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Subject:
Re: NERC/ FERC Retention Question - requirements vs audit needs
From:
Gary Link <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Tue, 18 Nov 2014 16:50:24 -0500
Content-Type:
text/plain
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text/plain (36 lines) 
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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