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Anatomy of a Retention Policy
Whether you follow a retention schedule or develop policies ad-hoc when storage space reaches capacity, well-documented retention decisions demonstrate your organization’s commitment to good information governance. The “Five Ws (and one H)” research and reporting style serves as an effective tool to review your retention policies.
The following example series is taken from the Louisville Metro Government Records Retention Schedule.
Text from the schedule appears in italics:
Louisville / Jefferson County Metro Government
The Checklist addresses records that are common among departments and agencies in the organization. Often these shared series are called “common records”.
Records Title: Budget Work Papers
A unique number is assigned to records grouped together in a series. When working in a database, this may be the unique identifier for the group of records.
Contents: May include agency priorities, suggested agency reductions, records of agency receipts, requests for budget enhancements, mission and vision statements, etc.
The “big bucket” approach argues that more expansive policies are needed for contemporary retention schedules. In this case, the specific contents and records titles might be generalized to encompass additional financial records with the same retention and recordkeeping requirements.
Function and Use: Records are agency working papers used to develop each fiscal year’s budget. Records are preliminary documents prepared by each agency or department and formulated into a budget request. This request is submitted to the Budget Office for further review and discussion
The policy should indicate where in the organization the records are generated and managed. This example of Function and use also addresses chain-of-custody.
Authority: Preliminary material – KRS 61.878(1)(h)(i)
In addition to legal authority, program records should document complete description and analysis of the records. Documentation should indicate all factors that were considered in the retention decision, including administrative, accounting, legal, other business and preservation needs.
(V) = Vital Records
Records that are essential to the continued functioning of the local government during and after an emergency, as well as those records that are essential to the protection of the rights and interests of that local government and of the individuals for whose rights and interests it has a responsibility. Local Government should have a plan in place to identify those records and provide for their protection in case of a disaster (fire, flood, earthquake, etc.).
(C) = Confidential Records
Records deemed unavailable for review by the public after applying the state’s Open Records Law (KRS 61.878) and other state and federal statutes and regulations with specific restrictions.
Disposition may also include transfer and preservation of inactive records.
Retention: 3 years
Your policies might include the timeline for transfer to offsite storage or related imaging projects.
In summary, retention decisions are as idiosyncratic as records themselves and require in-house discussion and decision-making. It can be tricky to document the many rules, laws, regulations and overlapping business needs. However, careful consideration of retention value is a critical part of effective recordkeeping, and related documentation supports defensible disposition.
Written by: AGriffin