Assessment: Is retention needed?

Assessment: Is data retention needed?

Acquired practices: Review the agreement documentation or contract regarding what responsibility Mass General Brigham has for the transfer, maintenance, and access for that data. See Acquired practices - responsibility for legacy data for detailed information.

This assessment applies to all data from legacy systems, whether it is still housed in the legacy system or has been ported to an archiving application.

Should we port the data from the legacy system to an archiving application?

What kind of legacy data does the system have?

Types of data that must be retained for defined periods for policy and legal reasons:

Financial = GL: General Ledger or AP: Accounts payable
Revenue/Billing = B/AR: Billing/Accounts receivable
Payroll = Employee wages and salaries paid, employer payments for health insurance or similar benefits, payroll taxes paid by the employer, bonuses, commissions and similar employer expenses
Clinical = Medical record and ancillary data from labs, radiology, pharmacy, etc.
Audit = Records of every user access of protected health information (PHI), identifying the user, records accessed, and the date and time of access

What are the retention requirements for the legacy data in the system?

Contact the Mass General Brigham Office of General Counsel (OGC) to find out if there's a legal hold on the type of data in the legacy system. If there is, the data must be retained. If the answer is YES, skip to step 4.

Currently (November 2021) there is an enterprise-wide legal hold on all payroll & personnel records.

Last date of service for the legacy application = _____

Years passed since last date of service for the legacy application = _____

Retention period in years = _____ For detailed instructions, see Finding the retention period in the RRS.

Are years passed (2c) more than retention period (2d)?

Has the legacy system data already been archived?