Classify before calculating
Seven years is not one universal deletion date. Under the Act, transaction records run from creation, customer-provided transaction documents from receipt, CDD records from the end of the relationship or completion of the occasional transaction, and program records from when no longer relevant to compliance. Apply the provision for the record type. Do not use the upload date as a substitute for a different statutory event. Other obligations and relevant exceptions also need checking before records are destroyed.
- Transaction record
Creation of the record.
- Customer document
Receipt of the document.
- CDD record
End of relationship or completion of occasional transaction.
- Program record
When no longer relevant to compliance.
Different records use different starting events
Parallel relative timelines show the general seven-year periods under sections 107, 108, 111 and 116. Each starts at its own event; they are not sequential stages. Program records must also be retained from creation while relevant. Apply each provision’s scope, section 118 exemptions and section 119 other duties before disposal. The endpoint is not permission to delete.
Transaction record: Record made; +7 years. Check exceptions and other duties before disposal. Customer document: Document given; +7 years. Check exceptions and other duties before disposal. CDD record: Relationship ends or occasional transaction completed; +7 years. Check exceptions and other duties before disposal. Program record: No longer relevant to compliance; +7 years. Check exceptions and other duties before disposal.
Build an event-based register
A useful retention register names the record category, the governing rule, the event that starts the period and the evidence of that event. Separate an active customer relationship from an archived individual file. A customer can have several matters while the wider relationship continues. Record the basis for deciding that the relevant event occurred. If it is uncertain, resolve the uncertainty before setting a destruction date. This reduces the risk that automated housekeeping removes evidence merely because a file looks old.
Example: an old document in an active relationship
Imagine a business collected customer information several years ago and still provides services to that customer. A generic rule that deletes every file seven years after upload could remove records needed under the CDD retention rule. The practical fix is to classify the record and link it to the relevant relationship event. This example does not decide how every historical record must be retained. It shows why a file’s age and the applicable retention clock can point to different dates.
Control the disposal decision
Before disposal, check the category, trigger date and any other reason to preserve the record. Suggested controls include a review of proposed deletions, an authorised decision and evidence of secure disposal. Apply the same thinking to backups and supplier-held records, not only the visible working folder. When migrating systems, carry forward the event information rather than resetting everything to the migration date. Keep the retention schedule linked to current legal sources so that changes can be assessed without guessing which stored records are affected.
Treat mixed records carefully
One file may contain several categories of record with different triggers. Do not assume that the shortest period applies to the whole file. Identify what must remain and how separation can be performed safely. Where the record cannot be split reliably, seek an informed retention decision before automated disposal runs.