How do we handle electronic records when an old system or application is being decommissioned?

Decommissioning a system is not the same as deleting its contents. The data inside often includes records that still carry retention, legal, or historical value. The goal is to ensure those records remain accessible, trustworthy, and complete long after the application is gone, while properly disposing of what no longer needs to be kept.

Start With Identification

Before anything is shut down, inventory what the system holds. Determine which content qualifies as a record versus transitory or duplicative data, and map each category to its retention schedule. Pay special attention to:

• Records under legal hold or litigation that must be preserved regardless of age
• Records with long or permanent retention
• Sensitive content (personal, confidential, or regulated information) requiring extra safeguards

If you cannot confidently classify something, treat it as a record until proven otherwise.

Preserve the Record, Not Just the Data

A complete electronic record includes its content, context, and structure. Plan to capture associated metadata, audit trails, and relationships, not only the raw files or database rows. Where possible, migrate records into stable, open, and well-documented formats so they remain readable when the originating software no longer exists. Verify that migrated records are accurate and complete through reconciliation counts, checksums, and sample review before retiring the source.

Choose a Destination

Records typically move to a successor system, a managed repository, or an archival storage environment that can enforce retention and protect integrity. Whatever the destination, confirm it can maintain authenticity, prevent unauthorized alteration, and support future search and retrieval, including for audits or public-records and FOIA requests.

Dispose Defensibly

Only after eligible records are safely preserved should the legacy system be wiped. Apply your retention schedule: destroy records that have met their retention and have no holds, and document that disposition. Ensure final disposal of the old environment includes secure sanitization of storage media so residual data is not recoverable.

Document the Whole Process

Keep a record of decisions, migration validation, and disposition approvals. This paper trail demonstrates that the transition was deliberate and defensible.

For related guidance, see the electronic records topic hub.