What Should a Document Retention Policy Include?

A document retention policy explains what records an organization keeps, where they are stored, how long they remain available, and how they are destroyed. It should cover paper and digital material across company systems and third-party platforms. A policy connects each period to a legal duty, business need, privacy requirement, or risk.
The policy should distinguish official records from drafts, duplicates, and convenience copies. For example, the executed customer agreement may be official, while an unsigned download can be removed after review.
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Define the Scope and Ownership

State which departments, workers, systems, and business entities must follow the policy. Include employees, contractors, subsidiaries, and anyone who creates or stores company records. The scope should cover physical files, company devices, email, shared drives, business software, and cloud storage.
Assign named responsibilities instead of saying that everyone is responsible. A practical structure usually includes:
- A policy owner from legal, compliance, or records management
- Department owners who classify records and confirm retention needs
- IT staff who manage access, deletion, backups, and holds
- Employees who store official records only in approved locations
Build a Detailed Retention Schedule
A retention schedule is the working table behind the policy. Each row should describe one record category. Separate invoices, payroll registers, job applications, customer contracts, supplier agreements, insurance claims, and safety records because different rules may apply. A quick document editing tool can help employees correct and standardize files before archiving, but it should not allow them to overwrite a signed original or bypass retention controls.
Every schedule entry should include:
- The record name, responsible department, and storage system
- The event that starts the stated retention period
- The retention period and the reason supporting it
- The final action, including deletion, anonymization, or permanent preservation
The trigger date needs careful definition. A contract might be retained for six years after termination, not six years after signature. A personnel file may be counted from the employee’s departure. A complaint record may run from case closure, while a tax file may run from the filing date.
Avoid assigning one period to every record. In the United States, the IRS generally uses three years for many tax records, although some cases require six years, seven years, or indefinite retention. Employment tax records generally require at least four years. EEOC guidance commonly requires one year for personnel records and three years for payroll records. OSHA injury and illness forms generally require five years, while certain employee exposure records require at least thirty years.
For personal data covered by UK or European privacy rules, the policy should explain why continued storage remains necessary. Data protection law does not provide one universal period for every category.
Include Legal Holds and Other Overrides

A legal hold temporarily stops normal deletion when records may relate to litigation, an investigation, an audit, or a regulatory request. The policy should explain who can issue a hold, which people and systems it covers, and how recipients confirm compliance.
The process should identify relevant custodians, date ranges, document types, shared folders, devices, and third-party systems. Automatic deletion must be suspended where necessary. The hold remains active until an authorized owner releases it in writing.
Routine destruction must stop when a dispute is reasonably anticipated. Following an ordinary schedule does not excuse destroying information after a preservation duty begins.
Set Storage, Security, and Version Rules
Retention has little value when records cannot be trusted or found. Require access controls based on job duties, strong authentication, appropriate encryption, and activity logs for sensitive repositories. Medical files, payment information, and investigation records should not sit in general team folders.
Define which version is authoritative. Signed agreements, approved policies, filed returns, and final reports should be protected against casual editing. Metadata, attachments, and signature certificates may also form part of the record.
Backups need separate treatment. A backup supports recovery after failure or ransomware, but it is not automatically a searchable archive. Normal backup rotation may overwrite older copies, so required records must be preserved independently.
Describe Secure and Verifiable Destruction
The policy should explain how records leave every location when their period ends. Confidential paper should undergo crosscut shredding or destruction by a vetted provider. Electronic records should be deleted or sanitised so they cannot be readily reconstructed, especially when devices are reused or returned.
Destruction should cover email, shared storage, local downloads, synced folders, removable media, business applications, and managed devices. Keep a destruction log with the record category, covered dates, method, approval, destruction date, and responsible person.
Review, Train, and Test the Policy
Review the schedule at least annually and whenever the company enters a new country, adopts a new system, changes services, or closes a business unit. Train workers during onboarding and provide targeted refreshers for teams handling HR, finance, legal, customer, and health information.
Testing should include sample searches, expiration checks, access reviews, and confirmation that legal holds override automated deletion. A policy works only when systems, employee habits, and documented decisions match its written rules.
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