Category: Information Governance Principles

Records Management Policy

Also known as: Records Management Directive, Recordkeeping Policy

Simply put

A records management policy is a formal document that sets out an organization's rules and responsibilities for handling its records throughout their life. It typically states who is accountable, what must be done to create, keep, use, and eventually dispose of records, and how records should be protected from loss, damage, or unauthorized destruction. The specific content and requirements vary depending on the organization, its sector, and the jurisdiction in which it operates.

Formal definition

A records management policy is an authoritative instrument that establishes the principles, responsibilities, and requirements governing the management of an organization's records across their lifecycle. Such policies commonly address the creation, capture, maintenance, use, and disposition of records, including electronic records, and often set out requirements for protecting records against loss, destruction, or theft. They typically assign accountability to defined roles and may be supported by accompanying procedures and standards; scope, mandatory requirements, and disposition provisions differ according to organizational context, sector, and applicable legal and regulatory obligations, which vary by jurisdiction. Note that a records management policy is distinct from the operational records management program it authorizes and from broader information governance frameworks that may encompass privacy, security, risk, and information value beyond recordkeeping.

Why it matters

A records management policy provides the authoritative foundation on which an organization's recordkeeping practices rest. Without a formal policy, responsibilities for creating, maintaining, using, and disposing of records tend to be inconsistent or undocumented, which can expose an organization to loss of evidence, unauthorized or premature destruction, and difficulty demonstrating accountability. The policy is what converts general intentions about good recordkeeping into stated rules and assigned responsibilities that staff can be held to, and it typically anchors the more detailed procedures and standards that follow.

The importance of such a policy is reflected in its adoption across public sector bodies. Agencies including the U.S. Department of Health and Human Services, the Department of the Interior, and the Environmental Protection Agency maintain records management policies or directives that establish the principles, responsibilities, and requirements for managing their records, including electronic records. Institutions in other sectors take similar approaches; for example, some universities issue policies articulating employees' responsibilities to protect records against loss, destruction, or theft. These examples illustrate that a records management policy is commonly treated as a baseline governance instrument rather than an optional supplement.

Because mandatory requirements, disposition provisions, and scope depend on organizational context, sector, and applicable legal and regulatory obligations that vary by jurisdiction, the policy also serves as the point at which those external obligations are translated into internal expectations. It should not, however, be mistaken for the operational program it authorizes, nor for a broader information governance framework that may address privacy, security, risk, and information value beyond recordkeeping.

Who it's relevant to

Records managers and recordkeeping staff

Records managers rely on the policy as the authoritative mandate for the operational program they run. It defines the principles and requirements they are expected to implement across the record lifecycle and typically underpins the procedures and standards that govern day-to-day capture, maintenance, use, and disposition.

Information governance and compliance leads

For those responsible for broader governance and compliance, a records management policy is one component of an organization's control environment. It helps translate applicable legal and regulatory obligations, which vary by jurisdiction and sector, into stated internal requirements, while remaining distinct from wider information governance frameworks that also address privacy, security, risk, and information value.

Senior management and policy owners

Executives and policy owners are often the parties who authorize and take accountability for the policy. Because such policies commonly assign responsibilities to defined roles, leadership involvement matters for establishing the authority behind those assignments and for supporting protection of records against loss, destruction, or theft.

General staff and record creators

Employees across an organization are frequently subject to responsibilities set out in the policy, particularly obligations to handle and protect records appropriately in the course of their work. As some institutional policies illustrate, individual staff may be expected to safeguard records against loss, destruction, or theft when carrying out their duties.

Inside Records Management Policy

Scope and Objectives

A statement defining what the policy covers, including the types of records, business functions, systems, and organizational units to which it applies. It typically articulates the purpose of managing records as evidence of business activity and clarifies what falls outside the policy's boundaries, such as transitory information or personal materials not created in the course of business.

Roles and Responsibilities

An assignment of accountability for records management activities, often spanning senior sponsors, records managers, IT, and individual staff who create and capture records. This component usually clarifies who is responsible for classification, retention decisions, and disposition, though the specific structure depends on organizational size and governance arrangements.

Legislative and Regulatory Context

A description of the legal, regulatory, and standards framework the policy is designed to help the organization meet. Because statutory retention periods, freedom of information, and privacy obligations vary across jurisdictions and sectors, this section typically uses qualified language and points to the specific requirements applicable to the organization rather than presenting a single universal regime.

Records Lifecycle Controls

Provisions addressing the stages through which records pass, which may include creation, capture, classification, retention, disposition, transfer, and destruction. Well-drafted policies distinguish these stages, noting that retention is not the same as archiving and that disposition may result in transfer or permanent preservation rather than only destruction.

Retention and Disposition Framework

A reference to the rules or schedules that govern how long records are kept and what happens to them afterward. The policy usually establishes the authority for these decisions and may reference a separate retention schedule, while noting that specific periods depend on jurisdiction, sector, and organizational policy.

Record Properties and Standards

Statements about the qualities the organization expects records to maintain, often described in terms of authenticity, reliability, integrity, and usability. This component may reference relevant standards such as ISO 15489 or a management system approach along the lines of ISO 30301, describing their general purpose rather than citing specific clauses.

Compliance, Monitoring, and Review

Arrangements for assessing adherence to the policy and for reviewing and updating it over time. This typically includes how conformance is measured and how the policy responds to changes in legislation, technology, or business needs, with review cycles depending on organizational policy.

Common questions

Answers to the questions practitioners most commonly ask about Records Management Policy.

Is a records management policy the same as an information governance framework?

No. A records management policy typically addresses the control of records as evidence of activity across their lifecycle, including creation, capture, classification, retention, and disposition. An information governance framework is generally broader, spanning policy, risk, privacy, security, and the value of information across the organization. The records management policy often sits within, and contributes to, an information governance framework, but the two are not interchangeable. Treating them as identical can leave gaps in areas such as privacy or security that fall outside a records-focused policy's scope.

Does having a records management policy mean records will simply be destroyed once their retention period ends?

Not necessarily. Retention and disposition are distinct concepts, and disposition does not mean destruction alone. Depending on organizational policy and applicable requirements, disposition may involve secure destruction, transfer to another custodian, or permanent preservation, for example through archiving. A records management policy typically sets out how disposition decisions are made and authorized rather than mandating destruction. It is also worth noting that legal holds and other obligations, which vary by jurisdiction and sector, can suspend disposition regardless of any elapsed retention period.

Who should be responsible for developing and maintaining a records management policy?

Responsibility is often shared, though accountability typically rests with senior management or an assigned records management or information governance function. In many organizations, records managers draft and maintain the policy, while executive sponsorship provides authority and resources. Input from legal, compliance, IT, security, and business units is commonly sought to ensure the policy reflects operational realities and applicable obligations. The precise allocation of roles depends on organizational structure, size, and sector.

How often should a records management policy be reviewed?

Review frequency depends on organizational policy and the pace of change in the relevant legal, regulatory, and operational environment. Many organizations schedule periodic reviews and also trigger reviews when significant changes occur, such as new legislation, restructuring, changes in systems, or shifts in business activities. The aim is generally to keep the policy current and defensible rather than to meet a fixed universal interval, which does not exist.

What are the typical core components of a records management policy?

While specifics vary by organization, a records management policy often addresses purpose and scope, roles and responsibilities, and the treatment of records across their lifecycle, including creation, capture, classification, retention, and disposition. Policies frequently reference how authenticity, reliability, integrity, and usability of records are to be maintained, and how legal holds and applicable obligations are handled. What falls outside the policy, such as broader privacy or security matters covered elsewhere, is best stated explicitly to avoid ambiguity.

How can an organization support compliance with its records management policy?

Compliance is typically supported through a combination of clear procedures, training and awareness, defined responsibilities, and monitoring. Aligning the policy with recognized guidance and standards can help, though organizations should adapt any framework to their own jurisdiction, sector, and needs. Embedding recordkeeping controls into systems and workflows, and reviewing adherence over time, are common approaches. The effectiveness of these measures depends on organizational culture, resources, and sustained management support.

Common misconceptions

A records management policy and an information governance framework are the same thing.

They overlap but are distinct. A records management policy concerns the control of records as evidence of activity across their lifecycle, whereas information governance is a broader accountability framework spanning policy, risk, privacy, security, and value. A records management policy often sits within an information governance framework rather than being equivalent to it.

Disposition in a records management policy means destruction.

Disposition is broader than destruction. Depending on the record and its value, disposition may involve transfer to another custodian or permanent preservation rather than destruction. A policy typically treats destruction as only one possible disposition outcome.

The policy sets fixed retention periods that apply universally.

Retention requirements depend on jurisdiction, sector, and organizational policy, so a records management policy usually establishes the authority and principles for retention rather than a single set of periods that applies everywhere. Specific periods are often held in a separate retention schedule and stated in qualified terms.

Best practices

Define the policy's scope explicitly, stating which records, systems, and business functions it covers and noting what falls outside it, such as transitory information or drafts, so users can distinguish authoritative records from copies and non-records.

Assign clear roles and responsibilities for records management activities, identifying who is accountable for classification, retention, and disposition decisions in a way appropriate to the organization's size and governance.

Frame legislative, regulatory, and retention requirements in qualified language, acknowledging that obligations depend on jurisdiction and sector, and reference a maintained retention schedule rather than embedding specific periods in the policy text.

Distinguish the lifecycle stages clearly in the policy, keeping creation, capture, classification, retention, disposition, transfer, and destruction separate so that retention is not conflated with archiving nor disposition with destruction.

Articulate the record properties the organization expects to preserve, such as authenticity, reliability, integrity, and usability, and align the policy with relevant standards by describing their general purpose rather than citing unverified details.

Establish a defined review cycle and monitoring approach so the policy stays current with changes in legislation, technology, and business needs.