Records Retention Schedules: How to Build and Maintain One

Every city and county office holds onto some records it no longer needs. Somewhere in that same office, someone has probably thrown away a record that should have been kept. Neither problem comes from carelessness. Both come from the same gap: nobody has written down, in one place, what each type of record is, who is responsible for it, and how long it has to be kept.

That written document is a records retention schedule. Once you have one that matches how your office actually works, a lot of daily questions get easier. Can I clear out this file cabinet? Do we still have the 2019 inspection reports? Who decides whether these emails can go? The schedule answers them, and it gives you legal cover when you dispose of records on time.

This guide walks through building a schedule from the ground up and keeping it current. You will start from your state's schedule, take inventory of what you actually hold, assign owners, handle electronic records, and destroy records in a way you can document and defend. It is written for offices without a dedicated records manager. You do not need special software to follow it, only steady time each week and a willingness to ask questions of the people who create the records.

What a retention schedule does, and what it does not

A retention schedule is a list of the types of records your organization creates or receives, with a rule for each one: how long to keep it, what event starts the clock, and what happens at the end. That last part is called disposition, and it usually means one of three things: destroy the record, transfer it to an archive, or keep it permanently.

The schedule is also, in most states, your legal authority to dispose of public records. Without an approved or adopted schedule, many local governments have no clear authority to destroy anything at all. That is why "we just keep everything" is so common. It feels safe, even though it rarely is.

A few things the schedule is not:

• It is not a disclosure guide. Whether a record must be released under your state's public records law is a separate question. A record can be scheduled for permanent retention and still be partly exempt from disclosure, or scheduled for short retention and fully public while it exists.
• It is not a filing system. The schedule tells you how long to keep records, not how to name folders. A good filing structure supports the schedule, but they are different documents.
• It is not a list of individual documents. Schedules work at the level of record series, not single files.

Terms you will use throughout

• Record series: a group of records filed together, used for the same purpose, and kept for the same length of time. "Building permit files" is a series. One permit application is a document within it.
• Retention period: how long the series must be kept.
• Trigger event: the event that starts the retention clock, such as "after the contract expires," "after the fiscal year closes," or "after the employee separates."
• Office of record: the department responsible for keeping the official copy.
• Record copy and convenience copy: the official version versus duplicates kept for reference.
• Legal hold: an instruction to preserve records, regardless of their retention period, because of litigation, an audit, an investigation, or a pending records request.

Start from your state's schedule, not a blank page

You almost never need to invent retention periods yourself. In most states, a state archives, records commission, secretary of state, or similar office publishes retention schedules for local governments. The names vary. You may see "general records schedule," "local government retention schedule," "records disposition authority," or something similar. Some states publish one schedule for all local governments. Others publish separate schedules for counties, municipalities, special districts, law enforcement, utilities, or other functions.

How you use the state schedule also varies by state. In some states, local governments adopt the state schedule as written. In others, you build a local schedule based on it and submit it for approval. Some states expect the governing body to adopt the schedule by resolution or ordinance. Some require you to notify a state office, or get permission, before each destruction. Because these requirements differ so much, confirm the process with your city attorney, your state archives, or your state clerk association before you start drafting.

Five things to do with the state schedule first

1. Get the current version from the official source. Old copies circulate for years. Check the revision date and save the official version, not a copy someone emailed in 2015.
2. Read the instructions and definitions before the tables. The front section usually explains how to read the schedule, how trigger events work, how convenience copies are treated, and what approvals are required. Skipping it leads to misreadings.
3. Identify every schedule that applies to you. A city that runs a water utility, a police department, and a library may need to consult several.
4. Write down the approval and notification steps. Note who must sign off on your schedule and on each destruction, and whether any forms are required.
5. Find out how to request a new series or a change. You will find records that do not fit anywhere. Know the process for asking before you need it.

Minimums, not suggestions, and not maximums either

State retention periods are generally minimums. You can usually keep a record longer if there is a business reason, but longer is not automatically safer. Every record you keep past its retention period is a record you must store, protect, search when a public records request arrives, and potentially produce in litigation. Keeping records on schedule and then disposing of them on schedule is the defensible position.

Other requirements can also apply. Grant agreements, federal program rules, tax rules, and personnel laws sometimes set their own retention periods. State schedules often account for these, but not always. When a grant or program has its own requirement, note it on the schedule and follow whichever period is longer. Your finance director and city attorney can help you confirm which rules apply.

Take inventory of what you actually hold

The state schedule tells you what records local governments typically have. The inventory tells you what your office has. This is the step most offices skip, and it is the reason many schedules look correct on paper but do not match the shelves or the shared drive.

Plan the inventory one department at a time

Do not try to inventory the whole organization at once. Pick one department, finish it, and move to the next. The clerk's office is a good place to start because it usually holds core series (minutes, ordinances, resolutions, agendas, contracts, and election records), and the clerk is often the person leading the effort anyway.

For each department, use three methods together:

• Walk the physical storage. Offices, file rooms, basements, offsite storage, and that closet nobody has opened in a while.
• Review electronic storage. Shared drives, department folders, email, cloud storage, and line-of-business systems such as permitting, finance, utility billing, and agenda management software.
• Interview the people who do the work. Ask three questions: What do you create? What do you receive from outside? Where does it go when you are done with it?

Interviews often reveal series that do not show up anywhere else, such as a spreadsheet one employee maintains that the department relies on, or records kept in a vendor portal.

What to capture for each series

Use a simple form or spreadsheet with consistent fields. Here is a workable set:

Inventory tips that save time later

• Use the names staff use, then map them. Staff may say "plan review folders" when the state schedule says something else entirely. Record both.
• Do not stop at paper. Electronic series are where most surprises live.
• Look for orphaned records. Former employees' drives and mailboxes, retired software, and boxes with no label often hold series nobody currently owns.
• Flag sensitive material as you go. It will affect destruction methods later.
• Do not destroy anything during the inventory. Even obvious junk can wait until the schedule is in place. Destroying during inventory is how mistakes happen.

Match each series to a retention rule

With the inventory in hand, you build a crosswalk: each series in your inventory matched to a series on the state schedule. This is careful, unglamorous work. Set aside focused blocks of time for it.

Three outcomes for each series

1. Clean match. Your series fits a state series clearly. Record the state item, retention period, trigger event, and disposition.
2. Partial match. Your series fits more than one state series, or fits loosely. Generally, choose the most specific match. If a series truly contains records covered by two different items, either split it into two series or ask your state archives which item applies. Do not pick the shorter period just because it is convenient.
3. No match. Nothing on the state schedule fits. Do not guess. Keep the records, note the gap, and use your state's process to request guidance or a new series.

Get the trigger event right

Most retention errors are trigger errors, not period errors. "Five years" means very different things depending on whether the clock starts at creation, at the end of the fiscal year, at contract completion, or at project closeout. Write the trigger on your schedule in plain words, and make sure each series owner understands it. For series with event-based triggers, such as "after the property is sold," someone has to track when that event happens.

Name the office of record

Many records exist in several places. Adopted council minutes may be held by the clerk, attached to a department's project file, and saved in someone's email. Only one of those is the record copy. Your schedule should name the office of record for each series, so everyone knows which copy carries the full retention period.

Many states allow convenience copies to be destroyed when they are no longer useful, but definitions differ, and a "copy" that has been annotated or used to make a decision may become a record in its own right. Check your state's definitions before telling departments they can clear out duplicates.

Lay out your local schedule

Whether or not your state requires a separate local schedule, it helps to keep one working document that combines your inventory and the state rules. Typical columns:

• Local series title and description
• Office of record
• State schedule item reference
• Retention period and trigger event
• Disposition (destroy, transfer, or permanent)
• Format and system of record
• Series owner
• Notes, including grant or program requirements and sensitive content

Assign owners and make the responsibilities real

A schedule without owners is a document that gets filed and forgotten. Every series needs a person, by role, who is responsible for keeping it on schedule.

Roles to define

• Records officer or coordinator. Often the clerk. Maintains the schedule, coordinates with the state, trains staff, runs the annual review, and keeps the destruction log.
• Department records liaison. One person per department who knows the department's series, answers questions, and coordinates destruction batches.
• Series owner. The role responsible for a specific series: applying the retention rule, tracking trigger events, and flagging records ready for disposition.
• City attorney or legal counsel. Issues and releases legal holds, and reviews questions about retention authority.
• IT staff or IT vendor. Implements retention in electronic systems, manages backups, and handles secure deletion and device disposal.
• Approver. The person or body that must authorize destruction. Depending on your state and local policy, this may be a department head, the manager, the clerk, the governing body, or a state office.

Make the assignments stick

• Assign by role, not by name. "Utility billing supervisor" survives turnover. "Pat" does not.
• Name a backup for every role. Destruction approvals and hold notices should not stall because one person is on leave.
• Put it in writing. A short records management policy, adopted or approved according to your local practice, should reference the schedule and list the roles.
• Add records duties to onboarding and offboarding. New staff should learn which series they own. Departing staff should hand off their files, email, and drive contents before their accounts are closed. Offboarding is when records most often disappear.
• Ask for an annual sign-off. Each liaison confirms once a year that their department's series list is accurate. It takes a few minutes and keeps the schedule honest.

Electronic records: same rules, different risks

The most important principle for electronic records is simple: retention follows content, not format. A contract is kept as long as contracts are kept, whether it is a signed paper original, a PDF on a shared drive, or an attachment in someone's inbox. Most problems with electronic records come from forgetting this.

Email

In most states there is no single retention period for "email." Each message takes the retention period of the series it belongs to. An email approving a change order belongs with the project or contract file. A reminder about a staff lunch may be a short-term or transitory record. Some states publish specific email guidance, including approaches based on the sender's role, so check yours.

Be careful with automatic deletion rules. A blanket rule that deletes all email after a set period can destroy records that should be kept longer, unless the rule was built to match your schedule and your state allows it. Before turning on any auto-delete setting, confirm it with your city attorney and document how it aligns with the schedule.

Text messages and personal accounts

If city business is conducted by text message or on personal accounts, those messages may be public records subject to retention. The cleanest approach is a policy that keeps city business on city systems and explains how to preserve any business message that ends up on a personal device. Your state's law and guidance will shape the details, so confirm your approach with counsel.

Shared drives

Shared drives tend to become the digital version of the unlabeled basement box. Two habits help:

• Organize folders by record series where practical, so a folder can be reviewed and disposed of as a group.
• Review shared drives on the same annual cycle as paper, rather than treating them as permanent storage by default.

Line-of-business systems

Permitting, finance, payroll, utility billing, agenda management, and similar systems often hold the record copy of important series. For each system, find out:

• Whether records can be deleted according to the schedule, and at what level (individual records or whole categories)
• Whether a legal hold can be applied to stop deletion
• Whether records can be exported in a usable, non-proprietary format
• What happens to your data if you leave the vendor

Capabilities differ by product and change over time, so confirm current features with each vendor in a demo and get the answers in writing. When procuring new systems, add retention, hold, export, and deletion requirements to the specifications.

Backups are not a retention system

Backups exist for disaster recovery. They are not where records should be kept for their retention period, and they should not be relied on as an archive. Talk with IT about how long backups are kept and how that interacts with your destruction process, since a record deleted from a live system may still exist in backups for some time. Your state or counsel may have guidance on how backups are treated.

Long-term and permanent electronic records

Records you must keep for many years, or permanently, need extra care, because file formats and storage media age. Plan to:

• Store long-term records in widely used, well-documented formats where possible
• Keep them in a system or storage location you control, with clear ownership
• Check periodically that files still open and are complete
• Migrate records when a system is retired, and document the migration

Scanning paper records

Many offices want to scan paper and destroy the originals. Some states allow this only under specific conditions, such as quality standards, verification steps, or approval, and some permanent records may need to stay on paper or be transferred to an archive. Check your state's rules on imaging before destroying any scanned originals, and keep a record of your quality control steps.

Destruction procedures you can defend

Destroying records on schedule is part of good records management, not a risk to avoid. What makes destruction defensible is consistency: the same steps, the same approvals, and the same documentation every time.

Run destruction in batches

Rather than destroying records whenever someone has time, set one or two destruction periods a year. Liaisons identify eligible records ahead of time, approvals are collected together, and everything is logged at once. Batches are easier to supervise and easier to document.

Pre-destruction checklist

Before any records are destroyed, confirm each item:

• The series is on your approved or adopted schedule.
• The retention period has passed, calculated from the correct trigger event.
• The records are the record copy, or are confirmed convenience copies your state allows you to destroy.
• No legal hold applies, including litigation, threatened litigation, audits, and investigations.
• No pending public records request covers the records.
• Any required state notification or approval has been completed.
• Internal approvals have been obtained from the designated approver.
• The destruction method fits the sensitivity of the records.
• The destruction log entry is prepared and ready to complete.

Holds come first

A hold overrides the schedule. When litigation is reasonably anticipated, an audit begins, or a public records request is pending, records that may be relevant must be preserved even if their retention period has passed. Many states prohibit destroying records responsive to a pending request.

Make the hold process simple and fast:

• Counsel or the records officer issues a written hold notice identifying the records.
• Series owners and IT confirm they have paused any destruction or automatic deletion.
• The hold is logged.
• When counsel releases the hold in writing, the records return to their normal schedule.

Choose the right method

• Non-sensitive paper can usually be recycled.
• Paper with personal, financial, security, or confidential information should be shredded or destroyed by a vendor who provides a certificate of destruction. Keep those certificates.
• Electronic records should be deleted from every location where the record copy and its duplicates live, not just one folder.
• Retired computers, drives, phones, and other media should be sanitized or physically destroyed before disposal. NIST publishes guidance on media sanitization that IT staff can use as a reference.

Records that are not destroyed

Some series end in transfer, not destruction. Records with historical value may go to your state archives or another approved repository. Follow your state's transfer process, which often includes a form and an inventory. Log transfers the same way you log destruction.

Documentation that shows you followed the schedule

If anyone ever asks why a record no longer exists, your documentation is your answer. A short, consistent file of evidence protects both the organization and the staff who did the work.

Keep these documents together

• The current schedule, with evidence of adoption or approval (a resolution, a state approval letter, or whatever your state requires)
• Previous versions of the schedule, so you can show which rule applied at the time of a past destruction
• Your records management policy
• The inventory, updated as series change
• Destruction logs
• Certificates of destruction from vendors
• Transfer records for anything sent to an archive
• Hold notices and releases
• Training records, showing who was trained and when

What a destruction log entry should include

• Series title and local schedule reference
• State schedule item, if separate
• Date range of the records destroyed
• Volume (boxes, folders, or approximate electronic size)
• Retention period and trigger event applied
• Confirmation that holds and pending requests were checked
• Approvals obtained, with names, roles, and dates
• Method of destruction
• Date of destruction and who performed or witnessed it
• Reference to any certificate of destruction

Destruction logs are records too. Many states treat them as long-term or permanent records, so check your state's schedule for how long to keep them, and store them with the same care as any other important series.

Keep the schedule current

A schedule is accurate on the day you finish it and starts drifting soon after. Departments reorganize, new software arrives, programs start and end, and the state revises its schedules. A light, regular review keeps the drift small.

An annual review cycle

Pick a predictable time, such as after the fiscal year closes, and work through the same list every year:

1. Check for a new state schedule version and note any changes to periods, triggers, or approval rules.
2. Ask each liaison to confirm their series list, including new series, discontinued series, and changes in format or system.
3. Update owners and backups for any role changes.
4. Review open holds with counsel and confirm which remain active.
5. Plan the next destruction batch and set dates.
6. Refresh training for new staff and anyone whose duties have changed.
7. Save the updated schedule as a new version, keeping the old one.

Update between reviews when something changes

Do not wait for the annual review if any of these happen:

• A new software system is selected or an old one is retired
• A department starts a new program or takes on a new function
• A reorganization moves responsibilities between departments
• The state issues a revised schedule
• Counsel advises you of a legal change affecting retention

A short note to the records officer, followed by an update to the schedule, is usually all it takes.

Next steps

You do not have to finish this in a month. A steady pace works better than a burst of effort that stalls. Here is a practical way to begin:

• This week: Download the current state schedule from the official source, read its instructions, and confirm with your city attorney or state clerk association how your state expects local schedules to be adopted or approved.
• This month: Inventory the clerk's office, using the fields above, and draft the crosswalk for those series.
• Within the quarter: Name a records liaison in each department, adopt a short policy listing roles, and set up a hold notice process with counsel.
• Within the year: Complete inventories for every department, adopt or submit the full schedule, and run your first documented destruction batch.

As your archive of minutes, packets, and staff reports becomes better organized, it also becomes easier to search. Some offices pair a sound retention schedule with a tool such as Govera, which keeps each city's records isolated in its own database schema and audit logs every action, but the schedule, the holds, and every disposition decision remain staff responsibilities. Start with the state schedule and one department, and build from there.