Unfortunately, this is one of the limitations of certain types of med


Unfortunately, this is one of the limitations of certain types of media when imaging / filming projects are initiated without regard to retention periods. Nevertheless, you now have to address the issue. In years past, the solution to expungement of microfilmed records was a well-aimed hole punch. That works fine for the one-off case report, but not so much for hundreds of pages of documents that need to be purged.


Since the film will be digitized, it would be possible to set retention periods for each image, but that will likely defeat the savings (if any) gained by digitizing the film. In theory, you could index every image and then have the system purge the images that are past retention. But that could mean hundreds of hours of labor.

It is certainly not unusual for a box of records to contain records with varying retention periods. It would be normal practice to hold the entire box for the longest retention period, although generally my approach has been to do that when the retention periods are within three to five years of each other. In other words, if the shortest retention period is until 2010, the longest retention period can only be until 2013 to 2015. If the longest retention period is longer, then the box should be pulled and the contents reboxed by retention period.

The challenge here is that you have temporary and permanent records mixed together (that sounds like education records). The first thing that I would consider is what the law or regulations have to say about the temporary records. If there is an absolute mandate to destroy the temporary records at a certain point, then you have no choice. If the law is silent on mandate to destroy and only set a minimum retention period, then it would not be hugely problematic to retain the temporary records. You would then simply want to note in the description of the permanent records that the files also contain related temporary records. If you have similar records that are better segregated, then you may need a special record series for the mixed items.

I would never certify destruction of records that still exist, particularly when you know they exist.

I have seen some organizations which would refuse to retrieve certain records because they were past the retention period, but that isn't a good practice.

 
Patrick Cunningham, CRM, FAI
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