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.
8
artefacts
1
held by a system
1
at each review
hard
to go live
Policy repository / GRC workspace
where the evidence lives
teal = a system already holds it · olive = produced at each review
system holds itEvidence a system already holds
- 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
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
- Storage and backup evidence for retained documentation · Policy repository / GRC workspace
- Legal hold procedures · Policy repository / GRC workspace
- Procedure for retired policies showing date last in effect · Policy repository / GRC workspace
- Verification samples confirming retention adherence · Policy repository / GRC workspace
First move
Mostly documents and reviews. Pull the 1 system-held artefact from your SIEM / log platform on a schedule; put the documents under version control with an owner and review date, and log each review as a dated record with a named reviewer.
Common gaps auditors find
- Retention periods shorter than 6 years
- Retention applied from creation date only, ignoring last-in-effect rule
- Departed staff documentation lost
- Legal holds not honored
- Disposal undocumented
- Backup retention misaligned
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.
Build my evidence sheet164.316(b)(1) Documentation (Standard) · 164.316(b)(2)(ii) Availability (Documentation)