Information Governance

Writing a Retention Schedule Departments Will Actually Follow

Writing a Retention Schedule Departments Will Actually Follow

Most retention schedules don't fail with a bang. Nobody stands up in a department meeting and refuses to follow one. They fail quietly: the schedule is adopted, posted on the intranet, mentioned once at orientation, and the departments go on doing what they did before. Some keep everything forever because deleting feels risky. Others throw things out when the shelves fill up or the shared drive hits its quota. Either way the schedule exists only on paper, and in an audit or a lawsuit that can be worse than having none, because now there is a written policy you demonstrably don't follow.

I've written a lot of these for towns, counties and mid-size companies, and the ones that get used share three things. People can find their own records in the schedule in under a minute. The trigger that starts each retention clock is an event someone in the department actually knows about. And destruction happens on a date on the calendar, not in a panic when the storage room overflows. Everything below serves those three things.

Start with the schedule you already have

If you work in local government, you probably don't have to start from a blank page. In most states the state archives, or a state records board or commission, issues general retention schedules for common local government records: minutes, payroll, permits, licenses, election records and so on. Some are mandatory, some advisory. Some let you destroy eligible records on your own authority; others require you to file a notice or get approval first. Read yours closely before you write a word, because it sets the floor and often the format.

A custom schedule comes into play in three situations. Your agency creates records the general schedule doesn't cover (a municipal airport, a water utility, a cemetery commission). The general schedule's language is too generic for staff to recognize their own files in it. Or you're a private company, in which case there is no state general schedule for you, and you build retention periods from the statutes and regulations that apply to your business (tax, employment, industry rules) together with counsel.

In practice, most of my local government projects end up as a hybrid: adopt the general schedule as the legal authority, then publish a department-level version that translates its item numbers into the department's own vocabulary. The general schedule says "Personnel Records – Employee Files." The HR coordinator says "the green folders." Your job is to connect the two.

Records series: the unit everything hangs on

A retention schedule doesn't list documents. It lists records series: groups of records created or filed together because they document the same function or activity, and that can be kept for the same period. "Building permit files" is a series. "Everything in Pat's cabinet" is not, and neither is "all records about 14 Elm Street," which cuts across permits, tax files, code enforcement and maybe a lawsuit.

Two mistakes come up constantly. The first is scheduling by format: a line for "email," a line for "scanned documents," a line for "the shared drive." Retention follows content and function, not the container. A council member's email about a zoning variance and a newsletter sign-up confirmation are both email; they have nothing else in common. The second is forgetting which office holds the record copy. The clerk's office keeps the official minutes for the full retention period; the six other departments holding copies of the same minutes can discard theirs once they no longer need them. If the schedule doesn't say which office is responsible, every office will assume another one is, or they'll all keep everything.

ISO 15489 gives the formal grounding, and ARMA International's materials cover the practical side. But the idea fits in one sentence: we schedule the kind of record, not the piece of paper.

Triggers: when does the clock start?

Every retention period runs from something. Time-based triggers are the easy ones: "end of calendar year plus three years." Event-based triggers are where schedules become both more accurate and more fragile:

  • Separation from employment plus a number of years, for personnel files.
  • Expiration or completion of a contract, plus a period tied to the relevant statute of limitations.
  • Superseded, for policies, procedures and fee lists, kept until a new version replaces them, often with a short tail.
  • Close of audit, for financial records that must outlast the auditors.
  • Life of the asset, for building plans, equipment maintenance logs and the like.

The fragile part is that an event trigger only works if somebody records the event and files accordingly. If closed personnel files are mixed in with active ones, nobody can tell which files have passed their retention date without opening every folder. So the schedule has to come with a filing habit. When an employee leaves, the file moves to a "separated" drawer under the year of separation. When a project closes, its folder moves into a "closed" folder for that year. When a policy is superseded, the old version gets a date written on it and goes into a superseded set.

Avoid two non-triggers. "Until no longer needed" is fine for genuinely transitory material (drafts, routing slips, duplicate copies), but it's useless for anything substantive because everyone's definition differs. And "permanent" should mean permanent, not "we weren't sure." Every permanent series is a promise to keep something forever, with all the cost that implies, so make it deliberately.

A sample schedule

The table below shows the format I use for department-level schedules. The retention periods are placeholders to show how the columns work. They are not recommendations. Your state's general schedule, any statutes that apply, and your counsel set the real numbers.

Item Records series Includes Trigger Retain after trigger Then Office of record
GS-101 Council minutes, approved Signed minutes, attachments adopted by reference Approval Permanent Keep in vault; security copy off-site Clerk
GS-214 Accounts payable files Invoices, vouchers, approvals, check copies ("APs") End of fiscal year, after audit 6 years Shred Finance
GS-305 Employee files, separated Application, evaluations, personnel actions, separation papers Separation 7 years Shred Human resources
GS-306 Applications, not hired Applications, résumés, interview notes Position filled 3 years Shred Human resources
GS-410 Contracts and agreements Executed contract, amendments, key correspondence Expiration or completion 6 years Shred Department managing the contract
GS-522 Building permit files Application, plan review, inspections, certificate of occupancy ("C.O.s") Structure demolished 10 years Offer to archives, then destroy Building
GS-830 General correspondence Routine letters and email not part of another series End of calendar year 2 years Delete or recycle Each department
GS-900 Transitory records Drafts, routing slips, duplicates, meeting notices Purpose fulfilled Until no longer needed Delete or recycle Each department

The item numbers tie back to the general schedule, so every line has visible legal authority. "Includes" is written in plain words, using the names staff actually use; I usually add an alias index at the back as well ("POs – see GS-214"). "Office of record" settles who keeps the official copy. And "Then" makes the end of the line explicit, because "6 years" on its own leaves people wondering what they are supposed to do on the first day of year seven.

Big buckets: fewer lines, more use

A big-bucket schedule (sometimes called flexible or functional) collapses many narrow series into a handful of broad categories, each with a single retention period, usually the longest of the series it absorbs. "Financial transactions: 7 years after fiscal year end" replaces fifteen separate lines for invoices, receipts, deposit slips and journal entries. Federal agencies have used the approach under NARA's flexible scheduling guidance, and many companies have adopted it because it is far easier to apply in electronic systems, where automated retention rules don't cope well with two hundred categories.

The trade-offs are real. You keep some records longer than you strictly have to, which carries storage costs and discovery exposure. You can't bucket records that have distinct legal requirements. And in some states, local governments can't collapse general schedule items without approval. My usual compromise: big buckets at the system and folder level, where software and busy people make the day-to-day decisions, with the granular schedule underneath as the legal authority. Most staff only ever need to know which bucket they're in.

Getting departments to adopt it

Most of the work is here, and almost none of it is technical.

Interview, don't survey. Sit with the person who does the filing, not just the department head, and ask them to walk you through a typical week of paper and files. You'll learn which records exist, what they're called and where they live. Surveys come back with "see attached" and a photo of a filing cabinet.

Write in their words. If the building department calls them "C.O.s," that phrase goes in the Includes column.

Give each department its own extract. One or two pages listing only their series. Nobody reads a ninety-page schedule to find the four lines that apply to them.

Name a liaison in every department. One person who knows the schedule, fields questions and runs the annual review. Rotating the role every couple of years spreads the knowledge around.

Map series to systems. For every series, note where the records actually live: a cabinet, a shared drive folder, a permitting system, an email account. Retention applies to all of them, including systems the town stopped using years ago. Records trapped in old software still have retention periods, which is a good reason to plan legacy data and media conversion before the last person who understands the system retires.

Adopt it formally. A council or board vote, or an executive policy, depending on your structure. It gives the schedule authority, and it gives a nervous department head cover when something goes into the shredder.

Train briefly. Thirty minutes per department, with their own extract on the table, and a yearly refresher.

Annual disposition: put it on the calendar

A schedule nobody acts on is just a list. The fix is a fixed annual disposition date, set to fall after the fiscal-year audit closes so financial records are clearly eligible. On that cycle:

  1. Each liaison lists the records that have passed their retention period, by series and date range.
  2. The records officer checks every item against legal holds, open public records requests, pending audits and active claims. Anything touched by one of those stays, whatever the schedule says.
  3. Approvals are collected: the department head, the records officer, counsel where your policy calls for it, and the state archives where your state requires notice or consent.
  4. Destruction is done properly: confidential paper shredded, by a bonded service or with in-house cross-cut shredders; electronic records deleted from the systems that hold them; backups handled according to policy.
  5. A certificate or log of destruction records the series, the date range, the volume, the method, the date and who authorized it. Keep that log a long time. It is your proof that destruction happened under a policy rather than at random.

Permanent records get their own annual attention: transfer to the vault or the archives, a check on condition, and a decision about security copies. Imaging and microfilm for preservation copies covers the options. If your permanent series are growing faster than your vault, that's a sign the office needs a proper preservation program, not just more shelving.

One warning that comes up on every project: scanning a record does not, by itself, make the paper eligible for destruction. Some states allow disposal of source documents after imaging under specific conditions; others require the original for certain series regardless. Your schedule should say which, series by series.

Keep it alive

A schedule is a working document. Departments reorganize, systems change, laws change. Review the whole thing every two or three years, and add new series as soon as they appear rather than waiting for the next review. The best sign of a healthy schedule is a liaison emailing to ask where a new record type belongs. It means somebody is using it.