Central finding: HR retention review is useful when each record class has a stated rule, system owner, access purpose, retention trigger, and deletion evidence.

Scope and population

Define the record classes in scope: hiring, onboarding, payroll, benefits, leave, performance, discipline, and separation. Record the system and owner for each.

Map shadow stores such as shared drives, inboxes, local exports, and vendor systems. A record can leave the official system through a copy or attachment.

Evidence and review method

Compare the stated retention rule with the actual record. Record the trigger event, retention period, deletion method, and evidence.

Review access by role and purpose. Retained records should not remain available to people who no longer need them.

Findings and limitations

Sample records that should have been deleted and records under a legal hold or approved extension. Do not delete records during the review.

Report gaps by class and system with an owner and remediation date. The review does not provide a legal conclusion.

The review describes the sampled records, not the whole population. A closed status is not proof that the underlying question was resolved. Corrective actions need an owner and a retest date.

Method note

Define the record classes in scope: hiring, onboarding, payroll, benefits, leave, performance, discipline, and separation. Record the system and owner for each. Map shadow stores such as shared drives, inboxes, local exports, and vendor systems. A record can leave the official system through a copy or attachment. Compare the stated retention rule with the actual record. Record the trigger event, retention period, deletion method, and evidence. Review access by role and purpose. Retained records should not remain available to people who no longer need them. Sample records that should have been deleted and records under a legal hold or approved extension. Do not delete records during the review. Report gaps by class and system with an owner and remediation date. The review does not provide a legal conclusion.

Sources

  1. Standards for Internal Control in the Federal Government
  2. Privacy Framework
  3. Records Management Policy and Guidance
Discuss your workflow