What is the FIRST step required in establishing a records retention program?

Identifying storage locations is a secondary step that follows the initial records inventory, since you must first know what records exist before mapping where they are stored.

Classifying records by sensitivity is a subsequent step that depends on having a complete inventory of records first, making it impossible to classify records that have not yet been identified.

Identifying and inventorying all records is the foundational first step because you must know what records an organization possesses before you can determine their sensitivity, where they are stored, or how long they should be retained. Without a complete records inventory, any subsequent steps-such as classification or policy drafting-would be incomplete or inaccurate. This discovery phase ensures that the retention program applies comprehensively to all organizational records.

Drafting a records retention policy comes after records have been identified, inventoried, and classified, as the policy must be informed by the types and categories of records the organization holds.