The Corporate Retention Policy serves as a crucial governance document that enables organizations to effectively manage their records while maintaining compliance with Canadian legal requirements. This document is essential for establishing standardized practices for retaining, protecting, and disposing of various types of corporate records, from financial documents and employee records to electronic communications and contractual agreements. The policy must align with multiple Canadian legislative requirements, including the Canada Business Corporations Act, Income Tax Act, and PIPEDA, while also accommodating industry-specific regulations and organizational needs. It should be implemented when an organization needs to establish or update its records management practices, particularly in response to regulatory changes, organizational growth, or risk management initiatives.
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1. Purpose and Scope: Defines the objective of the policy and its application across the organization, including all affected departments and types of records
2. Definitions: Clear definitions of key terms used throughout the policy, including 'record', 'retention period', 'disposition', 'legal hold', etc.
3. Roles and Responsibilities: Outlines who is responsible for records management, including specific duties of employees, managers, IT department, and legal team
4. Record Classification: Establishes how records are categorized and classified within the organization
5. Retention Requirements: General principles and requirements for record retention, including minimum retention periods and basis for determining retention periods
6. Storage and Protection: Requirements for secure storage, including physical and electronic storage requirements
7. Disposition Procedures: Procedures for proper destruction or deletion of records after retention period expires
8. Legal Holds: Process for implementing and managing legal holds that suspend normal retention and disposition procedures
9. Compliance and Audit: Procedures for ensuring compliance with the policy and conducting regular audits
1. Electronic Records Management: Detailed procedures specific to electronic records management, including backup procedures and electronic storage requirements. Include if organization heavily relies on electronic records.
2. International Operations: Special considerations for records maintained in different jurisdictions. Include if organization operates internationally.
3. Industry-Specific Requirements: Additional retention requirements specific to certain industries (e.g., healthcare, financial services). Include based on organization's industry.
4. Privacy and Data Protection: Detailed procedures for protecting personal and sensitive information. Include if organization handles significant amounts of personal data.
5. Emergency Procedures: Procedures for protecting and recovering records in case of disasters. Include if organization has specific disaster recovery requirements.
1. Schedule A - Retention Periods by Record Type: Detailed matrix of record types and their specific retention periods, organized by department or function
2. Schedule B - Record Classification Guide: Detailed guide for classifying different types of records within the organization's classification system
3. Schedule C - Disposition Procedures: Detailed procedures for different methods of record disposition based on record type and sensitivity
4. Appendix 1 - Forms: Standard forms used in records management, including disposition approval forms and legal hold notification forms
5. Appendix 2 - Compliance Checklist: Checklist for regular audits and compliance reviews of records management practices
6. Appendix 3 - Legislative Requirements: Summary of relevant legislative requirements affecting retention periods by jurisdiction
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