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From:
"Manago, William" <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Wed, 18 Jul 2012 13:47:11 +0000
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I prefer the term(s) 'disposition instruction' which are actions to be performed both during and at the end of a record's life cycle.  An example would be - cutoff at the end of the calendar year, keep in local office for 2 years, transfer to offsite storage after 5 years, destroy 20 years after transfer to offsite storage.

From the example given, note that there are disposition actions, which may include cutoff, transfer, archive, permanent storage, and destroy.

Some helpful definitions from the DoD 5015.02 Standard:

DL1.41.  Disposition.  Those actions taken regarding Federal records after they are no longer required to conduct current Agency business (Reference (f)).  	These actions include:

	DL1.41.1.  The transfer of records to Agency storage facilities or Federal Record Centers (FRCs).

	DL1.41.2.  The transfer of records from one Federal Agency to another.

	DL1.41.3.  The transfer of permanent records to NARA.

DL1.41.4.  The disposal of temporary records no longer needed to conduct agency business, usually by destruction or, occasionally, by donation of temporary records to an eligible person or organization after the authorized retention period has expired and after NARA has approved the donation (part 1228.60 of Reference (g)).

DL1.42.  Disposition Action.   The action to be taken when a disposition date occurs (e.g., interim transfer, accession, or destroy).

DL1.43.  Disposition Action Date.  The fixed date on which the records in a file become due for final disposition.

DL1.44.  Disposition Authority.  The legal authority that empowers an Agency to transfer permanent records to NARA or to carry out the disposal of temporary records.  Must be obtained from NARA and also, for certain records proposed as temporary, from the GAO (Reference (f)).

DL1.45.  Disposition Instruction.  The directions for cutting off records and carrying out their disposition (transfer, retirement, or destruction) in compliance with NARA's regulations and the General Records Schedule.  Disposition instructions in an RMA include retention-related fields such as authority, transfer location, active or dormant chronological retention periods, and conditional retention periods (Reference (f)).

DL1.46.  Disposition Instruction Type.  One of three ways of scheduling a disposition instruction: time, event, or a combination of both time and event.  (DL1.57, DL1.129, DL1.130, and Reference (f)).

DL1.28.  Cutoff.  To cut off records in a file means to break, or end, the record at regular intervals to permit disposal or transfer in complete blocks and, for correspondence files, to permit the establishment of new files.  Cutoffs are needed before disposition instructions can be applied because retention periods usually begin with the cutoff, not with the creation or receipt, of the records.  In other words, the retention period normally does not start until the records have been cut off.  Cutoffs involve ending input to old files and starting input to new ones at regular intervals (Reference (f)).  Cutoff is sometimes abbreviated as COFF and is also called file cutoff or file break.

	DL1.28.1.  For records with retention periods of less than 1 year, the cutoff is at an interval equal to the retention period.  For example, if a record series has a 1-month retention period, cut the file off at the end of each month and then apply the retention period (that is, hold the file 1 more month before destroying it).

	DL1.28.2.  For records with retention periods of 1 year or more, the cutoff is at the end of each fiscal (or calendar) year.  For example, if the disposition instruction for a correspondence file is "Destroy after 3 years," then destroy it 3 years after the annual cutoff date has been reached.

	DL1.28.3.  For records with retention periods based on an event or action, cutoff on the date the event occurs or when the action is completed, and then apply the retention period.  For example, if the disposition for case working papers is "Destroy when related case file is closed," then cut off and destroy the working papers when closing the related file.

	DL1.28.4.  For records with retention periods based on a specified time period after an event or action occurs, apply the retention period after the placement in an inactive file on the date the event occurs or when the action is completed and the inactive file is cutoff at the end of each fiscal (or calendar) year.  For example, if the disposition for a case file is "Destroy 6 years after case is closed," then destroy 6 years after the annual cutoff along with all other case files closed during that year.

Bill Manago, CRM
VP, Information Governance Solutions
Coconut Creek, FL  33073
Office: 954-876-9057
Mobile: 954-482-2977
[log in to unmask]   Note new email address
www.autonomy.com

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