For the most part, the minimum retention periods set out in TSLAC’s schedules provide a specific amount of time that records must be kept. However, some record series have the retention period “AV: as long as administratively valuable.” How long should governments keep those types of records? Well, each government will need to make that determination for themselves. As you’ll see in this blog post, it’s all about finding the right balance.
This post provides guidance to help governments determine an appropriate length of time to keep records with an AV retention period. It discusses the purposes and values of records, potential risks when keeping records, and other relevant considerations. At the end there are some examples and a template that governments can use to help determine how long to keep AV records.
Determining Record Values
So, you have some records that you need to keep for as long as they are administratively valuable—but what is “administrative value” anyway? And what other values should you consider when deciding how long to keep these records? Identifying the value of records will help you determine the minimum amount of time that you should keep them.
Definitions
The administrative value of a record refers to the purpose that the record serves for the government. All government records have a primary purpose, which is usually the reason that the record exists in the first place. Once the primary purpose has been fulfilled, many records also have one or more secondary purposes, which are other reasons that the record may be useful. See the chart below for specific definitions of these terms.
Term | Definition | Source |
AV: As Long as Administratively Valuable | The immediate purpose for which the record was created has been fulfilled and any subsequent need for the record to conduct the operations of the agency, if any, has been satisfied. | State Records Retention Schedule (RRS) |
Administrative Value | The usefulness or significance of records in supporting the operations and management of the organization that created them. | Dictionary of Archives Terminology (SAA) |
Primary Value | The usefulness or significance of records based on the purposes for which they were originally created. | Dictionary of Archives Terminology (SAA) |
Secondary Value | The usefulness or significance of records based on purposes other than that for which they were originally created. | Dictionary of Archives Terminology (SAA) |
Other Values to Consider
In addition to administrative value, records may also have fiscal, legal, or historical value. A record has fiscal value if it is useful for financial or business functions (i.e., receipts, transaction logs). Records with legal value document the legal rights, duties, interests, or obligations of the government itself or of individuals (i.e., deeds, contracts, licenses). Historical value refers to the ability of a record to be useful for understanding the history of the government and what changes have occurred over time. See our blog post on determining historical value for more information on that topic.
Records may also be needed in the case of an audit or litigation, so it’s a good idea to check with your legal and accounting departments for advice. Your legal department can also help you determine if there are any laws or rules that could affect the retention of the records.
Using Purposes and Values to Determine Minimum Retention
When records have the retention period AV, government staff should consider the values and purposes of the records and determine which of these should be prioritized. After considering values and purposes, government staff should set a minimum retention period that will allow the records to achieve these purposes. All records should be retained at least until their primary purpose has been fulfilled and potentially longer if there are other relevant and important purposes or values that the records could provide.
Limiting Factors
Determining the values of a record can help you determine the minimum amount of time to keep it. However, there may also be factors that limit the usefulness, practicality, or prudence of keeping a record past a certain point of time. You can use these factors to help determine an outer limit for the record’s retention period.
Risks
There can be risks associated with keeping records too long. For example, if your government over-retains records, you could easily end up with too many records to keep track of. If there is a high volume of records, it can take longer for staff to retrieve the records they need and it can become difficult to keep records organized. This can negatively affect your business practices and make your government less efficient and effective.
Also, the longer a record is retained, the longer it is at risk of being lost, stolen, or exposed. Government entities are often the targets of hackers and other bad actors. Many government records contain sensitive or personal information, so it’s important to consider how you will mitigate information privacy risks. As another of our blog posts explains, one way to do that is by disposing of records appropriately and in a timely manner.
Other Considerations?
Aside from risks, there may be other factors that make records either unnecessary or impractical to keep after a certain point. For example, information contained in the record may be duplicated in a different record, such as data that is later compiled into a report. Also, you may need to take storage limits into consideration. If the records take up a lot of physical space or digital storage space, your government may need to limit the number of records that are kept for practical reasons.
How to Determine AV?
At minimum, records with the retention period AV should be kept for as long as it takes for their primary purpose to be served. After that, governments should determine whether there are any secondary purposes that the records could serve. If there are, the government can choose to keep the records longer. However, governments should also consider whether they should limit the retention period due to potential risks or other considerations that make the records unnecessary or impractical to keep.
You can use the following questionnaire to help you benchmark an appropriate retention period for an AV record.
Question | Answer/Notes | Estimated Minimum Time Period | Estimated Maximum Time Period |
What is the primary purpose of the record and how long will it take for that purpose to be served? | |||
Are there any secondary purposes? If so, how long will it take for those purposes to be served? | |||
Are there any risks associated with keeping these records? If so, how should this affect the retention period? | |||
Are there any other considerations? If so, how should this affect the retention period? |
Examples
Example 1: Unsolicited Resumes
Unsolicited resumes have the retention period “AV” for both local governments (GR1050-38) and state agencies (3.1.034).
Your local city is a great place to work. Because of this, city staff receive several resumes in the mail each month from local residents who are hoping to get a job there, even when there aren’t any open positions. When a position opens up, the HR department reviews the resumes they’ve received in the past six months to see if any of them might be a good fit.
Question | Answer/Notes | Estimated Minimum Time Period | Estimated Maximum Time Period |
What is the primary purpose of the record and how long will it take for that purpose to be served? | A local resident wants to provide their information in case a job opens up in city government. | HR always reviews resumes from the past 6 months. | HR will not review a resume if it was submitted more than 1 year prior. |
Are there any secondary purposes? If so, how long will it take for those purposes to be served? | The city keeps statistics on the resumes they receive each year. | Statistics are compiled every January. | |
Are there any risks associated with keeping these records? If so, how should this affect the retention period? | Resumes contain personal information such as names, telephone numbers, email addresses, and mailing addresses. There is a risk of information exposure. | The city’s legal department has recommended disposing of these records as soon as possible after they are no longer useful. | |
Are there any other considerations? If so, how should this affect the retention period? | n/a |
After reviewing the purposes, values, risks, and other limiting factors, city staff decide to keep unsolicited resumes for: one year.
Example 2: Packing Slips
Packing slips have the retention period “AV” for both local governments (GR1075-03c) and state agencies (5.3.004).
The University Library receives many boxes of new books each week. Every box contains a packing slip that lists the books contained in the box, the vendor name, and the order number. Librarians use the packing slips to make sure all the books they ordered have arrived and that they didn’t get any extra books by accident. The packing slips are used again when the librarians approve invoices at the end of each month. The library currently has 10 years worth of packing slips in a filing cabinet that is stuffed to the brim.
Question | Answer/Notes | Estimated Minimum Time Period | Estimated Maximum Time Period |
What is the primary purpose of the record and how long will it take for that purpose to be served? | The slips document which books have arrived at the library. They are checked against book orders upon arrival. | 1 day | 2 weeks |
Are there any secondary purposes? If so, how long will it take for those purposes to be served? | The slips are used to double check invoices before they are paid at the end of the month. The purchasing department has used packing slips in the past when there was a dispute with a vendor about a previous bill. | 1 month | A couple years |
Are there any risks associated with keeping these records? If so, how should this affect the retention period? | n/a | ||
Are there any other considerations? If so, how should this affect the retention period? | The filing cabinet where the packing slips are kept is completely out of room. | The filing cabinet can comfortably hold 7 years worth of packing slips. |
After reviewing the purposes, values, risks, and other limiting factors, the University Library staff decide to keep packing slips for: two years.
Further Reading
There are many factors to consider when determining how long to keep AV records. The blog posts below provide further information that can help you determine the right balance.
- The Meaning of “Historical Value” on Local Government Schedules
- Data and Disposition: How Disposition Protects Loss of Privacy in a Data-Driven World
- Why Should I Purge Electronic Records That Have Met Retention?
- Is it Possible to Keep Records Too Long?
- Information Governance and the Records Life Cycle
- Customizing Your Local Government Retention Schedule
References:
- Dictionary of Archives Terminology. Society of American Archivists. 8/30/2022. https://dictionary.archivists.org/index.html
- Patricia C. Franks, Records and Information Management, Second Edition (Chicago: American Library Association, 2018).