Records Retention and Disposition Toolkit

Retention Scheduling

Retention scheduling is the process of determining the life of a record in each stage of the information life cycle (from creation through disposition). Scheduling takes into consideration not only the practical business life of records (satisfying administrative, fiscal, and research needs) but also federal, state and local regulatory requirements.

The length of time a record must be kept to meet these requirements is referred to as its retention period. Records retention schedules are a critical component of a records and information management program. In its most basic form, a records retention schedule identifies the records to be managed and communicates how long the records are to be retained. A records retention schedule provides direction and guidance on recordkeeping requirements and conditions.

The records retention schedule is typically compiled and maintained by a records and information management (RIM) professional (sometimes called a Records Manager) - using best practices, industry standards and methodologies.

The process of creating a retention schedule begins with gathering information by conducting a records inventory to determine among other things: what records exist, their formats, their origin, and who accesses them. In the end, the retention schedule is usually reviewed and approved by appropriate departments and signed off by the leadership of the organization. If the organization is a state-funding entity, it is possible that state law will require the retention schedule to be approved by another state agency – an agency that has legal authority over records and information management issues state-wide.

The following sections are included on this page. If you would like to submit additional resources, please contact the Higher Education Information Security Council.

Disposition of Records

Records disposition is a critical element of records management and is the final operational action taken in the records lifecycle. Disposition may include the destruction of records or the transfer of records to another entity (most commonly an Archives) for permanent preservation. An organization's records disposition program provides approved routine procedures to dispose or transfer records that are no longer needed in the office for current agency business.

During the disposition process, records are approved for destruction or transfer according to the policies and procedures of the organization. One goal of this process is to consistently and properly disposition records during the normal course of business. Records that contain information that is sensitive (e.g. FERPA or HIPAA protected information) should be destroyed in a secure manner that protects privacy, such as shredding, incineration, or secure digital destruction. Records containing non-sensitive information may be disposed of in the trash, recycling, or less secure digital destruction. Another goal of the disposition process is to provide proof that records have been consistently and properly dispositional. This point is extremely important in light of the most recent revisions to the Federal Rules of Civil Procedures which deal with the process of discovery and production of evidence in response to potential litigation. This process is most commonly called "E-Discovery Toolkit." In regards to disposition, it is very important that the destruction of records be documented and approved by the proper authorities. These documents should then be retained as part of the documentation of the records management program.

A comprehensive records disposition program should include procedures that address what to do when a litigation or legal hold is put into place. Generally, a record is frozen from ordinary disposition procedures when any litigation, claim, negotiation, audit, public information request, administrative review, or other action involving the record is initiated. At this point, disposition should be postponed until the completion of the action and the resolution of all issues that arise from it. See below for additional resources on the appropriate disposal of information.

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Developing a Records Management Program

Some considerations for developing a Records Management Program:

  1. Establish a strategic planning group which includes top managers/executives to support the program.
  2. Write and communicate a directive on the objectives of the program which should link to organizational goals.
  3. Identifying a "Records Manager" to oversee all aspects of the program including on-going management, use of internal personnel or outside consultants.
  4. Write a policy statement identifying purpose, responsibility, objectives, etc.
  5. Determine staffing and organizational structure for overseeing the program's day-to-day operations.
  6. Conduct a preliminary file purge of non-records from filing systems.
  7. Complete a records inventory.
  8. Develop and implement a retention schedule.
  9. Protect the vital records of the organization.
  10. Develop a records management manual with policies, procedures, etc.
  11. Implement filing standards throughout.
  12. Identify process for managing inactive records in low cost space.
  13. Implement forms management and reports management programs.
  14. Automate records management where it makes sense.
  15. Make records management a high priority.

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More about the Records Lifecycle and Stages

Effective records management consists of controlling these records from their creation or receipt through to their final disposition. This movement from creation to final disposition is known as the records lifecycle and it consists of three stages: active, semi-active, and inactive. Each lifecycle stage has associated activities.

Active records are maintained for as long as they support the organization's current functions, projects, initiatives, etc. The active stage of the records lifecycle includes activities such as creation, distribution, and use. Generally, active records are those that are referred to often during the regular course of business. Active paper records are typically located in nearby filing cabinets or in desks. Active electronic records are typically saved on local drives or on shared network space.

Once records are no longer needed to carry out current activities, they become semi-active. However, these records must still be kept, or "retained," as long as required to meet the organization's administrative, fiscal, legal, or historical requirements. Typically, managing semi-active records is a question of space, value and use. Semi-active records are records that are not frequently retrieved or accessed.

With paper records, management of these records may become an issue when there is no longer space to properly store them. At this stage, organizations may want to consider whether to maintain these records in on-site storage or off-site storage. Scanning source documents into electronic or imaging records onto microfilm may provide cost-effective options.

With electronic records, managing semi-active records may become an issue when storage options (networks and local drives) become overloaded with rarely accessed files. As the volume of files on networks and local drives increases, performance suffers, and accurate, timely retrieval becomes increasingly difficult and time-consuming. Routine disposition of electronic files is a cost-effective solution to file bloat.

Generally, inactive records are records that are no longer required to carry out the administrative or operational functions for which they were created and which are no longer retrieved or accessed.

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Retention Scheduling Considerations and Decisions

  1. Is the organization starting from scratch, or refreshing existing retention schedules?
  2. What is the scope of the retention schedules?
  3. Will the organization develop functional retention schedules or departmental retention schedules?
  4. What method will be used to gather information to develop the retention schedules?
  5. Who will perform research into regulatory recordkeeping requirements?
  6. What tools will support the development and ongoing maintenance of the retention schedules?

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Benefits of a Records Retention Schedule

Establishing and implementing a records retention schedule:

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Developing a Retention Schedule Step-by-Step

Developing a retention schedule requires a plan of action. Here are the basic steps to develop a records schedule:

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Records Inventory

A records inventory is a detailed listing of the volume, scope, and complexity of an organization's records, usually compiled for the purpose of creating a records schedule. The results of the inventory can be used to analyze the records for various purposes including retention and protection.

The steps in the records inventory process are:

  1. Define the inventory's goals. While the main goal is gathering information for scheduling purposes, other goals may include preparing for conversion to other media, or identifying particular records management problems.
  2. Define the scope of the inventory; it should include all records and other materials.
  3. Obtain top management's support, preferably in the form of a directive, and keep management and staff informed at every stage of the inventory.
  4. Decide on the information to be collected (the elements of the inventory). Materials should be located, described, and evaluated in terms of use.
  5. Prepare an inventory form, or use an existing one (e.g., <ac:link-body>Records Retention Inventory Worksheet</ac:link-body>).
  6. Decide who will conduct the inventory, and train them properly.
  7. Learn where the agency's files are located, both physically and organizationally.
  8. Conduct the inventory, being considerate of other's time/schedules.
  9. Verify and analyze the results.

An inventory should include certain elements of information for each series. Here are some suggestions:

What additional information should be included in an inventory specifically for electronic records?

Besides the inventory information listed above, include the following in an inventory of electronic records and electronic records systems:

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Retention Periods

The assignment of retention periods must be carefully considered and crafted in a meaningful way to support the organization, its functions, and its information management responsibilities. Retention periods are determined by appraising the associated records' usefulness or value in the following four areas:

This chart provides a glance at the typical break down of records by retention period.

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When Should I Update the Records Schedule?

Records schedules remain in effect as long as they are valid, i.e., as long as the nature, content, and functional importance of the records remain the same. AN organization should review their schedules at least annually and update them whenever necessary. Updates may be needed under the following circumstances:

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Resources for the Appropriate Disposal of Information

Once the decision has been made to dispose of information rather than to preserve or archive it, the custodian must choose the means of disposition. The choice should be based on the sensitivity of the information and the cost of disposition relative to the risk of disclosure.

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