There are two ways to create retention policies in Microsoft 365 – (a) by creating a label and publishing it as retention policy, or (b) creating a retention policy without a label. Both are created from the Information Governance section of the Compliance portal in Microsoft 365.
This post describes how the policies are created and applied, and the outcome for each.
Retention policy based on a label
Retention labels are created from the Labels tab of the Information Governance section in the Compliance portal.
Ideally, the name of the label would be based on a disposal class in a records retention schedule or records disposal authority. For the purpose of this post, the new label was named ‘Test One – Retain five years then delete‘.
Adding the details of the retention provided a quick visual clue to the retention details.
The label was configured to have a retention period of 5 years after the date modified after which the content could be deleted, with no disposition review. No record would be kept of what was deleted.
Alternatively, it would be possible to select the Disposition Review option. This option sends an alert to the account indicated so the records could be reviewed before disposal. However, keep in mind that if the trigger is left as ‘Date created’ or ‘Date modified’, records will be ready for disposition review based on those dates. It might be better to choose ‘Date applied’ instead so that a group of records could be reviewed at the same time – for example, in a SharePoint library.
Retention labels have no life unless they are published. This is achieved from the ‘Publish labels’ option in the same tab.
One or more labels can be published in a retention policy. This could be useful if the records disposal authority contained multiple labels for a single function.
As part of the publishing process, a decision has to be made to apply the policy to somewhere in Microsoft 365. In this case, the decision was made to apply it to a single SharePoint site because that site contained records that mapped to the retention label.
Finally, the new policy was given a name. In this case the policy had only one label so the policy had the same name as the label.
If the organisation’s records disposal authority/retention schedule had multiple retention classes mapped to a business function, the policy could be named after the function and include all the relevant classes created as labels.
All of these labels would appear in the drop down list from the Library Settings on every site where the policy was applied.
But even when it was published in this way and applied to a specific SharePoint site, the label does not do anything. The policy has to be applied to a document library in that site – but even then it wouldn’t do anything until the label was selected from a drop down list.
The screenshot below shows how the specific label is selected on the library and whether it should be applied to all existing items.
The label can now be seen in the ‘Retention Label’ column (when made visible in the view settings).
Anyone who uses the library to add and edit content (site members) will notice an obvious change if they try to delete anything, including from their synced document libraries in File Explorer.
They can’t.
There is, however, a workaround that end-users can use to delete documents with a label: (a) check the box next to the document, (b) open the information panel and (c) remove the label on individual documents.
Once the label is removed it no longer appears against the record.
The document can now be deleted. It will move to the Recycle Bin, from where it could be restored for up to 93 days if a mistake was made.
The lessons to be learned from this are that:
- It might be useful to make the library read only after the label is applied.
- The label should only be applied when the library became inactive, to allow people to get on with their work while it is still active.
If anyone was concerned about content being deleted from an active library, they could set an alert on the library.
In the meantime, for all the other records that retained their label, when the retention period ended the records in the library would be transferred to the Recycle Bin where they would sit for 93 days before complete and permanent deletion.
If no-one restored a document from the Recycle Bin, the content would be deleted, permanently, forever, without any record. The records managers might need to make a copy of the metadata for the documents to be deleted before they are deleted.
Alternatively, if they had selected the option for a ‘disposition review’ when the label was created, this would alert the records managers (and others) of the need to review the contents of the library.
Once everything had been deleted, all that will be left will be an empty library with no record of what used to be there.
Retention policy without a label
Non-label retention policies are created from the ‘Retention’ tab of the Information Governance portal.
For the purpose of this post, this label will be named ‘Label Two – Retain 5 years then destroy’.
This policy has the same retention period, trigger, and action as Label One – 5 years after date modified – and then the content could be deleted without any record of this being kept. [Note – yes the screenshot below shows 7 years].
As the policy was being created it was applied directly to a SharePoint site.
The policy could start working immediately.
Nobody, apart from the person who created and applied it knew it had been applied. It didn’t appear anywhere on the SharePoint site where it had been applied.
But, as part of the application process, it created a Preservation Hold (PH) library visible only to Admins, including the Site Collection Admins but not the Site Owners.
(Note – if end-users are allowed to create SharePoint sites, or Teams in MS Teams that also creates a SharePoint site, they are made Site Collection Admins by default and can accordingly see the Preservation Hold Library).
Anything that was deleted in advance of the retention policy expiry would be moved to the Preservation Hold library.
The PH library had a specific purpose – to ensure that everything on the site was retained until the end of the retention period.
It was not possible to restore any items from the Preservation Hold library. It was also not possible to ‘clear’ that library. If an administrator tried, they would be advised that ‘something went wrong’.
The only way to delete from the Preservation Hold library would be to remove the policy.
However, if a record was deleted it would be placed in the Recycle Bin for up to 93 days, from where it could be restored. If a record was restored in this way (from the Recycle Bin), the copy in the Preservation Hold library would remain.
For most people this type of policy was fine. They could (appear to) delete records, unaware that nothing was actually deleted if it were subject to a retention policy.
The same thing happened if a similar type of retention policy was applied to OneDrive accounts. End-users could ‘delete’, but nothing was actually deleted as long as the retention policy was active.
At the end of the retention period, the content that was subject to this policy was transferred to the Recycle Bin where it remained for 93 days. It would then be deleted, permanently, forever, without any record.
All that was left would be an empty library with no record of its previous content. The only clue would be in the ID or the ID part of the Document ID (if enabled). If anything new was added to the library, the next number in sequence would indicate how many records had previously been saved to that library.
Lessons to be learned
There are several lessons to be learned.
The first is that you need a plan to create and apply retention labels or retention policies to content across Microsoft 365. The configuration options and implications of each option need to be understood before they are applied.
You need to understand the difference between (a) a retention label published as a policy and applied to a SharePoint site and then a library on that site, and (b) a retention policy applied to an entire SharePoint site.
Retention labels can be mapped to retention schedule/disposal authority classes and then applied to specific libraries on SharePoint sites where the policy is applied. Accordingly, it may be useful to create document libraries that map to those classes, and only store content in those libraries that is covered by a single retention class.
If single SharePoint document libraries are used to store content that maps to different retention classes, then it will become very complicated to accurately map retention labels to content.
In many cases, it may be possible to apply a single non-label retention policy to a single SharePoint site or sites. For example, all project sites might have the same 7 year retention applied to all the content on the site as there may be no real need to apply policies to individual libraries.
Whatever you do, have a plan to act, document your settings, and keep it up to date.
And understand what happens at the end of the retention period. There is no back up.
Records about the world 
Hi Andrew, when you say :
“If single SharePoint document libraries are used to store content that maps to different retention classes, then it will become very complicated to accurately map retention labels to content.”,
have you evaluated to get some predefined folders for each retention class, at the root of the library, and set their respective retention label? (This will apply the label to all content inside the folder). Do you see any functionality issues using this method?
Good article!
Thanks Martin. There is always the possibility that document libraries may store content that is subject to different retention periods. This is partially why is it possible to auto-apply retention labels based on certain conditions.
My point was that, where document libraries are used as logical aggregations of records about the same subject or context, it makes sense to try to only store records about that subject or context in the same library (re-created annually as necessary, e.g., ‘Meetings 2020’) as it makes it easier to apply a single retention class to all the content in that library at the same time, especially when the retention is based on when the label is applied (e.g., when the library is no longer active), rather than during the life of the library.
Of course, in many cases, SharePoint document libraries may contain content on a range of subjects with different retention periods. The choice, then, in my view, is to (a) apply a single retention policy to the entire site, or (b) consider trying to apply retention labels at a granular level within document libraries which is what I think would get very complicated, whether you apply them to folders or documents. Currently, SharePoint allows end users with edit rights to remove a label (and delete the record) or choose another one.
In my personal opinion, label-based policies should primarily be used for aggregations of records in a (controlled) document library that is used to house records that ‘map’ to the retention class. Everything else (including in Exchange, MS Teams, ODfB) can be covered by non-label retention policies that keep everything for the longest period.
Andrew