Sending records to offsite storage is often necessary. However, dealing with active records in storage, i.e., those sent to offsite storage before the retention trigger event has occurred, can be a tricky proposition. The prudent implementation for “Active +” records is to utilize an Event Date as the base date for the calculation of the Destruction Date. This ensures that these records will not be destroyed before the trigger event plus the appropriate retention period has transpired. The deliberate population of a date into the Event Date field would be required for the Destruction Date to be calculated.
This again is prudent, but for many companies leads to a large volume of records in storage with undefined retention. There are a few things to consider to remediate this situation.
- Consider whether all cartons for some of the “Active +” record classes might be sent to storage once inactive, i.e., only after the trigger event has occurred. If this can be determined then the implementation for such record classes can be safely updated to utilize the To Date (latest Records Date) if available and if not then the Storage Date.
- Identify records in storage that may already be inactive and populate a date in the Event Date field. Even if it is not known that all cartons for a particular record class are sent to storage once inactive, it may be that some departments have a policy to send particular records offsite only once the trigger event has occurred. In that case, these subsets of cartons could have the To Date (or Storage Date if that is not available) populated into the Event Date field. The inventory can also be searched for inactive keywords such as “paid off,” “terminated” or “cancelled”. Such lists can be reviewed and if the cartons are determined to be inactive then the To Date (or Storage Date if that is not available) can be populated into the Event Date field.
These steps will help to narrow the volume of cartons with undefined retention due to an Event Date implementation. The remaining records should be reviewed periodically to identify cartons whose trigger events have occurred and have the current (or appropriate, recent) date populated into the Event Date field so that a Destruction Date can be calculated. It is good practice to include this review of undefined cartons during the periodic review of destruction eligibility reports.