A common approach I am seeing is that the time you talk about is defined as a "review" activity rather than a "destroy" activity. Thus, it is absolutely acceptable to have a destruction time that is undetermined at the point the records are archived BUT there should be a clear "review" period. For most records, they will be destroyed at that review time (and this can be built into retention schedule wording and retention policy wording) but for some records (like Drug Safety records or records linked to the marketed life of a drug) their retention will continue. In Pharma, I often see a review period of 10 years or 15 years for records that have an indeterminate retention time.
Kind regards,
Eldin Rammell,
Director, Rammell Consulting Ltd.
http://rammell-consulting.co.uk
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