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Subject:
From:
David Gaynon <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Wed, 1 Dec 2010 09:40:01 -0800
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As someone who has worked in both private and public sector records management I would say that there is considerable difference between the entire retention scheduling process between the two types or organizations.

It is my view that a private sector organization may safely establish any reasonable retention policy consistent with legal requirements.  This may mean that records created before a certain date are under one policy while records created after that date are under another policy. If the legal retention requirements are lengthened you will need to implement those requirements against all records.  If they are shortened you may choose to implement the shorter requirements against all of your records but you do not necessarily need to do that.

The key issues are reasonableness, adequate documentation for both policy and process, and the ability to recreate the "policy envelope" that existed at a particular time in which you are likely to have a legal issue or claim.

David B. Gaynon
[log in to unmask]
Huntington Beach CA, USA



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