
Building a records retention schedule
Keeping everything forever feels safe until a breach exposes ten years of client files, or a litigation hold has to search all of it. A retention schedule sets how long each kind of record is kept, and IT can enforce it.
Reviewed by the ITRS security team · Last updated
Why a schedule, not 'keep everything'
Old data is a liability with no upside. Every extra year of client files in a mailbox is more to expose in a breach, more to notify about, more to search and review in litigation, and more to protect. PIPEDA's Schedule 1 principles say personal information should be kept only as long as necessary to fulfil the purposes for which it was collected, and should be destroyed, erased or made anonymous once it is no longer needed.
A schedule also protects you from the opposite problem: deleting something you were legally required to keep.
Legal and business minimums
Start with the rules that set floors. The Canada Revenue Agency generally requires records and supporting documents to be kept for six years from the end of the last tax year they relate to, and some records, such as those on certain long-term assets and corporate records, need to be kept longer. Beyond tax, look at employment standards, sector regulators (health, financial services, professional bodies), contracts with clients, insurance policy terms and limitation periods for potential claims.
Then add business need: how long do you genuinely refer back to a closed project, a former client file or an old proposal?
Record categories
Keep categories broad enough that staff can apply them without a manual. Ten to twenty categories covers most small and mid-sized organizations.
| Category | Examples | Typical trigger |
|---|---|---|
Financial and tax | Invoices, receipts, bank records, payroll | End of the tax year |
Client files | Engagement letters, deliverables, correspondence | File closed |
Employee records | Contracts, reviews, payroll details | Employment ends |
Contracts | Vendor and client agreements | Contract expires |
Marketing | Campaigns, contact lists | Last interaction or consent withdrawn |
Transitory | Drafts, routine scheduling emails | Purpose served |
Security and audit logs | Sign-in logs, audit trails | Date created |
Retention periods and triggers
Each category needs a period and a trigger event: 'seven years after the file closes', not just 'seven years'. Event-based triggers matter because a client relationship can run for a decade; counting from the creation date would delete records you still need. Note who owns each category and the legal source for the period, so the schedule can be defended and updated.
Destruction and holds
Destroy securely
Shred paper; for electronic records, delete from systems and let backups age out on a known cycle. Wipe or physically destroy retired drives.
Record destruction
Keep a log of what categories were destroyed and when, without keeping the content.
Suspend for holds
When litigation, an investigation or a regulatory inquiry is reasonably anticipated, relevant records must be preserved regardless of the schedule. Holds override retention.
Release holds
When counsel confirms the matter is over, release the hold so normal retention resumes.
Retention questions
The duty to preserve arises when litigation is reasonably anticipated, and holds take care of that. Keeping everything indefinitely, with no specific matter in view, mostly increases breach exposure and discovery cost.
Backups are for recovery, not long-term retention. Keep them on a known, limited cycle so deleted records age out of backups within a predictable time, and say so in the schedule.
Email is a format, not a category. Treat client correspondence as part of the client file and routine messages as transitory. Purview retention labels or Vault rules can apply different periods to each.
Leadership, with counsel confirming the legal periods and category owners confirming business needs.
Enforcing in Microsoft 365 or Google Workspace
A schedule nobody enforces is a document, not a control. In Microsoft 365, Microsoft Purview retention policies apply broad rules to locations such as Exchange mailboxes, SharePoint sites, OneDrive accounts and Teams, while retention labels let specific items or libraries carry a category's period. In Google Workspace, Google Vault provides retention rules and holds. Both can keep and then delete content automatically, and both let holds override deletion.
Roll out carefully: start by retaining, confirm the categories map correctly, then switch on deletion for the categories you are sure about. We help organizations turn a schedule into tested retention settings.
Related reading.
- GuideSetting up Microsoft Purview retention policies and labelsRetention in Microsoft 365 decides what must be kept and what should be deleted. It is not a backup.
- GuideGoogle Vault retention rules and holdsGoogle Vault is Workspace's built-in tool for keeping, preserving and exporting data.
- GuideData classification policy for small organizationsA simple four-level scheme, with handling rules for each level, lets staff make the right call on sharing, storage and email without a manual, and maps straight onto…
- PracticePrivacy, Data Governance & AIPIPEDA and Quebec Law 25 readiness, data mapping, breach notification and AI governance.
Not sure what your obligations require of your systems?
Speak with our privacy practice. We are staffed 24/7. Active incident? Call (289) 582-9930, 24/7.
