FAQ: Triggers for Retention

One of the new features of the Functional Schedule for North Carolina State Agencies is more concrete triggers for retention periods. The trigger information is located in the Disposition Instructions column of the functional schedules and is introduced by “Retain until.”

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Sometimes, the trigger is simply the trigger for destruction, as in RC No. 132.< in the figure above. In this case, we’ve determined that the calendars of agency heads and/or secretaries are useful until the end of the head or secretary’s term, at which point the records immediately lose their value and may be destroyed. Other times, the trigger starts the clock on a longer retention period; for instance, RC No. 131.5, Accreditation Records, are to be retained until superseded/obsolete, and at that trigger point, an additional 5-year retention period begins, after which the records may be destroyed. In this case, we’ve determined that there is some value to that record beyond its active life—even after an accreditation has been renewed or has expired, the records related to it may be of informational or evidential value for at least 5 years.

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The explicit triggers in the Functional Schedules are meant to add some clarity that was lacking in the old state agency program schedules, but our hope is that they will also spur necessary records management conversations within your agencies to address the remaining uncertainties. It’s important for records creators and custodians within your agency to talk about what the trigger instructions mean and (hopefully document) how they will be implemented in your offices.

The following represent some of the more ubiquitous triggers within the Functional Schedules,[1] and some things to think about:

Closed: With a record such as an investigation, the retention period begins once the case is closed.

If your office retains a type of case file, it’s important to make sure everyone understands what constitutes “closure” and whether the definition differs depending on the case.

Complete: With a record such as a report, the retention period begins once the report has been finalized.

Most government offices create reports or are engaged in other projects or activities whose records have a completion date, but what steps are necessary to consider a type of report or project “complete” in your office? And who is the custodian of that completed report?

Execution of plan: With a record such as a business plan, the retention period begins once the plan has been carried out.

Where execution is the trigger, there is often a date range on the activity: for instance, a business plan for FY 2016-2017 would have been fully executed by July 2017, thus the retention clock would begin then. Discussing when your agency considers a plan to have been executed is key to maintaining consistent retention of record types with this trigger.

Reference value ends: Once the content of a record is no longer useful or significant [to either you or your agency], it can be destroyed. This disposition is usually applies to records that were not created by the agency.

Record types with a “reference value ends” trigger in their Disposition Instructions also have a prompt for a defined agency policy. This is meant to ensure that items with mere reference value to the agency are retained consistently across the agency and that agency employees have been made aware of how the agency defines when “reference value ends.”

Superseded/Obsolete: With any record that is produced in versions, an older version can be destroyed when the new version is received.

This trigger technically means “superseded or obsolete,” but for the purpose of generating agency policy, it is sometimes useful to think of this as “both superseded and obsolete.” Even if a record has been superseded—meaning it is no longer active—if it has some informational or evidential value for you or your agency, it may not be obsolete just yet.

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Once you’ve hashed out agency policies, it’s also a good idea to discuss how the Functional Schedule triggers can be used to optimize your filing systems for easy identification of materials that have met their retention. For instance, most contracts (RC No. 1232) should be retained until expiration or termination, plus 10 years, and then they can be destroyed. While it makes sense to file open contracts alphabetically by entity for easy retrieval, filing expired or terminated contracts separately from open contracts, and keeping them in chronological order by expiration or termination date once they are closed, makes identifying records that are eligible for destruction that much easier.

Do you have questions about records retention triggers? Contact your records management analyst! And be sure to check out our other FAQs on the Functional Schedules: Records Destruction Logs and Defensible Destruction, Transitory Records, the Record Copy, Reference Copies, and Archival Custody.

[1] See the Functional Schedule “Glossary” and “Key” sections available here: https://archives.ncdcr.gov/documents/functional-schedule-state-agencies.

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