SOX Record Retention and Management Checklist

A comprehensive checklist for financial services companies to establish, implement, and maintain SOX-compliant record retention and management practices, focusing on preserving financial and audit-related documents.

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About This Checklist

The SOX Record Retention and Management Checklist is a vital tool for financial services organizations to ensure compliance with Section 802 of the Sarbanes-Oxley Act. This comprehensive checklist guides companies through the process of establishing, implementing, and maintaining proper record retention policies and procedures. By adhering to this checklist, organizations can safeguard critical financial and audit-related documents, prevent document alteration or destruction, and maintain a clear audit trail. Regular use of this SOX record management checklist enables businesses to demonstrate due diligence in preserving financial records, enhance transparency, and mitigate risks associated with non-compliance.

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Industry

Financial Services

Standard

SOX Section 802 - Record Retention

Workspaces

Data Centers
Corporate offices
Archives

Occupations

Records Manager
Compliance Officer
IT Manager
Legal Counsel
Chief Information Officer
1
Is the document retention policy compliant with SOX Section 802?
2
Is there a scheduled review for document retention policies?
3
What is the maximum retention period for financial records (in years)?
Min1
Target7
Max20
4
Describe how legal holds are implemented for documents.
5
Is there an audit trail that tracks document access and modifications?
6
Are adequate data preservation measures in place for electronic documents?
7
Is encryption utilized for sensitive electronic documents?
8
Describe the procedures for the disposal of electronic documents.
9
How frequently are backups of electronic documents performed (in hours)?
Min1
Target24
Max72
10
Are proper access control measures implemented for electronic documents?
11
Are all employees trained on record retention policies and compliance?
12
Is there a mechanism for reporting incidents related to document management?
13
How often are audits conducted on record retention practices (in months)?
Min1
Target6
Max12
14
What are the defined roles and responsibilities related to document management?
15
Is the organization in compliance with all relevant regulations regarding document management?
16
How often are information governance policies reviewed?
17
Is there a data classification system in place for documents?
18
What percentage of documents comply with the established retention schedule?
Min0
Target95
Max100
19
Describe the disaster recovery plan for document management.
20
Are third-party vendors compliant with your document management policies?

FAQs

SOX Section 802 covers a wide range of records including audit workpapers, correspondence, memoranda, electronic records, and other documents related to audits and reviews of financial statements.

SOX requires that audit and review workpapers be retained for at least seven years after the conclusion of the audit or review. Other relevant documents may have different retention periods based on their nature and relevance.

While the overall responsibility often lies with the compliance officer or legal department, implementation typically involves collaboration between IT, records management, finance, and other relevant departments.

SOX imposes severe penalties for knowingly altering, destroying, concealing, or falsifying records with the intent to impede, obstruct, or influence a federal investigation or bankruptcy proceeding.

Technology plays a crucial role in implementing SOX-compliant record retention practices, including the use of electronic document management systems, data backup solutions, and access control mechanisms to ensure the integrity and security of retained records.

Benefits of SOX Record Retention and Management Checklist

Ensures compliance with SOX Section 802 record retention requirements

Reduces risk of penalties associated with improper document destruction

Enhances audit readiness and facilitates smoother regulatory examinations

Improves overall information governance and data management practices

Strengthens legal defensibility in case of litigation or investigations