The purpose of this session is to provide you with the necessary tools for complying with the SECs document retention rules.

For further details on these requirements, please see:  Compliance Documentation from Trumpet

By default, when you save documents to Worldox, you are saving them to an "active" document repository.  Worldox has other repositories, one of which is the "Salvage Bin".  The Salvage Bin is similar to the Windows Recycle Bin.

Just as in the Windows Recycle Bin, you cannot manipulate documents when they are in the Salvage Bin repository, but you can restore them to the active repository.  The Salvage Bin repository is searchable as well.

The main difference between the Windows Recycle Bin and the Worldox Salvage Bin is that, by default, documents are purged from this repository after they have been in it for 90 days.  After 90 days, the documents are not recoverable.  For regulatory purposes, you may wish to utilize Salvage Bin Retention Rules to ensure that documents are retained for the requisite amount of time.  Should you wish to change the 90-day default purge default, please email your current Worldox VAR.

Your firm's Compliance Officer has been provided documentation on both SEC and FINRA requirements for electronic record keeping.  Here is this document for further reference:  http://www.trumpetinc.com/Downloads/dms/compliancefinra.PDF

By default, the Indexer software will purge the documents in the Worldox Salvage Bin after 90 days.  This may not meet your regulatory agencies' (FINRA or SEC) document retention qualifications.  For example, your regulatory agency may require keep certain documents for 6 years after a client has terminated.   If that's the case, you can set retention rules on the Salvage Bin.

• To add Salvage Bin Retention Rules, select "Salvage > Rules"

  

• To add a rule, select "Add Rules"

  

Set Salvage Retention Rules per Cabinet

You may wish to have a default rule per cabinet.  For example, all documents that have been moved to the Salvage Bin from the Client cabinet should be purged after 6 years.

• Select the cabinet for which you wish to set the rule

  

• If you wish the rule to apply to all clients, categories and document types, place an asterisk in each

  

• Under "Defer final purge from salvage" you are presented with three options:
  
  Select the appropriate time frame from the drop down arrows.  For example, in this example, you may wish to select "Deleted Plus 6 years"

  1. Created plus - this will purge documents from the Salvage Bin based on the date they were created plus the defined time frame
  2. Modified plus - this will purge documents from the Salvage Bin based on the date they were last modified plus the defined time frame
  3. Deleted plus - this will purge the documents from the Salvage Bin based on the date they were deleted (i.e., moved to the Salvage Bin) plus the defined time frame
     

     

• Select OK to complete the rule

Set Salvage Retention Rules per Field

You can also set the salvage retention rules per applicable field in Worldox.  For example, while you may wish to purge all client documents that have been moved to the Salvage Bin after 6 years, you may wish to purge others, like client agreements less frequently.  In this example, perhaps you wish to delete documents from the Salvage Bin after they have a modified date of greater than 12 years.

• Select the cabinet in which you wish to apply the rule

  

• Select the appropriate Category / Document Type combination

  

• Under "Defer final purge from salvage" you are presented with three options:
  
  Select the appropriate time frame from the drop down arrows.  For example, in this example, you may wish to select "Deleted Plus 10 years"

  1. Created plus - this will purge documents from the Salvage Bin based on the date they were created plus the defined time frame
  2. Modified plus - this will purge documents from the Salvage Bin based on the date they were last modified plus the defined time frame
  3. Deleted plus - this will purge the documents from the Salvage Bin based on the date they were deleted (i.e., moved to the Salvage Bin) plus the defined time frame
     

     

• Select "OK"

Worldox Professional & Cloud

There may be multiple salvage retention rules that apply to a particular document.  For example, the Financial Planning Agreements are certainly filed to the client cabinet, and are also filed under the category and document type combination of FinPlan\Agree.  So, you may be asking, which rule "wins" the retention?  The answer is the one that retains the document for the longest period of time.

Let's use the following scenario as an example:  You have a Financial Planning Agreement with the modified date of 3/16/2009.  You move this document to the Salvage Bin on 7/1/2013.

The Client cabinet retention rule says the document should be purged from the Salvage Bin after it has been "deleted" 6 years.  Thus, this purge date is 7/1/2019
The FinPlan\Agree retention rule says the document should be purged from the Salvage Bin 15 years after the modified date of the file.  This purge date is 3/16/2024

The document will not be purged from the Salvage Bin until 3/16/2024 because that rule retains the file the longest.

You can view the set expiration date on a document using a column header.  The specific column header is entitled "Retention > Expires"

This column will show the date the file would be purged from the Salvage Bin if it were deleted today.

You may need to edit certain Salvage Bin Retention Rules as your regulatory agencies provide you with new rules. 

To edit a retention rule:

• Select Salvage > Rules

  

• Highlight the rule you wish to edit, and select 'Edit Rules'

  

• Edit the rule accordingly, and select "OK"

IMPORTANT:  If you edit a rule so that documents require a shorter or longer retention period, documents already in the Salvage Bin will maintain the original retention rule dates.  These edits will only apply to documents moved to the Salvage Bin since the rule has been edited. 

Worldox allows you to perform an audit on the Salvage Bin Retention Rules at any point in time.

• To audit the Salvage Bin rules, navigate to "Salvage > Rules"

• Select the "Audit Trail" tab

• This will list the Salvage Bin Retention rules and all edits made to those rules.