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>> I have never used a minimum or maximum concept for the final retention policy. <<
I have never used Minimum as part of a retention timeframe. I have used Maximum on rare occasions, particularly where there is no legal retention timeframe and the usefulness of the information being created can vary considerably. One example is Ad Hoc Management Reports. It is an exercise in futility to try to manage all of the possible reports that may be required as separate record series. It is also silly to maintain all of the reports for a fixed period of time. A Max 3 works just fine.
One additional note, with very few exceptions, EU requirements for records retention are requirements, not minimums. As noted by various data protection authorities, a retention requirements serves two purposes:
1. Identifying the timeframe an organization is required to maintain the record, and,
2. Telling the consumer when records containing PII will be destroyed.
Maintenance for a period in excess of the legal requirement can lead to privacy complaints and claims and subsequent regulatory enforcement or legal actions.
Bill Roach, CRM
Opinions expressed are my own and do not reflect the position of my employer or any other entity.
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