Record retention and document destruction policy

Wikimedians in New England Inc. (“Corporation”) takes seriously its obligations to preserve information relating to litigation, audits, and investigations. The Sarbanes-Oxley Act of 2002 makes it a crime to alter, cover up, falsify, or destroy any document to prevent its use in an official proceeding. Failure to follow this policy can result in possible civil and criminal sanctions against the Corporation and its employees, directors and officers and possible disciplinary action against responsible individuals.

The Corporation will retain documents in accordance with Generally Accepted Accounting Practices and applicable laws. The Corporation shall retain records for the period of their immediate or current use, unless longer retention is necessary for historical reference or to comply with contractual or legal requirements. Records and documents outlined in this policy includes paper, electronic files (including e-mail) and voicemail records regardless of where the document is stored, including network servers, desktop or laptop computers and handheld computers and other wireless devices with text messaging capabilities.

From time to time, the President, Chair of the Legal Committee, or the Chair of the Audit Committee may issue a “legal hold,” suspending the destruction of any records due to pending, threatened, or otherwise reasonably foreseeable litigation, audits, government investigations, or similar proceedings. Notice of a legal hold shall be posted on the internal email list of the Corporation. No records specified in any legal hold may be destroyed, even if the scheduled destruction date has passed, until the legal hold is withdrawn in writing by the person placing the hold, unless said destruction is required by law.

Records may be destroyed by any means that ensures that any Personally Identifiable Information (PII) is irrevocably inaccessible. Personally Identifiable Information refers to information which can be used to distinguish or trace an individual’s identity, including (but not limited to) their name, social security number, biometric records, credit card information, date or place of birth, mother’s maiden name, or other information that either alone, or in combination with other personal or identifying information is linked or linkable to a specific individual.