This article originally appeared in the July/August, 2018 issue of Mailing Systems Technology.
Mailers are often perplexed regarding the issue of maintaining data for the mailings that they process. What type of data should you be keeping? How long should you keep it? Why do you need to keep this data? What is the best method for maintaining the data? How do you access this data in the future?
The United States Postal Service (USPS) does have some requirements regarding retention of documentation. These requirements are typically outlined in the Domestic Mail Manual (DMM). However, there may be additional data retention requirements included in agreements with the USPS, such as Optional Procedure Agreements, Negotiated Service Agreements, and Customer Supplier Agreements. The length of time designated for data retention in the DMM and these agreements can vary. It is also important to note that USPS Revenue Protection investigations are permitted to go back 13 months from the date of mailing to request payment of revenue deficiencies. For this reason, the general recommendation for data retention policies for USPS purposes is at least 13 months from the date of mailing.
Since mailings involve financial transactions, there are also accounting requirements to consider when determining data retention policies. Time periods vary based on the type of accounting records, but there are Generally Accepted Accounting Practices (GAAP) guidelines available to detail this information. Typically, each mailing company will have its own data retention policies for accounting records.
Likewise, some mailings may fall under legal agreements, or there may be contracts with clients or vendors that specify data retention requirements. Again, each mailing company may have its own legal data retention policies that cover mailing data.
What Data to Keep?
The issue of what specific data to maintain may also vary, depending on USPS agreements and company-specific accounting or legal policies. Typically, documents that provide proof of mailing, details of the preparation of the mailing, and the finalized postage amounts are the primary documents that need to be maintained. Specifically, this usually includes (but may not be limited to):
- Postage statements (e.g. 3600, 3602, 3541, etc.)
o postage statements (as published by the USPS on the usps.com website)or the PostalOne! dashboard format postage statements
- Mailing transaction receipts (3607 form)
- USPS qualification reports
- Sample mail pieces
There is some argument for retaining the Mail.dat files as part of this process, but these files may not be of much value beyond about 30 days after the mailing date. While the Mail.dat files do indeed contain all the details regarding a mailing, the issue in using this data is that it cannot be used at some point in the future to re-create the actual mailing. USPS mail preparation requirements frequently change, as does the Labeling List data. As such, attempting to re-create documentation of the actual mailing months or years after the mailing date using Mail.dat files is virtually impossible. Too many variables change in the interim period, so that any documents created using Mail.dat files after the actual mailing date most likely will not match the actual mailing. For this reason, it is best to retain the actual finalized documents from the mailing rather than counting on the ability to re-create these documents later.
How and Where to Keep the Data
PostalOne! retains mailing data for a period of 13 months after the mailing date, and mailers may access this data through the Business Customer Gateway. However, PostalOne! may not be accessible when these documents are needed, and there is no guarantee that the USPS will continue to retain this data. For this reason, we recommend that mailers download the finalized documents to their network systems on a regular basis, so that the data is locally resident behind your own firewalls and is included in your normal back-up and archiving processes. We also recommend that you implement robust back-up and archiving processes for this data, along with disaster recovery plans to ensure that the data is readily available when needed. At first blush this may all seem like overkill, but making the effort to put these policies and processes in place up front can save you time and money in the future. If there is a USPS revenue deficiency issued, a postal or accounting audit, or a legal dispute, you will be thankful that you took the time to ensure that the appropriate mailing data has been securely retained and easily accessed.
Jeff Peoples is founder & CEO, Window Book. He is a frequent industry writer and speaker at events such as the National Postal Forum.