Exactly right. Statutory and regulatory retention periods are the
minimum period for which the records need to be held. If there is an
operational or business need - including the potential historical or
other long term value of the records - which is longer it takes
precedence over the citation. However, it's important to show both so
that the legislative requirement can be audited.
The retention schedules that we use for our clients have separate
columns for each category and a total retention period which is the
longer of the two. A comment column allows a note to explain the
rationale for the decision to extend the retention period.
Peter Emmerson
Director
Emmerson Consulting Limited
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County Durham DL14 0AS
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-----Original Message-----
From: The UK Records Management mailing list
[mailto:[log in to unmask]] On Behalf Of Larry Medina
Sent: 05 November 2004 14:11
To: [log in to unmask]
Subject: Re: Retention periods/citations
> Can anyone clarify best practise to define reason for retention for
> records I would wish to keep longer than the cited
statutory/regulatory
> retention requirement
The common practice is to have a column in th eretention schedule for
"disposition" which cites the authority/legislation that requires the
disposition, then another column for "retention" that states the
required retention period and a final column for "guidance" where you
would put notes related to how the material should be properly disposed
of, if there are additional considerations related to its handling, or
other notes related to the record series.
This is where you would put notations such as: "Prior to destruction,
evaluate for historic value" or "For continuing business need, retain
an additional 2 years beyond required retention"
> i.e. Where a record can be attributed with a specific retention period
> relative to a statutory or regulatory citation but also has an
> intrinsic
> value to be kept longer e.g. Life of Company to support Corporate
> memory,
> how should this best be defined within the records retention schedule
> so
> as not to confuse?
You're correct in that it should NOT be included in thre calculated
retention period stated in your retention column based on the required
disposition, as it would be dificult to audit against AND makes it more
dificult to review and revise your schedule as requirements
periodically change.
> My dilimma is:
> If I quote the citation against a preferred longer retention period,
> then
> I am referring to the citation requirements incorrectly, but if I
quote
> the reason for retention as Corporate Memory against the longest
> timescale, then that would not make it clear that there is also a
> mandatory requirement to retain the document.
One of the things that should ALWAYS be calculated into the retention
of documents and records is their business value, along with their
intrinsic, historic or enduring value to an organization. But you're
right in saying the two (required and desired) shoud not be mixed in
the stated retention period.
> What is best practise in this situation?
That's my story, and I'm sticking with it!
Larry Medina
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