Data Retention and Archival Policy
Establish consistent retention requirements for compensation-related documents and data to ensure compliance with legal and regulatory requirements, audit readiness and supportability, appropriate data destruction, and balance between retention needs and cost/risk management.
1Purpose & Objectives
Establish consistent retention requirements for compensation-related documents and data to ensure compliance with legal and regulatory requirements, audit readiness and supportability, appropriate data destruction, and balance between retention needs and cost/risk management.
- •Ensure compliance with legal and regulatory requirements
- •Maintain audit readiness and supportability
- •Establish appropriate data destruction procedures
- •Balance retention needs with cost and risk management
2Scope
Applies To
- •Electronic documents (Word, Excel, PDF, etc.)
- •System data (ICMT, CRM, ERP, HRIS)
- •Email communications
- •Paper records
- •Audio/video recordings (if any)
3Definitions
Active Storage
Storage for current plus 3 years of data in primary systems (ICMT, HRIS, Finance/ERP, Email) readily accessible by authorized users.
Archive Storage
Storage for years 4-7 in secure archive server, cloud archive, or offline backup media, retrievable within 5 business days upon request.
Legal Hold
Exception to normal destruction schedule when litigation, investigation, or audit is pending or reasonably anticipated, requiring immediate suspension of all destruction of potentially relevant records.
Destruction Log
A permanent log maintaining date of destruction, description of records destroyed, retention period applied, authorization, method of destruction, and certificate of destruction.
4Key Provisions
All compensation-related records must be retained according to the defined schedule, with 7 years as the standard retention period.
Plan Design Documentation
Retention requirements for plan design documents:
- •Plan documents (approved versions): 7 years after plan ends - Governance repository
- •Plan design models and analysis: 7 years after plan ends - Shared drive
- •Market benchmark data: 3 years - Comp team files
- •Approval records (CRB minutes, etc.): 7 years - Secure archive
Participant Data
Retention requirements for participant data:
- •Eligibility records: 7 years after termination - HRIS + ICMT
- •Quota assignments: 7 years - ICMT
- •Performance data: 7 years - ICMT + Data warehouse
- •Payout calculations: 7 years after payment - ICMT
- •Payment records: 7 years after payment - Finance systems
- •Participant statements: 7 years after issuance - ICMT / Archive
Financial Records
Retention requirements for financial records:
- •Accrual calculations: 7 years - Finance systems
- •GL reconciliations: 7 years - Finance systems
- •Budget vs. actual reports: 7 years - Finance systems
- •Tax withholding records: 7 years minimum - Payroll/Finance
- •W-2 copies: Permanent - HR/Payroll
System and Audit Documentation
Retention requirements for system and audit documentation:
- •System configuration history: 7 years - ICMT / IT
- •Audit reports (internal/external): 7 years - Governance archive
- •Control testing documentation: 7 years - Finance / Audit files
- •Data validation logs: 3 years - ICMT logs
Communications
Retention requirements for communications:
- •Plan rollout communications: 7 years - Governance repository
- •Participant acknowledgments: 7 years after termination - ICMT / HR
- •Email re: plan interpretation: 3 years - Email archive
- •Training materials: Current version + 3 years - Training repository
Disputes and Exceptions
Retention requirements for dispute and exception records:
- •Dispute records: 7 years after resolution - ICMT / Legal files
- •Exception requests and approvals: 7 years - ICMT / Governance files
- •Investigation files: 7 years after close - HR / Legal files
5Compliance References
Federal Laws
- •IRS retention requirements (minimum 3 years, 7 years recommended)
- •SOX (Sarbanes-Oxley Act) audit documentation requirements
- •FLSA (Fair Labor Standards Act) - 3 years certain records
- •EEOC - 1 year employment records
State Laws
- •State wage laws (3-7 years depending on state)
- •California: 3 years minimum (4 years recommended)
- •New York: 6 years (wage theft prevention)
- •Texas: Federal standards (FLSA 3 years)
- •CCPA data privacy requirements