Records Retention and Disposition - ISO 9001:2008 Requirements

[prady2581]

Hi All,
This is my first post. Specifically looking for below information. I searched through forum but was not able to get this info.
All our records are placed in Electronic. For some records the Retention time is never. For few of the records we have set period ex : 5 years, 6 years as per the requirement. Few of the records are saved at offsite for some years past their retention time.

I have below few queries.

1. Disposition Value should be "Never" where Retention period is "Never". (I mean requirement per se Am I correct stating this).

2. "Disposal" under Disposition is correct or it should reflect actual method of disposal. (From requirement perspective).

3. Is there any special requirement for records which are kept at offsite(Electronically archived or hard copy), like we have to maintain in the Master Matrix.

Thanks in advance for your inputs.

 

[John Broomfield]

Re: Records Retention and Dispostion - ISO 9001:2008 Requirements

prady,

One day an auditor may ask these questions of you and your management system.

Keeping records forever suggests to me a lack of thought about:

A. The usefulness of the records
B. The retrievability of the records
C. The process owner's engagement

So, determine how the records are used and consider the need for reviews of retrievability as technology evolves and work with the owners of the processes that generate and use the records to make your management system process-based and helpful to your colleagues.

Then you'll have your answer.

John

 

[somashekar]

Re: Records Retention and Dispostion - ISO 9001:2008 Requirements

Welcome and happy to have you in the COVE ~~~
For 1. Retention can be life time of product (if defined) or life time of organization. Hence a planned disposition is not applicable.
For 2. Delete, erase, burn or destroy could be better control of disposition.
For 3. Please cover same under storage control, ie. Where stored

 

[AndyN]

Re: Records Retention and Dispostion - ISO 9001:2008 Requirements

"Disposition" doesn't mean "disposal", so when something is moved from an active filing system to "archive", that's also a disposition. Yes, "disposing" of records - to trash, burn etc. is a disposition, but think of "disposition" as moving the records "from dis-position to dis-position"... (jk)

 

[RoxaneB]

Re: Records Retention and Dispostion - ISO 9001:2008 Requirements

I've never been fond of the Never/Always classification for record retention...it's the easy way out from actually having a discussion about the records in question. Let's face facts - space is finite. You do not have unlimited space - you may have MORE space if you acquire more memory for electronic records, but there is still a maximum amount available.

We addressed this situation by indicating MINIMUM retention times (not maximum) for some records and/or the caveat that read something like "...and until XX [insert suitable unit of memory] is reached."

As for your off-site storage, depending on the nature of your business (and the records), they could fall under the critical supplier classification and be subject to review for certain criteria such as steps taken to protect your records.

 

[Kronos147]

Re: Records Retention and Dispostion - ISO 9001:2008 Requirements

..some records the Retention time is never. For few of the records we have set period ex : 5 years, 6 years as per the requirement.

Welcome to the Cove.

-What requirement? Customer, internal, statutory/regulatory?
-How is the requirement stated in the context of your QMS (maybe a procedure for 4.2.3 doc control and 4.2.4 record control)?

Stating the Minimums, as proposed by RCBeyette, is spot on IMO. The QMS should say what the organization does, and the organization should then do that. Make sure it all meets all requirements.

In my experience, it is usually the customer requirement that drives it all. 10 years and Lifetime of product are common terms on the contract or customer terms and conditions.