E-mail Retention Policy

[JWRB]

Hi everyone,

I'm curious what everyone else is doing for an e-mail retention policy.  We're looking to put an auto-deletion policy in place, but are having a hard time nailing down an appropriate set of parameters.  Seven years is where my mind instantly goes, but in light of cumbersome investigations and producing copious amounts of email, I'd love to trim that back if possible.  What is everyone else using and what are your thoughts on whatever you implemented/considered?

Thanks!

[Peter Gulia]

About records retention, there is no one uniform answer that is right for every service provider.

 

Here’s a list of some questions I ask when I design a TPA’s, recordkeeper’s, or similar service provider’s records-retention/destruction plan:

 

How often does it happen that a client’s question, worry, or request, or the business’ response, is in e-mail and is not fully described in other writings?

 

Does the business want to be ready to save a client from the client’s failure to keep a record it ought to have kept?

 

Does the business or an affiliate sometimes offer services as a § 3(16) administrator? a plan’s trustee? an investment manager?

 

Does the business or an affiliate sometimes offer banking services? insurance-agency services? securities broker-dealer services? commodities dealer services? investment-adviser services?

 

Has the business made any agreement with another service provider or a financial-services business?  Read each of those agreements to find records-retention obligations.

 

Does any record about a client ever get used in evaluating an employee’s job performance?

 

In how many States are the clients located?

 

Considering the business’ usual forms of service agreements, do they always, often, seldom, or never specify which State’s law governs the agreement?

 

Considering the business’ usual forms of service agreements, do they always, often, seldom, or never specify a time limit on claims against the service provider?

 

How often does the business face subpoena and other document-production demands?

 

Does the business charge a client expenses, fees, or both for a document production?

[ratherbereading]

The TPA for whom I work deletes after one year.

[david rigby]

Here's another question to add to Peter's excellent list:

Does the entity (whether TPA or plan sponsor/PA, etc) want to get the correct and/or best solution to its problem?

[BG5150]

On 6/18/2019 at 7:59 AM, CEB50 said:

The TPA for whom I work deletes after one year.

That seems extreme given the low cost of storage these days.  

Are those e-mails deleted or archived each year?

[ratherbereading]

On ‎6‎/‎21‎/‎2019 at 12:17 PM, BG5150 said:

That seems extreme given the low cost of storage these days.  

Are those e-mails deleted or archived each year?

They are automatically deleted. No archiving.

[david rigby]

39 minutes ago, CEB50 said:

The TPA for whom I work deletes after one year.

They are automatically deleted. No archiving.

Call me a cynic, but I'll bet many other TPAs would love to use this as ammunition to acquire your clients.

[BG5150]

46 minutes ago, CEB50 said:

They are automatically deleted. No archiving.

How do they handle paper files?  Do you print e-mails either to paper or pdf?

[ratherbereading]

3 hours ago, david rigby said:

Call me a cynic, but I'll bet many other TPAs would love to use this as ammunition to acquire your clients.

Lol won't happen. One of the best TPAs in the Northeast.

[ratherbereading]

2 hours ago, BG5150 said:

How do they handle paper files?  Do you print e-mails either to paper or pdf?

We are paperless.  Maybe I should clarify -- we  keep our emails in online folders - we use Sharepoint. So it's up to the administrators, staff, etc.,  to keep important emails.  They are deleted after 1 year from our Outlook - not our actual online files.  Although I'm sure even deleted ones could be retrieved.

2 hours ago, BG5150 said:

How do they handle paper files?  Do you print e-mails either to paper or pdf?