Records Retention Explained
Retention is not the wizardry that everyone thinks that it is. It’s to help you demonstrate that you shall retain information only for the specified retention periods set out in a policy and shall then arrange for the prompt and secure disposal of that information if the review means you aren’t keeping it longer.
- Retention periods are set out in a retention schedule
- Retentions are minimum periods unless otherwise stated.
- A Retention Schedule is a policy document that is signed off by Senior Management
- Do not destroy anything before it has been signed off.
- Retention of record series must be created in a Functional, Activity and Transaction (FAT) format. Where you have an item that is not specifically listed, this is because it will fall into a topic. Find the topic related to your item and follow the related retention.
- Unless otherwise stated the year of retention runs calendar January-December, where it says:
- Financial year this means April to March
- Academic Year is September to August.
- Company Year is the month from which company accounts start and end
- Retention is created on-topic or what the record is actually about not format. E.g. Email is not a topic. It’s the topic of the email. Therefore, Email has many different retentions depending on what topic it covers.
- The same retention applies to all formats of the same topic.
- If you are going to publish your records retention schedule please put a disclaimer on it that if you copy any retention periods, they are specific to your organisation’s risk appetite. A lot of people look for retention schedules based on a simple google search. You are being accountable to others to show the reason behind your retention.
- Do not list any records on your retention schedule that you do not have. e.g. If you are a mental health trust, do not list A&E records.
- PDF your retention schedule to ensure it isn’t tampered with easily.
- Keep all major versions of your retention schedule so that you can prove changes that have been made over time.
- If you review your retention schedule and make any changes – detail those changes on the front of the policy so that users know what has changed with ease.
- A trigger is a point at which the period of years starts to apply. E.g. Last action entry is the trigger. You can have many types of triggers but make sure they can be realistically implemented.
- Remember that if you use the trigger “Date of Death” but you don’t actively seek out the persons date of death, then it is not realistic and could not be implemented.
- Notes field will give you any extra information you might need to know before disposition.
- Records may be weeded to reduce down file size where there is Redundant, Obsolete or Trivial (ROT) information that is not needed. ROT falls outside any retention period. Do not weed it out if it isn’t ROT. Deletion/Destruction is a phrase only to be used with records that are not ROT and need to be kept for the retention.
- Retention only applies to anything that is created by your organisation or in something that your organisation has the only copy of. As soon as you change the original document received by adding a date stamp, it belongs to your organisation.
- Make sure you have a source of where your retention has come from. Do not write a source that does not apply to your business. An example being the Companies Act if you are a civil service body. (I’m looking at you ICO.)
Retention Exceptions & Reviews
- Exceptions to this Policy must be approved by <SOMEONE WHO KNOWS WHAT THEY ARE DOING>
- Retention periods are minimum requirements and set out an expectation that your organisation will not remove any records before the time stated.
- The periods of time can be extended upon review if there is a business need to keep it longer or it is something that can be reused.
- Reviews need to be taken out on all records before disposal unless otherwise authorised.
- Never factor in automatic destruction unless the risks have been assessed and tolerated.
- Please check with a qualified archivist on whether there are any records within your schedule that they would be interested in transferring to a local place of deposit/county archives.
- Review extensions are not acceptable if they are “I don’t have time to review them”, “I don’t know” or “Let us keep it just in case” – you need a suitable business need to retain it.
Destruction or Disposition
- Destruction/Deleting of documents must happen at a minimum of once a year, recommended in January of the year.
- Where documents and records destruction day falls outside the year of destruction, you may let it fall into the next time. E.g. Destruction taking place on 31st January 2020 and deletion date is 1st February 2020, the 1st of February documents will be destroyed in January 2021.*
- Never destroy records before their destruction date even if it’s days.
- All information must be disposed of in accordance with IT security standards policies on document and data
- Disposals must be logged on a Disposal Register (yes that includes a list of electronic deletions too)
- Disposal does not just mean destruction. It is the release of it from your care. An example of disposal is giving the records to Archives.
- If you are unsure of anything please contact a suitably experienced Records Management person before getting rid. RMGirl can help you here.
Here end my guidance on what retention means to an organisation. This is not an exhaustive list but it is a list of items that you can consider.
RMGirl will help you build your retention schedule or write a suitable policy that can assist your organisation to become compliant and ensure your company protects itself with appropriate records management.
Please read my Legal Disclaimer before actioning on anything you’ve read in the blog post.
COMING SOON I am launching some new items that can be bought in the RMGirl Shop on this website. STAY TUNED for the 1st September 2020.
Expect items such as:
- Retention Schedule
- Disposal Register
- Privacy Notice
- Cookie Notice
- Guides (Both long and short)
- Email Management
- Drive Management
- White Mail Guide
- EDRMS considerations
- Legal admissibility
- Data Protection for Freelancers Guide
- Offsite Storage Tender Wording
- Records Management Girl Hotline Subscription
- All information governance covered, not just Records Management.
- Hourly rate
- 6 months fixed
- Annual fee based on sector
- 5-year contract discount.
- Free templates and guides when signing up to certain packages.
*post edited the next day after publishing due to a type. Text from 2022 to 2021