Document Retention Cleanup
Documents past retention identified, categorized, and processed (deleted/archived/held). Audit log captured. Summary distributed to legal and compliance.
Before you start
- Documented retention policy per document type
- Document repository inventory
- Legal hold list
- Retention policy (how long each doc type is kept)
- Document inventory with creation dates and types
- Legal hold exceptions
The steps
- Identify documents past retention — Run the retention inventory: documents older than their type's retention period. Common: HR records (7 years), tax records (7 years), customer data (varies by contract), internal emails (often 1-3 years).
- Filter out legal-hold documents — Cross-reference against active legal holds. Any document under hold is preserved regardless of age. Removing held documents is spoliation — serious legal consequence.
- Categorize for review or auto-deletion — Some categories can auto-delete (e.g., old internal newsletters). Others need review (e.g., customer-related docs that may have lingering value). Apply the documented categorization.
- Move review-needed documents to a holding location — Move flagged documents to a 'pending review' folder. Notify document owners (or, if owners are gone, manager equivalents). Give 30 days for review before final deletion.
- Delete or archive per category rules — Auto-delete categories: hard delete with audit log. Review-completed categories: delete or archive per the reviewer's decision. Long-term archive: move to cold storage with metadata.
- Generate the deletion audit log — Log: documents deleted, by whom, when, reason (retention policy), legal-hold check completed. Audit logs are the SOC 2 / litigation defense — keep them durable and queryable.
- Distribute summary to legal and compliance — Quarterly summary: documents deleted, exceptions, legal-hold count, recommendations. Legal and compliance should know the cleanup is happening — surprise cleanups create distrust.
If it goes wrong
Document deleted that was under legal hold
Hard-fail: legal hold check is a non-skippable step. If the check failed and a document was deleted, notify legal immediately and document for spoliation defense.
Cleanup deletes documents that are still actively used
Review-period (30 days in holding folder) catches active items. If items are still flagged for deletion despite active use, the retention policy is wrong, not the document.
Audit log incomplete or unsearchable
Audit logs must be append-only and queryable. Use a dedicated tool, not a doc folder. Audit trail integrity is non-negotiable.
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