How Long is Long Enough: Records Retention and Your Agency
November 3, 2011
Managing and maintaining a steady flow of data are two major components of the records management equation. Then there’s retention. Where records go—and how long they stay there depends on the agency, the nature of the information and the data source itself.
All records are not created equal. So how do you determine how, how long and where to keep them? The answer to that potentially boggling question starts with a few basic considerations. Consult this checklist before embarking on your own records retention plan:
Consider the Source
Not all data is created equal. Traditional paper, audio and video data sources—and now email—have longer shelf lives than tweets, Facebook posts and blog posts. This distinction notwithstanding, the National Archives and Records Administration (NARA) Guidance on Managing Web Records suggests that those in charge of records retention should treat web content as if it might be included in federal records—even though, by some estimates, well under five percent of such web-generated information finds its way there.
Consider the Record Type
The nature of the information on record also plays a large role in determining its ultimate lifespan. For starters, tax, military and benefits records are endowed with greater longevity than certain employment information, and there are even variations within each of those categories: In some cases, government agencies must retain pension and welfare information for six years, while they can destroy employment verification forms and some payroll records after three years. Over time, the government has tweaked and tuned retention requirements for evidentiary records maintained by agencies such as the Justice Department and the Securities and Exchange Commission (SEC).
Consider the Agency
Whether tracking criminals, plotting military maneuvers or distributing benefits, every agency has its own records retention schedule. The Department of Labor must keep Adjudicatory Boards' Monthly Reports for three years, while Social Security benefits records extend well past the life of the taxpayer—and through the lives of his or her beneficiaries.
The Army has noted that some records “protect the rights and interests of the Army and its current and former members, and those records are of permanent value.” In contrast, the Army stipulates that records “related to matters involved in administrative or legal proceedings” should be kept only until “the staff judge advocate or legal advisor authorizes resumption of normal disposition.”
Consider The FOIA
The stringent requirements of the Freedom of Information Act (FOIA) also impact record retention parameters. Following it to the letter greatly diminishes your exposure to risk, liability and the possibility of lawsuits.
If you’re grappling with record retention issues, these steps are essential for success:
- Identify the data source.
- Determine the record type and classification.
- Assign records a home based on use. Some must be more easily accessed than others.
- Know long term what to send to the archives at NARA. Agencies can port permanent records to NARA where they are archived.
- Develop a records management policy specifying retention requirements.
- Train and educate employees on policies and requirements.
- Learn your agency's official disposition schedule.
- Update and enforce your agency's records retention policy.
- Familiarize agency workers with the Freedom of Information Act and its special record retention requirements.
These four sets of considerations are a great start to building a long-term retention program—one that your agency can deploy over time to meet the challenge of Tweets, Facebook and bog posts, and whatever incarnation of data comes your way.
More questions about Records Storage Services for the Federal Government? Read additional Knowledge Center stories on these subjects, or contact Iron Mountain’s consulting services team. You’ll be connected with a knowledgeable product and services specialist who can address your information management challenges.
Managing Records the FOIA Way
Your Agency and the Open Government Directive
A Safer Space: Assessing Your NARA Compliance Status