A file plan is a systematic classification scheme for an organization’s records, providing a structured framework for information governance. This roadmap lists the various record types maintained by an office, specifying storage location, and dictating retention and disposition instructions. A well-maintained file plan is the foundation for regulatory compliance and operational efficiency, ensuring records are managed consistently throughout their lifecycle. Because the business and regulatory landscape is constantly shifting, the file plan must be actively managed to maintain its accuracy.
Defining the Review Process: Review, Revalidation, and Update
The maintenance of a file plan involves three distinct, sequential actions that ensure the document remains accurate and legally defensible.
The first step is the Review, which is a thorough assessment of the file plan’s current effectiveness and alignment with existing business processes and legal requirements. During this phase, the records manager and department custodians examine whether records are being classified and managed according to the plan’s instructions.
The second action is Revalidation, which is the formal approval that the reviewed file plan remains compliant and fit for its intended purpose. This step provides organizational authority and sign-off, confirming that current retention periods and disposition rules satisfy all internal policies and external regulations.
The final action is the Update, which is the practical process of making necessary modifications based on the review and revalidation findings. This involves concrete changes, such as adding a new record series, modifying a retention period to align with a new law, or updating location details for a system migration. These three actions form a continuous cycle of governance.
The Standard Periodic Review Cycle
Industry best practice supports a routine, formalized schedule for file plan maintenance. The most common standard is an annual review, which helps ensure that changes in policies, procedures, or requirements are promptly incorporated. Organizations often use this annual cycle to conduct a comprehensive “records cleanup” and verify the accuracy of their record series inventory.
For organizations in highly regulated fields, such as finance or healthcare, an annual review cycle is typically required to manage the pace of regulatory change. This mitigates the risks of non-compliance and legal exposure. Less complex organizations or those with stable regulatory environments may adopt a biennial, or every-two-year, formal review cycle. Regardless of the chosen frequency, the schedule must be formalized in policy and consistently documented.
Organizational and Regulatory Triggers for Immediate Action
A file plan must also be managed reactively, as certain events trigger an immediate review and update outside of the standard periodic schedule.
One significant trigger is a change in the regulatory landscape, such as the introduction of new data privacy laws or updates to compliance requirements. New legislation can quickly render existing retention periods invalid, requiring an urgent revision to the plan’s disposition instructions.
Significant organizational restructuring also necessitates an immediate file plan update. Events like mergers, acquisitions, or the creation or dissolution of major departments change the ownership and location of records, requiring the plan to reflect the new corporate structure.
Major technological shifts, such as implementing a new Enterprise Content Management (ECM) system or a large-scale cloud migration, require the file plan to be reviewed. This ensures classification and access controls transfer correctly to the new environment. The introduction of a new business function that generates uncategorized records is another trigger, demanding the immediate creation of new record series and retention rules.
Essential Components to Verify During a File Plan Review
A thorough file plan review focuses on several operational and compliance elements to confirm the plan’s integrity and usability.
Classification Scheme Accuracy
This is a primary verification point, ensuring that new records are correctly mapped to the appropriate record series based on their function and content. This check prevents misfiling, which can lead to premature destruction or unauthorized retention.
Retention Schedule Compliance
Reviewers must confirm that the stated retention periods are still legally valid and that final disposition—whether destruction or archival—is being carried out as scheduled.
Legal Holds
A review must confirm the correct application of Legal Holds, which override any scheduled disposition to preserve records relevant to current or anticipated litigation. This ensures that no defensible information is inadvertently destroyed.
Access Controls and Security Tags
The review should assess these controls to confirm that permissions and security levels remain appropriate for the sensitivity of the records, preventing unauthorized access and data breaches.
Risks Associated with Neglecting File Plan Maintenance
Failing to maintain an accurate and current file plan introduces significant organizational risk.
Legal penalties and financial fines are a direct consequence of non-compliance with regulatory requirements, particularly when records are destroyed too early or retained too long. The inability to produce required records during an audit or investigation can lead to legal action and substantial monetary penalties.
Neglect also creates operational inefficiency, as employees waste time searching for misclassified or poorly organized documents. An outdated file plan increases e-discovery costs during litigation, as a larger, unmanaged volume of data must be searched and reviewed. Furthermore, an unmanaged file plan heightens the risk of data loss and unauthorized access, as security controls become obsolete over time.