Traceability and compliance
When what you must keep changes
A new obligation, a new criterion or a client demanding more: what to do with everything already filed.
Every so often something changes: a new obligation, a client tightening requirements, or you yourselves deciding to ask for more. The question that always appears is the same and is rarely answered well: what do we do with everything from before?
The three possible answers, and when each applies
| Answer | When it makes sense | Risk |
|---|---|---|
| Forward only | When the change is yours and there is no retroactive duty | Living with two criteria for a while |
| Forward and at renewal | The usual: everyone catches up when their turn comes | Taking a full cycle to be complete |
| Everything, now | When there is a real deadline or a client auditing soon | The most expensive and the most resisted |
Important
The second works in most cases and is the least considered, because it sounds like half-measures. It is not: **using the renewal you already run turns a project into a routine**. Asking a supplier for a new document while you are already asking for their annual renewal costs nothing; asking separately, in May, costs a whole campaign.
What to decide before starting
- 1
Whether the change affects what is done or only what is new
A new requirement is not the same as a different criterion for judging the same thing.
- 2
From what date it applies, written down
It is what later explains why two files from the same year look different.
- 3
What happens to what no longer complies
Flagged, re-requested, accepted as is? Decided once, not case by case.
- 4
And who owns the transition
By name, or it stalls in month two.
Watch out
The mistake that causes most trouble is applying the new criterion backwards **without leaving a trace that it changed**. If a year from now someone looks at a three-year-old file and sees something missing that was not required then, the natural conclusion is that you skipped it. Recording from when each criterion applies is not bureaucracy: it is what stops your own archive accusing you.
What can almost always be reused
That third costs the least effort and covers the most ground: if every time someone opens an old file they leave it at the current criterion, the archive catches up by itself within months.
Worth knowing
If the change comes from an obligation rather than your own criteria, **its scope and start date are a question for your adviser**: some changes look only forward and some do not. What is described here is how to organise the transition once you know which case is yours.
›Do closed files have to be redone?
Absent an express duty, no: what is closed is judged by the criteria of its time.
›What if a client demands the new criterion for old material?
That is a negotiation, not an obligation: quantify what it involves before agreeing.
›Should suppliers be told about the change?
Yes, and in the renewal request itself: it lands better than a separate email.
A real case
The situation
A company decides to require a new document from all its suppliers.
What you do
- Adds it to onboarding and the annual renewal instead of launching a separate campaign
- Records the date it applies from
What you get
Within one cycle it is complete, with no extra campaigns and without the old archive looking deficient.
The situation
What must be kept changes and nobody reviews the old material.
What you do
- Reviews which files are affected
What you get
The change reaches what already existed.
The situation
The new criterion is applied only to new material.
What you do
- Decides what happens to the earlier material
What you get
The archive is coherent.
The situation
Nobody knows from when the new criterion applies.
What you do
- Records the date of the change
What you get
You can say which criterion applied when.
The situation
A client asks why their file holds less.
What you do
- Checks which criterion applied then
What you get
The difference is explained.
The situation
The change is communicated verbally.
What you do
- Keeps the criterion written and accessible
What you get
The team applies the same thing.
This article answers
- the rules changed what about old records
- applying a new criterion to filed documents
- they now require documentation we did not keep
- reviewing the archive after a requirements change