How do we handle records found in an old system that is being decommissioned and were never put on a retention schedule?

Discovering content in a system that is about to be retired is one of the most common, and most stressful, moments in records work. The key principle is simple: the absence of a retention schedule does not give you permission to delete. Until you have appraised the content and applied an approved disposition, treat everything as a potential record.

Stop and Preserve First

Before any data migration or shutdown, place a hold on destruction. If the organization has active litigation, audits, investigations, or open public-records requests, a legal hold almost certainly already covers this material. Decommissioning should never be the de facto disposition decision.

Identify and Appraise

Survey what the system actually holds. You are trying to answer a few questions:

• What business functions and processes created this content?
• Does any of it duplicate records already managed elsewhere (the “system of record”)?
• Does it contain sensitive categories such as personal, financial, or otherwise protected information?

From there, appraise the value. Records fall roughly into three buckets: clearly temporary material whose value has lapsed, records that map to an existing retention category, and content that is genuinely unscheduled and may warrant a new schedule.

Schedule, Then Dispose

For records that match an existing category, apply that retention period. For truly unscheduled material, create or amend a schedule through your normal approval process before disposing of anything. In federal agencies, new schedules require NARA approval; in other settings, follow your governing authority. Document the appraisal rationale so the decision is defensible later.

Migrate What Must Be Kept

Anything with continuing value should be moved to a managed repository in a sustainable, open format, with its metadata and context preserved so the records remain findable, readable, and trustworthy after the source system is gone. Records lose meaning when separated from the information that explains who created them and why.

Document the Whole Process

Keep a clear record of what was found, what was kept, what was destroyed, and under what authority. This audit trail is your protection and demonstrates good-faith, defensible disposition.

For more on long-term care of migrated records, see the archives and preservation hub.