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Hi Dwight,
So when we think about this, I find it helpful to think in terms of similar normal records cases. 

So suppose we have a letter that's relevant to a business deal (Context "A"). And then later that letter becomes relevant to a second business deal (Context "B"). The result is that we have one record with multiple retentions (if you like this approach)  -- or two different records (if you like this approach).

When Context B's retention period comes up there's no problem: either Context A's retention period continues on that record (the first approach) or it really doesn't matter because we have two completely different records (A and B) with independent retention periods (the second approach). The point is that there's no problem with this kind of situation -- it happens all the time.

But it's the same with the "legal hold records". Suppose we have a letter that's part of Context A. But now the letter comes under legal hold -- and we call this legal hold Context B. When the legal hold (now Context B) is lifted, either Context A's retention period continues on that record (the first approach) or it really doesn't matter because we have two completely different records (A and B) with independent retention periods (the second approach)

So that's what happens when we lift a legal hold on a "legal hold record". And you uncovered an issue. If we want to do the "legal hold record" approach AND we want to use a separate repository for "legal hold records", THEN we can't use the "multiple holds on the same record" approach. (This is the first approach in each case above.) We must declare a new record for each "legal hold record". (This is the second approach in each case above.) But that's more common approach with garden-variety RM anyway -- most folks don't apply multiple retention periods to single records.

Thanks for the great question!
Rich

-----Original Message-----
From: Records Management Program [mailto:[log in to unmask]] On Behalf Of Dwight WALLIS
Sent: Tuesday, March 26, 2013 3:53 PM
To: [log in to unmask]
Subject: Re: Defining “Documents under Legal Hold” as Records?

Richard, how long do you keep the "legal hold" records in the separate repository if they are not under legal hold?

--
Dwight Wallis, CRM
Multnomah County Records Management & Distribution Services Manager
1620 SE 190th Avenue
Portland, OR 97233
ph: Records- (503)988-3741
ph: Distribution - (503)988-3533, x29131
cell: (503)260-2263
fax: (503)988-3754
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