insurance F. TAX RECORDS Tax-Exemption Documents and Related Correspondence IRS Rulings Excise Tax Records Tax Bills, Receipts, and Statements Tax Returns - Income, Franchise, Property Tax Workpaper Packages Originals Sales/Use Tax Records Annual Information Returns - Federal and State IRS or other Government Audit Records