> We all know to keep employee files/data for x years after termination.  
> However, in the case that an org has a retiree program that can span from 
> the age of 55 until death (and by the way the retired employee can begin 
> the program anytime after retirement), this throws a wrinkle into getting 
> rid of the retired employees personal data (i.e., address, salary, DOB, 
> etc.).  In this case, it appears that the only thing to do is maintain data for 
> that subset of the employee population that retires after age 55 and is 
> eligible to take advantage of the program anytime thereafter.  I can't purge 
> all former employee data x years after term.  

Another classic "it depends" situation.

In part, it depends on what drives the retention WHICH records must be retained for the required period.

If there is a statute or regulation (State or Federal) regarding retention in the event of potential exposure to hazardous materials at any time while employed, THEN anything in the OPF that may indicate WHEN or WHERE an employee was working, must be retained.  If not to prove where/when they may have been exposed, it prove that they were NOT exposed.

An example was the DOE EEOICPA program, where the inability of contractors to disprove exposure resulted in millions of $ in payouts to deceased employees families as much as 50 years after their separation and/or death.

The retention on these is 75 years after separation, which is designed to ensure the records remain available for two successive generations of surviving family members, reaching majority age. 

Larry
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