Code Corner:
Follow These Rules Regarding Company Records
ITT's business records are important company assets. Just as you are careful to document and maintain your personal records, including for example, your birth certificate, Social Security card, checkbook, and passport, our company’s business records also must be properly created and maintained.
Auditing and legal requirements place responsibility on the company and its employees to generate and handle business records accurately, and to retain them for prescribed time periods, depending on the nature and purpose of the record. It is a crime to intentionally create a company record that is inaccurate, false or misleading, including invoices, contracts, statements of work, expense reports, shipping documents and any other paper or electronic record.
In an emergency or if we reasonably anticipate or are involved in litigation, governmental inquiry or a similar proceeding, we must be able to quickly locate and retrieve our records.
Our policies for managing records vary according to the content and type of record. Not all documents, messages or other media are necessarily records. If you are not certain about how to create, handle, preserve or destroy any company record, ask your supervisor or Legal Department.
Company records come in many forms: a paper document, a database, an e-mail or instant message, a voice message, a diagram or photograph. Information may reside in any media, including a hard drive, DVD, CD, floppy disk, PDA, cell phone or voice mail system, server, audio or videotape, or camera. All company records are subject to audit and inspection at any time.
Employees play an essential role in creating, handling, storing, and destroying records throughout their lifecycle. You must understand the requirements which apply to the records with which you work. Failing to comply with policies and regulations or improperly destroying or altering a record can subject you and ITT to penalties and fines.
In particular, you must preserve any record that is or may be relevant to an existing or potential legal proceeding or government investigation even if ITT's standard document retention policy calls for the destruction of that record. If you are not certain about the preservation or destruction of any ITT document or record, consult with ITT counsel.
You must:
- Organize your records. Label, document, and maintain them for easy access.
- Regularly dispose of confidential or proprietary records by shredding or other permanent methods.
- Send properly indexed and labeled records to designated archive storage areas.
- Review and test your retrieval procedures periodically to be sure your archived files are accessible.
- Be aware of destruction dates for records in your possession, and destroy them at the appropriate time.
- When you receive notice that regular company document destruction procedures are to be suspended, promptly stop any automatic or regularly scheduled record destruction and do not move, alter or destroy any records placed on legal hold.
Can I Take Copies Home?
I have personal copies of some work that I did on a company project completed last year. I would like to take these copies home. May I do so?
A. No. The records and all copies belong to ITT, not to you; therefore you may not remove them or use them for any purpose without the company's express permission. They may be stored on-site until they are no longer needed, then they should be destroyed. You should also be aware that in the event of an investigation or legal proceeding, any company records stored in your home are subject to production at the request of authorities or other parties and may be used as evidence in a subsequent proceeding or inquiry!