1
Define your scope and record formats
Identify every format in which your organization creates or receives records β paper, email, cloud files, instant messages, scanned documents, and database exports. List them explicitly in the purpose and scope section.
π‘ If your organization uses a document management system (DMS) or cloud storage platform, name it in the scope so employees know the policy applies to those systems directly.
2
Build your record classification categories
Group your record types into six to eight logical categories. Use the template's default categories as a starting point and add or remove based on your industry. Each category will map to a row in your retention schedule.
π‘ Run a quick inventory with department heads before finalizing categories β finance, HR, and legal teams almost always have record types that don't fit a generic list.
3
Research applicable retention requirements
Look up statutory minimum retention periods for each category in your jurisdiction. Key sources: IRS Publication 583 for tax records, FLSA and state labor laws for payroll, SEC rules for public companies, HIPAA for healthcare, and applicable state corporate codes for governance records.
π‘ Where multiple laws apply to the same record, use the longest retention period β then note the legal basis in Schedule B so future reviewers understand the rationale.
4
Complete the retention schedule (Schedule B)
For each record series, enter the retention period, the legal or regulatory basis, the storage location during active retention, and the approved disposition method at the end of the period.
π‘ Add a 'Permanent' row for corporate formation documents, board minutes, and audited financial statements β these are never destroyed and should be explicitly excluded from any purge process.
5
Define storage locations and access permissions
Map each record category to its primary storage system and specify which roles or departments are authorized to access it. Include how access is requested, approved, and revoked.
π‘ If you use role-based access controls in your DMS or cloud platform, document the role names here so IT can configure permissions to match the policy.
6
Document your litigation hold process
Write out the step-by-step procedure: who can issue a hold, how custodians are notified (email template or written notice), how long the hold stays active, and who has authority to lift it.
π‘ Attach a blank Litigation Hold Notice as an appendix so legal or HR can issue one immediately without drafting from scratch under pressure.
7
Assign roles and named custodians
Fill in the named role (or title) for the Records Manager and designate a custodian for each record category. For small organizations, one person may cover multiple categories β make it explicit rather than implied.
π‘ Include a succession note: 'In the absence of the Records Manager, responsibilities transfer to [TITLE].' This prevents a single point of failure during leave or turnover.
8
Set a review schedule and communicate the policy
Enter the annual review date, the approving authority, and the distribution list. Publish the policy in your intranet or employee handbook and require staff acknowledgment at onboarding and on each update.
π‘ Store a signed acknowledgment form for each employee alongside their personnel file β this creates a paper trail if a compliance dispute arises later.