LensReading which lens this session carries.

Records governance

Records Schedule and Legal Hold

Agent evidence is a record like any other. It has a class, a retention period, a legal basis, and a deletion rule. When a matter opens, a hold freezes the records in scope so nothing ages out while it is live, and discovery can be exported for the matter rather than for the whole estate.

Health

What is kept, for how long, and why

Retention classes by review state, the record volumes under each and the legal holds in force.

Records
8,080
In the evidence spine
Classes
8
Retention schedule entries
Frozen
2,834
Under an active legal hold
Free to age
5,246
Subject only to the schedule
Active holds
5
Open matters
Classes due review
6
Schedule review overdue

Retention schedule

Each class names its legal basis and its deletion rule, and carries a live record count

ClassCoversRetainBasisDeletion ruleJurisdictionsLive records
FIN-7Y
Review overdue
Financial assertion evidence
clearance · approval · posting · reconciliation
7yStatutory accounting retention in the majority of operating jurisdictions, aligned to the longest applicable period rather than the shortest.Deleted at seven years from the close of the reporting period, provided no legal hold is in force on the record or its unit.US UK DE SG AU
601
PROC-7Y
Review overdue
Supplier and contract evidence
clearance · approval · sanctions-check · award
7yContract limitation periods and public-sector supplier audit rights.Deleted at seven years from contract expiry, not from record creation.US UK DE SG AU BR
575
HR-6Y
Review overdue
Employment and people decisions
assessment · approval · people-decision · appeal
6yEmployment claim limitation periods, taken at the longest applicable across works-council jurisdictions.Deleted at six years from the end of the employment relationship. Personal identifiers pseudonymized at two years where the record is retained only for statistical monitoring.US UK DE FR SG
604
LEG-10Y
Legal and regulatory correspondence
opinion · filing · approval · disclosure
10yRegulatory inspection windows and the outer limitation period for corporate filings.Deleted at ten years. Never deleted while any related matter carries an open hold.US UK DE FR SG AU BR
562
CUST-5Y
Review overdue
Customer commitment and service evidence
commitment · clearance · credit · complaint
5yConsumer claim windows and revenue recognition audit trail.Deleted at five years from the last account activity.US UK DE SG AU
2,130
OPS-3Y
Review overdue
Operational routing and execution
routing · execution · notification
3yInternal operating requirement. No statutory driver, so the shortest defensible period is used deliberately.Deleted at three years. This is the only class where the estate deletes rather than retains by default.US UK DE FR SG AU BR
1,093
TECH-3Y
Technology change and access evidence
change · access-grant · access-removal · test-result
3ySecurity review and change audit requirement.Deleted at three years from the change closing.US UK DE SG AU
1,784
AI-10Y
Review overdue
Autonomous decision evidence
agent-decision · override · refusal · promotion
10yModel risk and AI regulation expectations on traceability of automated decisions, taken at the longest emerging requirement rather than the current minimum.Deleted at ten years. Never deleted where the decision affected a person and an appeal window may still open.US UK DE FR SG AU BR
707

Legal holds

A hold overrides the schedule. Nothing in scope is deleted while the matter is open.

HOLD-001activeRegulatory inquiry — cross-border payment routing

A regulator has asked how payments above the cross-border band were authorized in the two quarters before the materiality policy moved to v9. Deletion is suspended across the whole function rather than a narrower scope, because the inquiry has not yet named the lines it will examine.

Scope: function = All finance evidenceCustodian Group General CounselRequested by External counselPlaced 2026-07-15Review 2026-10-13
603
records in scope
HOLD-002activeEmployment claim — promotion decision

A claim has been filed alleging an automated screening step influenced a promotion outcome. Every people-decision record is held, including the records that show the decision was taken by a human, because those are the records that answer the claim.

Scope: function = All human resources evidenceCustodian Head of Employment LawRequested by Employment counselPlaced 2026-06-08Review 2026-09-06
607
records in scope
HOLD-003activeSupplier dispute — award challenge

An unsuccessful supplier has challenged an award on process grounds. The sanctions and beneficial ownership evidence is the material part of the record.

Scope: function = All procurement evidenceCustodian Head of Commercial LawRequested by Chief Procurement OfficerPlaced 2026-08-06Review 2026-11-04
578
records in scope
HOLD-004activeInternal investigation — expense approvals

A pattern of approvals just under a materiality threshold was flagged by the observe layer and is being examined. The hold covers the approving authority records as well as the transactions.

Scope: function = All administration evidenceCustodian Head of Internal InvestigationsRequested by Audit committeePlaced 2026-07-01Review 2026-09-29
534
records in scope
HOLD-005activeCustomer complaint escalation — service credits

A pattern of service credit refusals was raised with a consumer regulator. Held until the regulator confirms it will not open a formal matter.

Scope: function = All customer service evidenceCustodian Head of Consumer LawRequested by Chief Customer OfficerPlaced 2026-07-23Review 2026-10-21
511
records in scope
HOLD-006releasedClosed - reasoning model decision review

A defect report against the reasoning model raised the question of whether any judgment-grade decision taken under it needed reversal. Every record written under that model version was frozen while the committee worked through them. The committee closed the review without reversing a decision and the hold was released. The records remain, under their normal retention class.

Scope: model = Decisions taken under Reasoner Core 5.4Custodian Chief AI OfficerRequested by Model risk committeePlaced 2026-03-16Released 2026-05-22
0
records in scope

What a discovery export contains

Machine-readable, matter-scoped

The export returns every evidence record inside the hold scope with its full version stamp, the authority grant cited, the hash link to the record before it, and the chain verdict for each unit touched. It is a JSON file, so counsel can load it rather than read screenshots.

Scope is resolved from the hold itself. A function-scoped hold pulls that function; a period-scoped hold pulls the records written while a named model version was in force. That second case is the one that matters when a model is later found to have been wrong.

A per-unit auditor pack is available from the evidence spine as a document, in PDF and JSON.

Honest limits

What this schedule does not do yet

Nothing here actually deletes. The deletion rules are written and the counts are live, but no scheduled job enforces disposal, and no disposal certificate is produced. That is deliberate for a demonstration estate and should not be read as a working retention engine.

Holds are recorded and scoped, but placing one does not physically write-protect the underlying rows. A real deployment would enforce the freeze in the storage layer, not in the application.

Jurisdiction on a record is a single tag. Cross-border data residency and transfer rules are a much harder problem than one field can carry, and are not modeled.

Actions

What is waiting on a person

Retention only bites at the moment something is due to be destroyed. These are the decisions standing between the schedule and the delete.

Operations

What this desk is allowed to start

A surface that only reports is not operable. This is the work this page can set in motion, and the bound it runs into.

Trigger and bound

This desk can place a hold, release a hold and mark a class reviewed. It cannot destroy anything: the platform has no delete path for spine records, so a retention decision here is a written disposition, and the physical removal happens in the system of record. That gap is deliberate and it is also a limitation — the schedule is asserted here and enforced somewhere else.

Live observability

What the record shows right now

8,051 records sit under a retention class and 2,834 spine records carry a legal hold reference.

Current distribution

8,051 records

Inside the retain period5,21865%
Due for review2,83335%

Is policy and strategy coming to fruition

Whether the written intent is holding here

2,833 of 8,051 records are past their retain period with no disposition on the record.

Not holding on the record

The written rule is that data is kept for as long as the class says and no longer. In practice 35.2% of everything under a schedule has reached its date and is still held, because disposition needs a person and nothing here forces one. 6 legal holds are on the record, 5 of them active, and a hold correctly overrides the schedule — but a hold that is never re-certified quietly turns into indefinite retention, which is why re-certification is tracked as a queue above rather than assumed. Today every active hold is still inside its own review date.

Why an examiner asks for this first

Retention is where paper trails usually fail

Most agent programs can show what happened last week. Very few can show what happened two years ago, under a model version that has since been retired, with the policy text that was in force at the time. A records schedule that names the class, the basis and the period, plus a hold that can freeze a slice of it, is the difference between an evidence trail and a log file.