Records Retention Policy

Record Retention Policy

This Records Retention Policy promotes and assists with the implementation of procedures, best practices, and tools to promote consistent life cycle management of GitLab records

This Records Retention Policy promotes and assists with the implementation of procedures, best practices, and tools to promote consistent life cycle management of GitLab records. Because records contain important information, it is essential to take a systematic approach to the management of records.

1. Records Management

Records management addresses the life cycle of records, i.e., the period of time the records are in the possession of GitLab.

The life cycle usually consists of three stages: 1) Creation or receipt; 2) Maintenance or use; and 3) Destruction or retention. This policy is used in conjunction with the Records Retention and Disposal Standard. Records retention does not mean permanent retention. There are certain situations where documents must be preserved permanently, but most records need only be retained for a specified period of time. When the retention period for a particular record expires, we should destroy or delete the record. However, if we destroy or delete a record before its retention period expires, GitLab may be subject to penalties and sanctions. Unnecessary retention of records creates significant burdens for GitLab. For example, unnecessary records take up valuable storage space and make retrieval of needed records more difficult and costly. Consequently, GitLab recommends destruction of records after the retention period expires, except in those instances where GitLab directs otherwise (such as when a Litigation Hold is issued by the Legal Department). In other words, GitLab requires adherence to the records retention requirements and recommends the destruction of records according to the Retention Schedule.

2. The Difference between a “Record” and “Non-Record”

GitLab Records Retention Policy is based on a fundamental distinction between a “record” and a “non-record.” GitLab Records Retention Schedule applies only to “records.” Therefore, it is important to understand the difference between a “record” and a “non-record.”

2.1 What is a “record”?

A “record” is a Document created or received by a GitLab entity or individual in the transaction of business that contains significant business value. It is maintained to memorialize GitLab’s policies, procedures, functions, decisions, operations, processes or other business activities. The business value of a record is derived from the legal, regulatory, fiscal, operational, or informational significance of the content. “Records” must be retained throughout their life cycle in accordance with GitLab Records Retention Schedule. “Document” as used above is a piece of written, printed or electronic matter that provides information or evidence or otherwise serves as an official record and can include software application files, paper, slide presentations, spreadsheets, CAD drawings, electronic images, pictures, emails, faxes, and the like.

2.2 What is a “non-record”?

Simply stated, a “non-record” is everything that does not qualify as a “record.” Non-records are materials that GitLab does not own, materials without substantive business value, or materials that have only temporary use as reference or reminders. They are not subject to GitLab Records Retention Schedule and should be discarded when no longer needed. Examples of non-records include: Correspondence that is only needed for a short period of time and does not have substantive business value; Calendars; Informational items such as publications and extra copies of documents kept only for convenience or reference; personal or casual correspondence, Reminders and ticklers that are needed only for a short period of time and do not have substantive business value. This would include things like reminders, “post-it” notes or superseded drafts.