Employee & Organisational Record Retention Policy

Employee & Organisational Record Retention Policy

Version 1.0 | Approved: March 2026 | Next Review: March 2027

1. Purpose

This policy sets out how Generocity Church stores, manages, and disposes of employee and organisational records in compliance with Australian law, including the Fair Work Act 2009, the Privacy Act 1988, ATO requirements, NSW employment legislation, and child safety obligations.

Proper record retention protects the church, its employees, and the people we serve — particularly children. It also ensures we can meet our legal obligations and respond to any audit, dispute, or investigation with confidence.

2. Scope

This policy applies to:

• All paid employees and pastoral staff

• Contractors and volunteers in roles with ongoing obligations (e.g. child-facing roles)

• All campuses and ministry arms of Generocity Church, including Generocity Kids and The Horizon Project

It applies to records held in any format — paper, digital, or cloud-based (including Xero, Google Workspace, Basecamp, and any church management systems).

3. Retention Schedule

The table below sets out minimum retention periods for key record categories. Where multiple obligations apply, retain records for the longest applicable period.

4. Responsibilities

CHURCH LEADERSHIP / SENIOR PASTOR

• Approves this policy and any significant changes

• Ensures the organisation has adequate systems to meet these obligations

CHURCH ADMINISTRATOR / OPERATIONS

• Maintains the master record register in GC Admin File > Employee File on drive

• Oversees secure storage and disposal of records

• Coordinates annual review of this policy

CAMPUS PASTORS

• Ensure campus-level records are captured and stored appropriately

• Report to church administration when records are due for review or destruction

ALL STAFF

• Handle records in accordance with this policy

• Do not destroy records without authorisation

• Notify church administration if a dispute arises that may affect records

5. Storage & Security

All employee records must be stored securely and only accessed by authorised personnel. This includes:

• Digital records: password-protected, stored in approved systems (e.g. Google Workspace with appropriate sharing restrictions)

• Physical records: stored in locked cabinets, accessible only by the church administrator and senior leadership

• Cloud-based payroll/accounting (e.g. Xero): ensure accounts remain active and records are exportable before downgrading or cancelling subscriptions

Records must not be stored on personal devices unless secured and backed up to the organisation's systems.

6. Record Destruction

When records have met their minimum retention period and are no longer required, they must be disposed of securely:

• Paper records: shred or use a certified document destruction service

• Digital records: permanently deleted (including from cloud backups where practicable) but listed on the Record Destruction Section of the policy

• USB / physical media: physically destroy or use certified e-waste disposal

Records must NOT be destroyed if:

• A dispute, complaint, or legal claim is pending or reasonably anticipated

• An audit or investigation has been notified

• The record relates to a child safety matter (retain indefinitely)

RECORD OF DESTRUCTION

All record destruction will be kept in a separate register as looks like this for example:

7. Privacy

All records containing personal information must be handled in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs). This includes:

• Collecting only the information necessary for employment and ministry purposes

• Ensuring employees can access records about themselves on request

• Not disclosing personal information to third parties without consent, except where required by law

8. Policy Review

This policy will be reviewed annually, or earlier if there are changes to relevant legislation. The church administrator is responsible for initiating the review.

Authorised by

Name: Ps Tash Eagle 

Role:   HR Executive Pastor 

Date:  25th March 2026