Enablers Association Document Retention Policy
Version: 1.0
Effective Date: 1 January 2026
Approved by: Enablers Mission Circle
Questions? [email protected]
- Purpose
This policy establishes retention periods for Association documents to ensure compliance with Swiss legal requirements, tax obligations, and good governance practices while avoiding unnecessary accumulation of outdated records.
- Legal Requirements
Swiss Law requires retention of:
- Accounting records: 10 years (Swiss Code of Obligations Art. 958f)
- Business correspondence: 10 years
- Supporting documents for accounting: 10 years
- Contracts: 6 years after termination (general statute of limitations)
GDPR requires:
- Personal data retained only as long as necessary for purpose
- Specific retention schedules documented (see Privacy Policy)
- Retention Schedules by Document Type
3.1 Financial and Accounting Records
Retention: 10 years from end of fiscal year
Includes:
- Annual financial statements and balance sheets
- General ledger and journals
- Bank statements and reconciliations
- Invoices (issued and received)
- Payment records and receipts
- Expense reports and supporting documentation
- Tax returns and tax payment records
- Audit reports
Reason: Swiss tax law and Code of Obligations requirements
3.2 Client Contracts and Project Records
Retention: 6 years after contract termination or project completion
Includes:
- Master Service Agreements (MSAs)
- Individual Project Agreements (IPAs)
- Statements of Work
- Contract amendments and addendums
- Client correspondence related to contracts
- Project deliverables (final versions)
- Client approval and acceptance documentation
Reason: Swiss statute of limitations (Art. 127 Swiss Code of Obligations)
Exception: Delete participant personal data per GDPR schedule (typically 30 days after project completion) even if other project records retained.
3.3 Insurance Records
Retention: 6 years after policy expiry
Includes:
- Professional liability insurance policies and certificates
- Member individual insurance certificates
- Insurance claims and correspondence
- Coverage verification records
Reason: Potential claims may arise years after services delivered
3.4 Member Records
Active Members:
- Retain all records during active membership
Former Members – Retention: 6 years after membership termination
Includes:
- Membership agreements and applications
- Policy acknowledgments
- Training and certification records
- Performance evaluations
- Disciplinary records (if any)
- Correspondence regarding membership
Delete sooner:
- Personal data not required for legal/financial purposes: 3 years after termination (per Privacy Policy)
- Photos and marketing materials: 30 days unless explicit consent for continued use
3.5 Governance Records
Retention: Permanent
Includes:
- Association Statuts (bylaws) and all amendments
- General Assembly meeting minutes
- Association Committee meeting minutes
- Circle meeting minutes (all circles)
- Membership registers
- Annual reports to authorities
Reason: Historical record, legal compliance, governance continuity
3.6 Policies and Procedures
Retention: Permanent
Includes:
- All Association policies (current and superseded versions)
- Operating procedures and guidelines
- Code of Conduct and professional standards
Reason: Track policy evolution, demonstrate compliance history
3.7 Compliance and Legal Records
Retention: 6 years after matter closes
Includes:
- Conflict of interest disclosures and resolutions
- Incident reports and investigation records
- Legal opinions and advice
- Regulatory correspondence
- Compliance audit records
Exception: If ongoing legal matter, retain until matter fully resolved plus 6 years
3.8 Personal Data (GDPR)
Retention: Per Privacy Policy and Data Protection Agreements
Includes:
- Member personal information: 3 years after membership ends
- Website visitor data: 26 months (Google Analytics automatic deletion)
- Newsletter subscriber data: Until unsubscribe + 30 days
- Client project participant data: 30 days after project completion (working files)
Financial/legal records with personal data: Retain per financial/legal schedule above, not GDPR schedule
See Privacy Policy Section 8 for complete retention schedules
3.9 Correspondence and Communications
General business correspondence: 3 years
Client-related correspondence: 6 years after engagement ends
Legal/compliance correspondence: 6 years after matter closes
Internal communications (WhatsApp, informal emails): Not retained systematically
3.10 Marketing and Communications Materials
Retention: 3 years or until superseded
Includes:
- Website content (keep version history)
- Newsletter archives
- Marketing presentations
- Case studies and testimonials
- Blog posts and articles
Longer retention acceptable for historical/archival purposes
- Storage and Access
During Retention Period:
- Documents stored securely per Information Security Policy
- Google Drive primary repository for electronic documents
- Access restricted to authorized personnel
- Annual review of stored documents to verify retention compliance
Responsible Party:
- Compliance Contact maintains retention schedule tracking
- Committee member designated for financial record custody
- All members responsible for documents in their possession
- Destruction Procedures
When retention period expires:
Electronic Documents:
- Permanent deletion from Google Drive (empty Trash)
- Remove from any backup systems
- Document destruction date in retention log
Physical Documents (if any):
- Shred or destroy securely
- Do not simply discard in regular trash
- Document destruction date in retention log
Personal Data: Follow Privacy Policy procedures for data deletion
Confidential Information: Ensure complete destruction, not just deletion (overwrite if possible)
- Legal Hold
If any document becomes subject to litigation, investigation, or audit:
- Do NOT destroy, even if retention period has expired
- Notify [email protected] immediately
- Place “legal hold” on documents
- Retain until legal matter fully resolved
- Then apply normal retention period from resolution date
- Annual Review
Each January:
- Compliance Contact reviews all stored documents
- Identifies documents eligible for destruction
- Coordinates destruction of expired documents
- Updates retention log
- Reports to Association Committee on compliance
- Exceptions and Approvals
Retention beyond scheduled period:
- May be approved by Network Development Circle for legitimate business reasons
- Must document reason and review date
- Examples: ongoing business relationship, historical significance, pending litigation
Early destruction:
- Requires approval from Enablers Mission Circle
- Only in exceptional circumstances
- Must document reason
- Never permitted for financial, legal, or regulatory records
- Relationship to Other Policies
This policy works together with:
- Privacy Policy: Personal data retention schedules
- Information Security Policy: Secure storage during retention period
- Confidentiality Policy: Confidential information handling
- Data Protection Agreements with Clients: May impose different/additional retention requirements
If conflict: More stringent requirement applies
- Responsibilities
Compliance Contact ([email protected]):
- Maintain retention schedule and tracking log
- Coordinate annual review and destruction
- Answer retention questions
- Monitor compliance
Association Committee:
- Designate custody for financial records
- Approve exceptions to standard retention
- Oversee compliance
All Members:
- Follow retention schedules for documents in their possession
- Delete participant data within 30 days of project completion
- Consult [email protected] with questions
- Report documents subject to legal hold
Quick Reference: Retention Periods
|
Document Type |
Retention Period |
Trigger |
|
Financial records |
10 years |
End of fiscal year |
|
Client contracts |
6 years |
Contract termination |
|
Member agreements |
6 years |
Membership termination |
|
Insurance certificates |
6 years |
Policy expiry |
|
Meeting minutes |
Permanent |
N/A |
|
Policies |
Permanent |
N/A |
|
Personal data (working files) |
30 days |
Project completion |
|
Personal data (general) |
3 years |
Membership/relationship ends |
|
General correspondence |
3 years |
Creation date |
|
Compliance records |
6 years |
Matter closes |
Questions? [email protected]
Acknowledgment: I have read and understood the Document Retention Policy and will comply with retention schedules for documents in my possession.
Member Name: _______________
Signature: _______________
Date: _______________