What should we do if a record cannot be located when responding to a request or audit?

A record that cannot be found is not necessarily a lost record. It may be misfiled, stored under an unexpected name, held by another office, or already disposed of under an approved schedule. The goal is to conduct a reasonable, well-documented search and to handle the outcome transparently.

Conduct a Reasonable Search

Begin with a search that is thorough enough to be defensible if questioned later. Practical steps include:

• Identify every system, location, and format where the record could plausibly exist, including shared drives, email, content repositories, physical files, and offsite or archival storage.
• Search using multiple terms, dates, custodians, and alternate spellings, not just the original file name.
• Ask the staff or offices most likely to have created or handled the record.
• Check whether the record was transferred, lent, or migrated during a system change.

A search is generally considered “reasonable” when it is designed to locate records that are likely to exist, not when it guarantees a result.

Determine Why It Is Missing

Once searching is exhausted, establish the most likely explanation:

• It was destroyed under an approved retention schedule (this is lawful and should be documented).
• It never existed or was never captured as a record.
• It is genuinely lost, misplaced, or possibly destroyed outside of policy.

This distinction matters. Disposition under an authorized schedule is routine; unauthorized loss or destruction is a more serious matter that may carry legal and compliance consequences.

Document and Disclose

Whatever the outcome, record what you did. Note the systems searched, search terms used, people consulted, dates, and conclusions. In a request context, you generally must inform the requester that no responsive record was located after a reasonable search, rather than simply staying silent. In an audit, provide the same trail to the auditor.

If you suspect a record was destroyed improperly or is unaccounted for, escalate to your records officer, legal counsel, or compliance team promptly. Concealing a gap is far riskier than disclosing it.

Prevent the Next Gap

Recurring “missing record” events usually point to a process weakness: inconsistent filing, unclear ownership, gaps in capture, or schedules that are not followed. Treat each incident as a signal to tighten capture, indexing, and disposition controls.

For broader context on policies, retention, and accountability, see the information governance topic hub.