Amy & Steph,
You are both correct to be concerned about over-retaining records in your
specific scenarios and in general. However I just want to point out that
it is typical, not atypical, for an organization's operational, fiscal,
legal (other), and historical needs for a record series to exceed the
regulatory requirements attached to those records. The regs may say, for
example, 3 years, but operational needs including active use & inactive
reference for the record's original purpose, tax, audit, contractual,
statute of limitations, and historical needs very often require your
retention to be longer than that 3 years.
I do not in any way intend to dissuade you from your work in better
understanding your respective audit requirements and scheduling your
records appropriately. It is important work and must be completed. But
remember that typically regulatory requirements are for a minimum, not a
maximum retention, (exceptions include privacy regs) and setting a
retention that meets all of your operational needs is necessary and will
seldom if ever get you in trouble with your regulators.
Gary Link
Pittsbugh, PA
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