When storing files in a Shared Drive, you will need to set up a process to manually apply retention and disposition (usually deletion) of files.
You can do this by:
- Creating a process to move files/folders to specific disposition folders when they close,
- Including the disposition date in folder names (either at the creation of the file or renaming the folder at the cut-off),
- Creating process to review files routinely for retention/disposition
Option 1 – Move files to Disposition Folders when files close
This option works best for files that have a retention period that doesn’t start until the file is “closed” or an event happens.
With this method, when a file “closes” (e.g., the contract ends or other event), part of the closing process would be to move the files to a folder for the appropriate disposition date.
The Contract with Vendor X is terminated/completed and not renewed on October 11, 2022. The folder(s) for that Contract would be moved to a folder for files to be deleted in October 2028, or one to be deleted after 2028, depending on how frequently your program performs dispositions.
Once the retention period is reached, the files within the folder can be reviewed and deleted. (Files should be reviewed prior to deletion to ensure that there is no litigation hold or other reason to retain the files longer. See: Records Destruction.
Form files that have cut-off based on a specific date (e.g., end of fiscal year or end of calendar year), you can include the disposition date or retention period in the folder name.
For example, the cut-off for records of financial transactions is “end of fiscal year.” Folders for financial records can then be named like the following:
For small amounts of files, it may be feasible to have a routine review process to determine what files may have reached their retention requirements – that is going through folders and files to determine what their retention is and what is eligible. However, this will require repeated analysis of what the files are and how old they are, which is generally inefficient.
This process should be done regularly by an authorized individual and should be documented in your program’s procedures to ensure consistency.