Type

Description

Administrative

These citations provide context about other recordkeeping requirements. For example, they may include definitions or explanatory sections. ADM is also used for requirements that laws from external jurisdictions/regulators must be followed. For example, New Mexico citation 17.3.310.10 NMAC requires that certain gas, water, sewer, and electric utilities follow the National Association of Regulatory Utility Commissioners (NARUC) “REGULATIONS TO GOVERN THE PRESERVATION OF RECORDS OF ELECTRIC, GAS AND WATER UTILITIES.” This citation is entered as 17.3.310.10 NMAC [ADM].

Relevant abbreviations:

ADM, DEF

Duration / Statutes of Limitations / Periods of Prescriptions

These requirements limit the duration for actions that commonly have recordkeeping implications. Some common examples include limits on duration to bring a legal claim, limited assessment periods for taxes/audits, or intellectual property ownership rights durations. They are not recordkeeping requirements but may be relevant in evaluating the risk of how to retain related records.

Relevant abbreviations:

IPDEV, SOLEV

Handling/Sanctions

Handling citations deal with records format, destruction method, location requirements, whether there are requirements to protect records, and whether there are sanctions associated with non-compliance.

Relevant abbreviations:

BRC, CBD, DST, FMT, LCT, LNG, PTC, SAN, SIG,STZ, WRM,[ABBV]+G, [ABBV]+M

Retention - Minimum

Minimum retention requirements specify the minimum amount of time that records must be retained. Most identify a defined period of time for retention; some just specify that records must be retained.

Relevant abbreviations:

CLO, CR, CY, DAO, DOE, EV, EVL, EVS, EXP, FY, LOA, LOC, LOM, LST, NONESTATED, PRD, ROR, SET, SUP, SUPX2, SUPX3, TY, VAREV

Retention -  Maximum

Maximum retention requirements require that records disposition must occur before a specified time. These are commonly associated with privacy laws.

NLTG, NLTM, [ABBV]+G, [ABBV]+M

Abbreviation

Title

Description

... G

General

Requirements that are general or permissive in nature. For example, FMTG (FMT+G) is used where keeping electronic records is permissible but not required. Going forward, please use either a +G or a +M on all handling requirements.

... M

Mandatory

Requirements that are mandatory in nature. For example, FMTM (FMT+M) is used where keeping a hard copy record is required. Going forward, please use either a +G or a +M on all handling requirements.

ADM

Administrative Requirements

This is used for administrative requirements that have record keeping implications not already captured by another abbreviation.

BRC

Breach Notification

Used to indicate a records retention requirement associated with a security breach.  Often relates to records of notifications to parties concerning a definite or possible breach involving personal information.

CBD

Cross Border

Used where there is a requirement restricting or prohibiting the cross border movement of requirements.  Most commonly associated with restrictions concerning personally identifiable information.

CLO

Closure

Retain until the closure/completion/fulfillment of an account, deal, transaction, negotiation, file, delivery, or request.

CR

Creation

This abbreviation is used when there is no specified trigger.  For example, a retention requirement specifying retention for 7 years will be CR+7.

CY

Current Year

Retain until the end of the current year or begin calculation at the end of the current year (retain until the end of the current year, plus the period of years stated).

DAO

Destroy at Option

Destroy at the record owner’s discretion so long as it does not conflict with other legal retention requirements.

DEF

Definitions

This trigger captures definitions useful in determining the applicability of other citations.

DOE

Duration of Employment

Retain until retirement, resignation, termination, or death of employee. Includes the duration of work in the current position and duration of volunteer work.

DST

Destruction

Used where there is a requirement to destroy records in a particular way including but not limited to shredding, burning, or by use of chemicals.

EV

Event

Retain until after an event has occurred, or until the occurrence of an event. This is the default that is used when an abbreviation/trigger event does not match other abbreviations/triggers listed..

EVL

Event, Whichever is Longer

Used where a retention period contains multiple requirements followed by "whichever is longer". All of the requirements are broken out into their own citation and each is designated with the EVL trigger abbreviation.

EVS

Event, Whichever is Shorter

Used  where a retention period contains multiple requirements followed by "whichever is shorter". All of the requirements are broken out into their own citation and each is designated with the EVS trigger abbreviation.

EXP

After Expiration

Retain until expiration. Used for expiration or termination of agreements, contracts, plans, policies, permits, licenses, registrations. Also used for records relating to expiration dates/shelf life of products (pharmaceuticals, food) and the expiration of a process.  See SUP for instances where these are superseded.

FMT

Media/Format

Used where there is a requirement to keep records in a particular media or format or where a certain format is allowed but only under certain circumstances. For WORM or other un-editable formats use WRM. For signatures use SIG.

FY

Fiscal Year

Retain until the end of the fiscal year or begin calculation at the end of the fiscal year. (Retain until the end of the fiscal year, plus the period of years stated).

IPDEV

Intellectual Property Duration

Used to capture the duration of intellectual property rights. Not in and of itself a retention period, but potentially valuable in setting a retention period.

LCT

Location/Movement

Used where there is a requirement to keep a record at a particular location or where the movement of a record is allowed or prohibited. For cross border requirements use CBD.

LNG

Language

Used where there is a requirement to keep a record in a specific language.

LOA

Life of Asset

Retain for the life of the asset. This includes equipment (vehicles, tanks, pipes, systems, tools, and related items), facilities (plants, buildings, and related structures), and other property (land, securities, bonds, investments, and any other things that are owned).

Retired equivalents: LOF, LOE

LOC

Until Divestiture/Life of Enterprise

Used where there is a requirement to keep records until or after divestiture of a division, function, or of the entire enterprise.  Retain permanently for the life of the enterprise and its legitimate successors. This also includes the post-care period where applicable. Where there is a requirement to keep something permanently it often relates to the medium, not the retention, so many requirements with the word permanent are categorized as a format requirement.

Retired equivalents:  PRM

LOM

Life of Manufacturer

Retain until an item is no longer manufactured, or until the last date of manufacture.

LST

Last Use

Retain until the last access for any purpose including final use, after use, last effective date. Put another way, retain while the record remains in active use or as long as it’s being used.

Retired equivalent: ACT

NLTG

No Longer Than/Privacy General

Used where there is a requirement to keep records relating to privacy or Pll for no longer than a general period such as while the information is relevant or until the purpose for collecting has expired. For requirements that specify a certain number of years or months see NLTM.

Retired equivalent: NLT

NLTM

No Longer Than/Privacy Mandatory Destruction

Used where there is a requirement to keep records relating to privacy or Pll, or other requirements to keep records for no longer than a specific period. If a specific period is not included, or the period relates to the purpose the information is collected, see NLTG.

Retired equivalent: NLT

NONESTATED

No Retention Stated

Used where there is a requirement to keep records, but no period of time is specified.

Retired equivalent: NONE

PRD

Life of Product

Retain for the life of the product.

PTC

Protection

Used for requirements designed to protect records from damage, theft, or unauthorized access by environmental, human, or technological mechanisms.

ROR

Remainder of the Retention Period

Keep records for the remainder of the retention period as required under the same or another law, as mandated. Generally relates to the cessation, divestiture, dissolution, or acquisition of a corporation or line of business and the retention of records thereafter.

SAN

Sanction

Used where there is a sanction related to record keeping or generally applicable to a law that contains record keeping or handling requirements.

SET

Settlement

Retain until settlement or final resolution of relevant matter. Includes Claims, Complaints, Audits, Examinations, and related items.

SIG

Signature

Used where there is a signature requirement, including where an original signature or a wet signature is required.

SOLEV

Statute of Limitations and an Event

The maximum time after an event that legal proceedings based on that event may be initiated.  Not in and of itself a retention period, but potentially valuable in setting a retention period.

Retired equivalent: SOL

STZ

Sanitize

Used where there is a requirement to anonymize, pseudonymize, or otherwise sanitize PII from a record, database, object, artifact, etc.

SUP

SUPX2

SUPX3

Superseded

Superseded Twice

Superseded Three Times

Retain until the record is replaced by a new record or an updated version of the existing record.

TY

Tax Year

Retain until the end of the tax year or begin calculation at the end of the tax year (Retain until the end of the tax year, plus the period of years stated).

VAREV

Various Events

Used when the retention period in the regulation is too complicated to fit into an abbreviation. Where possible, each unique retention period will be broken into its own citation using EVL and EVS, so this trigger is reserved for convoluted or vague triggers.

Retired equivalent: VARIOUS

WRM

WORM

Used for WORM (Write Once Read Many) requirements or similar requirements to save records in an un-editable format.