The first question I'd ask is if you have an RRS already, and if you do,
aren't you simply verifying/validating the existing retention periods?

Unless there have been major changes to the business model resulting in new
series of records being generated or received, there should be no reason to
perform an inventory or make major adjustments.

If the existing RRS includes (and it should) citations to the sources for
the requirements that were initially set, it should be a simple process of
checking each of these citations and ensuring they haven't changed since the
last revision to, or creation of, the RRS.

I think if I were in this situation I'd ask my management:

"Is the firm you contract this responsibility to going to accept liability
for their research?  If it turns out they provide incorrect information and
we apply an improper retention period, will they be fined, or will it still
be us?"

It's important to keep in mind whatever citation/s you find, these
requirements only establish a MINIMUM required retention- your organization
still needs to determine if there are competing business needs that require
a longer retention, or if you are risk tolerant enough to consider a shorter
retention. And naturally, if any of this information may have an enduring or
historic value to the organization warranting permanent preservation.

Larry
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