Molson Group Record Retention Policy

1. Purpose

The purpose of this Policy is to ensure that necessary records and documents of MOLSON GROUP are adequately protected and maintained and to ensure that records that are no longer needed by MOLSON GROUP or are of no value are discarded at the proper time. This Policy is also for the purpose of aiding employees of MOLSON GROUP in understanding their obligations in retaining electronic documents - including e-mail, Web files, text files, sound and video files, PDF documents, and all Microsoft Office or other formatted files.

2. Policy

This Policy represents MOLSON GROUP’s policy regarding the retention and disposal of records and the retention and disposal of electronic documents. 

3. Administration

Attached as Appendix A is a Record Retention Schedule that is approved as the initial maintenance, retention and disposal schedule for physical records of MOLSON GROUP and the retention and disposal of electronic documents. The Operational Director of MOLSON GROUP (the “Administrator”) is the Director in charge of the administration of this Policy and the implementation of processes and procedures to ensure that the Record Retention Schedule is followed. The Administrator is also authorised to: make modifications to the Record Retention Schedule from time to time to ensure that it is in compliance with National legislation and includes the appropriate document and record categories for MOLSON GROUP ; monitor legislation affecting record retention; annually review the record retention and disposal program; and monitor compliance with this Policy.

In addition, any retained information can only be used for the purpose for which it is stored. This is compliant with the Data Protection Act 1998.

4. Suspension of Record Disposal In Event of Legal Proceedings or Claims

There are certain occasions when information needs to be preserved beyond any limits set out in the Policy. The Policy must be SUSPENDED relating to a specific customer or document and the information retained beyond the period specified in the MOLSON GROUP’s Data Retention Schedule in the following circumstances: 

  • Legal proceedings or a regulatory or similar investigation or obligation to produce information are known to be likely, threatened or actual. 
  • A crime is suspected or detected. 
  • Information is relevant to a company in liquidation or receivership, where a debt is due to MOLSON GROUP. 
  • Information is considered by the owning unit to be of potential historical importance and this has been confirmed by the Administrator.

In the case of possible or actual legal proceedings, investigations or crimes occurring, the type of information that needs to be retained relates to any that will help or harm MOLSON GROUP or the other side's case or liability or amount involved.

If there is any doubt over whether legal proceedings, an investigation or a crime could occur, or what information is relevant or material in these circumstances, the Administrator should be contacted and legal advice sought.

The Administrator shall take such steps as is necessary to promptly inform all staff of any suspension in the further disposal of documents.

5. Security of personal information

  • MOLSON GROUP will take reasonable technical and organisational precautions to prevent the loss, misuse or alteration of your personal information.
  • MOLSON GROUP will store all personal information on our secure (password- and firewall-protected) servers. 
  • All electronic financial transactions entered into through our website will be protected by encryption technology. 
  • All electronic financial transactions entered into through our website that are handled by third party sources will be protected by the security measures put in place by the bank or organisation in question
  • The Client should acknowledge that the transmission of information over the internet is inherently insecure, and that MOLSON GROUP cannot guarantee the security of data sent over the internet. 
  • The Client will be responsible for keeping their Username and Password used for accessing the MOLSON GROUP website confidential; MOLSON GROUP will not ask for password other than when needed to log in to our website. 

 

6. Amendments

MOLSON GROUP may update this policy from time to time by publishing a new version.

This page should be checked occasionally to ensure that the policy remains relevant.

7. Applicability

This Policy applies to all physical records generated in the course of MOLSON GROUP’s operation, including both original documents and reproductions. It also applies to the electronic documents described above. 

This Policy was approved by the Board of Directors of MOLSON GROUP on June 2nd 2014.

APPENDIX A RECORD RETENTION SCHEDULE

The Record Retention Schedule is organised as follows:

SECTION TOPIC

A. Accounting and Finance
B. Contracts
C. Corporate Records
D. Correspondence and Internal Memoranda
E. Personal Information
F. Electronic Records
G. Grant Records
H. Insurance Records
I. Legal
J. Miscellaneous
K. Personnel Records
L. Tax Records
M. Fiscal Sponsor Project Records

A. ACCOUNTING AND FINANCE

Record Type

Retention Period

Annual Audit Reports and Financial Statements

Permanent

Annual Audit Records, including work papers and other documents that relate to the audit

7 years after completion of audit

Annual Plans and Budgets

2 years

Bank Statements and Canceled Checks

7 years

Employee Expense Reports

7 years

Interim Financial Statements

7 years

Credit card records (documents showing customer credit card number)

2 years

Credit card record retention and destruction

A credit card may be used to pay for the following MOLSON GROUP products and services: The Good2Go System and all future additions to this system.

All records showing customer bank details must be locked in a desk drawer or a file cabinet when not in immediate use by staff.

If it is determined that information on a document, which contains credit card information, is necessary for retention beyond 2 years, then the credit card number will be cut out of the document.

B. CONTRACTS

Record Type

Retention Period

Contracts and Related Correspondence (including any proposal that resulted in the contract and all other supportive documentation)

7 years after expiration or termination

C. CORPORATE RECORDS 

Record Type

Retention Period

Corporate Records (minutes, signed minutes of the Board and all committees, record of incorporation, articles of incorporation, annual corporate reports)

Permanent

Licenses and Permits 

Permanent

D. CORRESPONDENCE AND INTERNAL MEMORANDA

General Principle: Most correspondence and internal memoranda should be retained for the same period as the document to which they pertain or support. For instance, a letter pertaining to a particular contract would be retained as long as the contract (7 years after expiration). It is recommended that records that support a particular project be kept with the project and take on the retention time of that particular project file. 

Correspondence or memoranda that do not pertain to documents having a prescribed retention period should generally be discarded sooner. These may be divided into two general categories:

1. Those 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. 

Please note that copies of interoffice correspondence and documents where a copy will be in the originating department file should be read and destroyed, unless that information provides reference to or direction to other documents and must be kept for project traceability.

2. Those pertaining to non routine matters or having significant lasting consequences should generally be retained permanently.

E. Retaining personal information

1. This Section sets out the data retention policies and procedure of MOLSON GROUP, which are designed to help ensure compliance with legal obligations in relation to the retention and deletion of personal information

2. Personal information that is processed by GOODTOGOLTD for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

Without prejudice to point 2 (above) MOLSON GROUP will usually delete personal data falling within the categories set out below at the date/time set out below: 

Record Type

Retention Period

Information about a computer and about visits to and use of this website (including an IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths

2 years following account closure

Information provided when registering with our website (including email address)

2 years following account closure

Information provided when completing a profile on our website (including a name, gender, date of birth, interests and hobbies, educational details)

2 years following account closure

Information provided for the purpose of subscribing to email notifications and/or newsletters (including a name and email address)

Indefinitely or until the client chooses to ‘unsubscribe’

Information provided when using the services on the website, or that is generated in the course of the use of those services (including the timing, frequency and pattern of service use)

Indefinitely

Information relating to any subscriptions made (including name, address, telephone number, email address and card details)

2 years following account closure

Information posted to our website for publication on the internet 

2 years after post

Information contained in or relating to any communications sent through the website (including the communication content and meta data associated with the communication)

2 years following contact

Any other personal information chosen to be sent

2 years following contact

Notwithstanding the other provisions of this Section, MOLSON GROUP will retain documents (including electronic documents) containing personal data: 

(a) to the extent that MOLSON GROUP is required to do so by law;
(b) if MOLSON GROUP believes that the documents may be relevant to any ongoing or prospective legal proceedings; 
(c) and in order to establish, exercise or defend MOLSON GROUP’s legal rights (including providing information to others for the purposes of fraud prevention and reducing credit risk).

Each day MOLSON GROUP will run a database backup copy of all electronic data contained on the MOLSON GROUP servers. This backup will include all information relating to all current users, as well as any information that remains on the server due to any reason contained in this policy. This database backup is a safeguard to retrieve lost information within a one year retrieval period should users on the Good2Go system experience any problems. All data backups are stored in a separate location for a time period of 14 days prior to the backup initially being stored.

F.ELECTRONIC DOCUMENTS

1. Electronic Mail: Not all email needs to be retained, depending on the subject matter. 

  • All e-mail—from internal or external sources—is to be deleted after 12 months. 
  • Staff will strive to keep all but an insignificant minority of their e-mail related to business issues. 
  • MOLSON GROUP will archive e-mail for six months after the staff has deleted it, after which time the e-mail will be permanently deleted. 
  • Staff will take care not to send confidential/proprietary MOLSON GROUP information to outside sources
  • Any e-mail staff deems vital to the performance of their job should be copied to the staff’s H: drive folder, and printed and stored in the employee’s workspace. 

2. Electronic Documents: including Microsoft Office Suite and PDF files. Retention also depends on the subject matter.

  • PDF documents – The length of time that a PDF file should be retained should be based upon the content of the file and the category under the various sections of this policy. The maximum period that a PDF file should be retained is 6 years. PDF files the employee deems vital to the performance of his or her job should be printed and stored in the employee’s workspace. 
  • Text/formatted files - Staff will conduct annual reviews of all text/formatted files (e.g., Microsoft Word documents) and will delete all those they consider unnecessary or outdated. After five years, all text files will be deleted from the network and the staff’s desktop/laptop. Text/formatted files the staff deems vital to the performance of their job should be printed and stored in the staff’s workspace. 

MOLSON GROUP does not automatically delete electronic files beyond the dates specified in this Policy. It is the responsibility of all staff to adhere to the guidelines specified in this policy.

In certain cases a document will be maintained in both paper and electronic form. In such cases the official document will be the electronic document.

G. GRANT RECORDS 

Record Type

Retention Period

Original grant proposal

7 years after completion of grant period

Grant agreement and subsequent modifications, if applicable

7 years after completion of grant period

Final grantee reports, both financial and narrative

7 years after completion of grant period

All evidence of returned grant funds

7 years after completion of grant period

Documentation relating to grantee evidence of invoices and matching or challenge grants that would support grantee compliance with the grant agreement

7 years after completion of grant period

Pre-grant inquiry forms and other documentation for expenditure responsibility grants

7 years after completion of grant period

Grantee work product produced with the grant funds

7 years after completion of grant period

H. INSURANCE RECORDS 

Record Type

Retention Period

Certificates Issued to MOLSON GROUP

Permanent

Claims Files (including correspondence, medical records, injury documentation, etc.) 

Permanent

Insurance Policies (including expired policies)

Permanent

I. LEGAL FILES AND PAPERS 

Record Type

Retention Period

Legal Memoranda and Opinions (including all subject matter files)

7 years after close of matter

Litigation Files

1 year after expiration of appeals or time for filing appeals

Court Orders

Permanent

Requests for Departure from Records Retention Plan 

10 years

J. MISCELLANEOUS

Record Type

Retention Period

Consultant's Reports

2 years

Material of Historical Value (including pictures, publications)

Permanent 

Policy and Procedures Manuals – Original

Current version with revision history 

Policy and Procedures Manuals Copies

Retain current version only

Annual Reports

Permanent

K. PERSONNEL RECORDS

Record Type

Retention Period

Employee Personnel Records (including individual attendance records, application forms, job or status change records, performance evaluations, termination papers, withholding information, garnishments, test results, training and qualification records)

6 years after separation

Employment Contracts – Individual

7 years after separation

Employment Records Correspondence with Employment Agencies and Advertisements for Job Openings

3 years from date of hiring decision

Job Descriptions

3 years after superseded

L. TAX RECORDS

General Principle: Donors Forum must keep books of account or records as are sufficient to establish amount of gross income, deductions, credits, or other matters required to be shown in any such return.

These documents and records shall be kept for as long as the contents thereof may become material in the administration of federal, state, and local income, franchise, and property tax laws.

Record Type

Retention Period

Tax-Exemption Documents and Related Correspondence

Permanent

Tax Bills, Receipts, Statements

7 years

Tax Returns 

Permanent

Sales/Use Tax Records

7 years

Annual Information Returns 

Permanent

M. FISCAL SPONSOR PROJECT RECORDS

Record Type

Retention Period

Sponsorship agreements

Permanent