Lesson 4 — Document Control, Retention, Disposition & Legal Hold
Three control strengths
Custody Control — safest/lightest: store safely and ensure retrieval.
Revision Control — track versions/changes and notify stakeholders.
Formal Control — formal change initiation, impact analysis, authorized change decision, status accounting and validation.
Use the strongest control only when risk/evidentiary need justifies it. A regulated operating procedure may require Formal Control; a low-risk reference item may need only Custody.
Document hierarchy
A useful source hierarchy moves from:
Law / Regulation → Policy / Standard → Process / Procedure → Work Instruction → Record / Evidence
Each step becomes more operationally specific; records prove what actually happened.
Backup is not retention
Backup/recovery protects operational continuity after failure.
Record retention intentionally preserves evidence for defined business/legal/regulatory/fiscal periods.
A 30-day backup cycle does not satisfy a seven-year retention requirement.
Retention vs Disposition
Retention: how long information is normally kept.
Disposition: authorized action at the end of retention—destruction, transfer or another approved treatment.
Over-retention increases storage/management cost, search burden, protection scope and e-discovery exposure.
Legal Hold / Preservation
When litigation is pending or reasonably anticipated and relevant ESI is identified, ordinary destruction must be suspended for the relevant information.
Normal retention rule: “delete after three years.”
Changed fact: relevant email is under anticipated litigation.
New answer: preserve it under legal hold even after year three.
Retention and legal hold answer different questions: retention defines the normal lifecycle; hold is an exception/override for relevant material.
Source: pp. 295–306.