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Can you have different policies for record retention time?

Started by , Jan 21 2020 12:06 PM
9 Replies

We have a customer asking for a 3 year record retention and our current policy is 2 (shelf life plus 1 year) -- can we have two different policies? 

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I'd always go for the longer one.  So if your customer is asking for 3 years, I'd keep everything for 3 years.  If you're very paperwork based, some companies will scan these for you (at a cost) to save on storage space.  Alternatively it could be the push you need to go for electronic records.

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Certainly under BRC this is possible (Ver 8 section 3.3.2) as long as you define this & IFS (ver 6.1 clause 2.1.2) but the problem arises when you need to segregate what is relevant for a customer & what isn't....

 

eg. most UK companies I have worked at define record retention as 3 years, we then started working with a retailer who specified 5 years... and whilst we could have defined that in the policy, the difficulty would then have been separating the records for that customer & archiving those that were no longer relevant, so we decided to go for 5 years for all records, which has created a spectacular amount of stored records.

 

In summary - as long as you define this clearly & can show compliance - you can work to whatever system suits your company.

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Not suggested that you have 2 policies, will almost always cause an issue.

 

If your customer is big enough I'd make a blanket 3-year policy.

 

If not, I'd push back and tell them your standard policy is 2 years.

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It's completely up to you unless you accept it within customer specifications, then you have to. I'm not sure why you wouldn't save them for 3 years anyway. Once you handle them all one last time and archive them you're done with them unless you have to reference them for some reason. You'll have to archive them one way or another so unless you actually run out of room, you'll have to purge them too so the purge will just happen one year later.

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Thank you for the feedback and advice...greatly appreciated. 

We have a customer asking for a 3 year record retention and our current policy is 2 (shelf life plus 1 year) -- can we have two different policies? 

 

I suppose you could always define Policy as minimum 2 years and then internally adjust as appropriate ?

I think about the only way to keep a defined rule is to keep all records for 2 years unless a customer specifies a longer period of time. If it's written into your policy / procedure, you abide by it and can prove it and it doesn't create a food safety or quality risk I don't see how they could deduct for it?

We have a customer asking for a 3 year record retention and our current policy is 2 (shelf life plus 1 year) -- can we have two different policies? 

 

2nd alternative - modify the policy, eg (US/PMO) -
 

 

4. Record Retention a. All records, required by this Section, shall be retained at the milk plant, receiving station or transfer station for perishable or refrigerated products, for at least one (1) year after the date that such products were prepared, and in the case of frozen, preserved, or shelf-stable products, for two (2) years after the date that the products were prepared or the shelf-life of the product, whichever is greater, unless longer retention time is required by other regulations individual customers.

 

Certainly under BRC this is possible (Ver 8 section 3.3.2) as long as you define this & IFS (ver 6.1 clause 2.1.2) but the problem arises when you need to segregate what is relevant for a customer & what isn't....

 

eg. most UK companies I have worked at define record retention as 3 years, we then started working with a retailer who specified 5 years... and whilst we could have defined that in the policy, the difficulty would then have been separating the records for that customer & archiving those that were no longer relevant, so we decided to go for 5 years for all records, which has created a spectacular amount of stored records.

 

In summary - as long as you define this clearly & can show compliance - you can work to whatever system suits your company.

:thumbup:


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