I agree with Ginny. I'm not sure the word retroactive applies to the
formation of an inaugural retention schedule. Any considerations for the
records would be part of the formation of the schedule and once set and
approved it would be applied per the guidelines/policy of the records
program. The first application of it likely would net a far larger
destruction than say the next quarter's destruction, but it sounds like it's
simply the formation of a schedule and first application of it. In addition
to the schedule of course research would need to be done on what
investigations, litigation or audits might require defined holds from the
retention schedule, but otherwise, if the schedule has been created through
a process which involved the stakeholders, there shouldn't be an element of
it being retroactive. A record held 20 years when no schedule was present,
would now, let's say with a seven-year retention, become eligible for
destruction for the first time. It had never been eligible before assuming
there had never been a retention schedule. If habits or other slightly
formal means had been applied in the past, but maybe inconsistently, then I
still think that defines an environment without a retention schedule which
may not have been a healthy thing for the company, but in creating a
schedule through a good process and applying it the first time, I don't
think it would be considered retroactive.
Good luck!
-----Original Message-----
From: Records Management Program [mailto:[log in to unmask]] On Behalf
Of Greene, Ben
Sent: Monday, November 29, 2010 8:55 PM
To: [log in to unmask]
Subject: Implementing Retention Periods Retroactively
I believe this subject has come up before on the list, but I am not
locating anything specific. Are there any formal "guidelines" regarding
implementing retention periods to records that did not have any periods
set previously? Meaning, when a company implements its inaugural
retention schedule, how are the periods enforced from the onset? From
my experience, it was usually just a business decision to either go back
and implement retention or to put a stake in the ground as say "this is
our policy going forward". I was hoping to find something in ISO or
Sedona regarding retroactive retention enforcement, but have found
nothing.
Thanks.
Ben Greene, CRM
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