Here is the next tip from our GRS Team.
Flexible retentions in the GRS: Your new best friend
Many new GRS disposition instructions look like this: “Destroy when 3 years old, but longer retention is authorized if required for business use.” Some reviewers have criticized us for this latitude, and recommended that we state a specific retention period (in the above case, 3 years), then stop. They object to the elastic clause. Here’s what we bet is at the bottom of these objections, and why we believe flexibility is really in agencies’ best interests.
We suspect the main objection to retention flexibility is a fear that offices outside the direct sight lines of an agency’s records management function will abuse “longer retention is authorized” as license to never discard anything ever again. If our guess just tapped into the primal root of your own objection to flexible retention, we have good news. Flexible retention really is the agency records officer’s new best friend. If a GRS item has an elastic disposition, as long as you retain records for the minimum time required, you can do one of three things:
- You can determine how long your agency has business use for the records. Answering the question “how long is enough?” is more work than pulling a number out of a hat, and less entertaining than throwing darts at a dartboard, but conversation with subject area experts should get you to a good, defensible answer. Once you’ve determined the right time period for your agency in excess of the minimum in the GRS, you can publish it without the flexible elastic clause in your records manual and cite the GRS item as your authority.
- You can determine that your agency will do just fine with the minimum retention period in the GRS, and not a day longer. Use the GRS item in your agency manual without the flexible elastic clause and cite the GRS item as your authority.
- You can do nothing. Let individual offices in your agency determine their own business needs. We can’t recommend this as a best practice, but we acknowledge it as an option.
And the good news mentioned above? Did you notice that in all three of these options you do not have to process a records schedule through NARA or ask for a GRS exception? You have the authority to make choices to best suit your agency. We think that’s very good news indeed.
2 thoughts on “Flexible Retentions in the GRS”
NARA already had in its “Disposition of Federal Records” [Chapter IV, Applying General Records Schedules to Agency Records] publication the guidance for agencies that have the need to modify the GRS submit a “tailoring” request to NARA to modify the GRS just like any other retention schedule. The effect of including the open-ended disposition instructions places the burden of having to make additional policies (after the fact) to have to have to go in and strip that out. Why not leave the burden on the desiring agencies and leave the rest of us alone.
Here is the response from our GRS Team: Thanks for your comment. Please note “The Disposition of Federal Records publication” has outdated CFR citations and is being revised. In updating the GRS, we debated the pros and cons of adding the new disposition authority language. We believe the flexibility it offers helps more agencies than it inconveniences. Please contact us on GRS_Team@nara.gov if you would like to discuss your concerns in more detail.
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