EvidenceSheet
HIPAA Security Rule · Policies and Procedures

164.316(b)(2)(i) Time Limit (Documentation Retention)

Retain the documentation required by paragraph (b)(1) of this section for 6 years from the date of its creation or the date when it last was in effect, whichever is later.

Source: HIPAA Security Rule, 164.316(b)(2)(i). The statement above is our statement of the clause, read from the published text and cited so you can check it against the official text, not the instrument verbatim. Open HIPAA Security Rule in the compliance library.

Applies to covered entities and business associates. An addressable specification can be met by a documented, reasonable alternative.

8
artefacts
2
held by a system
2
at each review
moderate
to go live
Backup / DR tooling
where the evidence lives
teal = a system already holds it · olive = produced at each review. To go live: easy when half or more of the artefacts are already held by a system, moderate from a quarter to a half, hard below a quarter.

These are the artefacts auditors commonly ask for on this requirement, our guidance rather than text from the standard. Your assessor decides what is sufficient in your context, and asks for samples across the period when a report covers one.

system holds itEvidence a system already holds

  • Storage and backup evidence for retained documentation · Backup / DR tooling
  • Audit trail demonstrating retention compliance · SIEM / log platform

periodic reviewEvidence produced at each review

  • Disposal records at end of retention period · Data governance / DLP tooling
  • Verification samples confirming retention adherence · Data governance / DLP tooling

governing documentDocuments that govern the control

  • Documentation retention schedule with 6-year minimum · Policy repository / GRC workspace
  • Records management system or procedure · Policy repository / GRC workspace
  • Legal hold procedures · Policy repository / GRC workspace
  • Procedure for retired policies showing date last in effect · Policy repository / GRC workspace

First move

Start with the 2 of 8 artefacts that already live in a system (Backup / DR tooling); keep the periodic reviews but log each one as a dated record with a named reviewer.

Common gaps auditors find

Do this for your whole sheet

Paste the rows you run your controls from and get this mapping for every control at once, with the periodic-review ones flagged and a first move per row. No account for the first run.

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164.316(b)(1) Documentation (Standard) · 164.316(b)(2)(ii) Availability (Documentation)