How do you write a records management policy from scratch, and what sections does a defensible policy need to include?

A records management policy is the foundational document that tells your organization what counts as a record, how long to keep it, and who is accountable. Writing one from scratch is less about wordsmithing and more about grounding each provision in law, business need, and evidence you can later defend. Start by surveying the legal and regulatory landscape that applies to your organization, inventorying the records you actually create, and identifying who owns each process.

Before You Draft

Three inputs make a policy defensible. First, an authority map: the statutes, regulations, and standards that govern your records. Second, a records inventory describing what you hold, in what systems, and in what formats. Third, executive sponsorship, because a policy without leadership backing is rarely followed.

Core Sections a Defensible Policy Needs

• Purpose and scope. State why the policy exists and which records, systems, people, and locations it covers, including email, messaging, and cloud content.
• Authority and references. Cite the laws, regulations, and standards the policy implements, so requirements trace to a source.
• Definitions. Define “record,” “non-record,” “official copy,” and related terms to remove ambiguity.
• Roles and responsibilities. Name accountable parties, from records officers to individual employees, and describe their duties.
• Recordkeeping requirements. Explain how records are captured, classified, stored, and made accessible across their lifecycle.
• Retention and disposition. Reference an approved retention schedule and the documented, authorized process for destruction or transfer. Defensible disposition is consistent, scheduled, and logged.
• Legal holds. Describe how routine disposition is suspended when litigation, audit, or investigation is reasonably anticipated.
• Privacy and security. Address protection of sensitive and personal information and access controls.
• Training and compliance. Specify required training, monitoring, and consequences for noncompliance.
• Review and version control. State how often the policy is reviewed and how revisions are approved and dated.

What Makes It Defensible

A policy is defensible when its rules are reasonable, consistently applied, and documented. Tie every retention period to a schedule, log disposition actions, and revisit the policy on a regular cycle as laws and systems change. Pair the policy with practical procedures so staff know not just the rule but how to follow it.

For broader context on government recordkeeping requirements, see the federal records hub.