3PL records that are kept
3PL add-on For: Administrator, Compliance manager Checked on 18.0.0.2.0, 18.0.1.0.0
Which records and files of the 3PL setup and of owner operations the software keeps for good, what happens when someone tries to delete or change them, and how a wrong record is set aside instead. The core rules for DSCSA records are on What is kept, and what can never be deleted or changed.
Background: records of owner stock (documents and files, ledger, holds, instructions, gate evidence and notifications) fall under the core's six-year retention and immutability rules, and nothing is deleted when an owner relationship ends. The modules follow the reading that six years is the period for the owners' own records, while FDA's proposed rule gives three or six years (FD&C Act § 582, record-keeping provisions; see Compliance background). The software doesn't set a retention period for these records: it keeps them. Your procedure decides how long your business keeps its records; this page only describes what the software does.
Which 3PL setup records and files are kept for good
Records
No user, whatever their rights, can delete these records: the ⚙ (Actions) menu offers no Delete, and an import or an integration that tries is refused. A record that is wrong or no longer needed is archived (the ⚙ (Actions) menu, Archive) and stays readable under the Archived filter.
| Record | Where | What can still change | Message when code tries to delete it |
|---|---|---|---|
| Owner profile | Inventory ‣ Rx Tracking ‣ Owners (in the 3PL ‣ Configuration section) | archived when the relationship ends; re-activated if it resumes | "Owner profiles are never deleted: archive the profile when the relationship ends." |
| Owner instruction | Inventory ‣ Rx Tracking ‣ Owner Instructions (in the 3PL ‣ Operations section) | nothing after it is recorded, except that an operation marks it used once | "Owner instructions are 3PL records: they are kept for good and never deleted." |
| Jurisdiction record | Inventory ‣ Rx Tracking ‣ Jurisdictions (in the 3PL ‣ Configuration section) | before verification, everything; once verified, only the source, notes, evidence and archiving | "Verified jurisdiction records are evidence and are never deleted (STATES): archive them instead." |
| FDA annual report record | Inventory ‣ Rx Tracking ‣ FDA Annual Reports (in the 3PL ‣ Configuration section) | a submitted report can't go back to draft; archive a wrong one | "Submitted FDA annual reports are evidence and are never deleted (REPORTS): archive them instead." |
| Facility event | Inventory ‣ Rx Tracking ‣ Facility Events (in the 3PL ‣ Configuration section) | archive a wrong one | "Facility events are evidence and are never deleted: archive a wrong one instead." |
| Gate log row | Inventory ‣ Rx Tracking ‣ Gate Log (in the 3PL ‣ Reports section) | nothing: rows are written by the checks only | "The gate log is a record of checks made: its rows are never deleted." |
Facility licenses are licenses: a verified license is kept as verification evidence under the core rule (Renew, correct or retire a verified license). The records that owner operations create are in the next table.
When an owner relationship ends, nothing is deleted: the profile is archived, and the owner's documents, histories and reports stay.
Operational records
The records that owner operations create. None of them has Delete in the screens, except a draft owner order. For users, imports and integrations, the access rights refuse first, whatever the user's rights: "You are not allowed to delete 'RECORD-TYPE' (…) records." and "No group currently allows this operation."; the table gives the message the software's own code meets, as in the table above.
| Record | Where to find it | What can still change | Message when code tries to delete it | Procedure |
|---|---|---|---|---|
| Owner document (inbound or outbound, in the owner's name) | Inventory ‣ Rx Tracking ‣ Owner Documents (in the 3PL ‣ Reports section) | as any DSCSA document: after posting, only the chatter, the legal hold and the off-site archive fields. Keep At Least Until, the legal hold and the off-site archive work as for your own documents; the archive puts owner documents under the company's prefix, with no folder per owner | the core rule for DSCSA documents (What is kept) | Find the DSCSA documents issued in an owner's name or received for it |
| Owner notice | Inventory ‣ Rx Tracking ‣ Owner Notices (in the 3PL ‣ Operations section) | nothing; an unsent notice can still be sent, which fills its delivery fields. A change is refused with "Owner notices are records of what we told the owner: they can't be changed. Refused change of: FIELDS." | "Owner notices are 3PL records: they are kept for good and never deleted." | Read and send owner notices |
| Owner hold | Inventory ‣ Rx Tracking ‣ Owner Holds (in the 3PL ‣ Operations section) | only through its hold and release actions; any other change is refused with "Owner holds change only through their hold and release actions. Refused change of: FIELDS." | "Owner holds are DSCSA records of the owner's stock: they are kept for good and never deleted." | Follow an owner hold placed by an owner receipt |
| Title transfer | Inventory ‣ Rx Tracking ‣ Title Transfers (in the 3PL ‣ Operations section) | everything while it is open; once done or cancelled nothing ("TRANSFER is STATE: it can't be changed any more."), except that an Rx Tracking Manager may link the customer invoice of a done transfer | "TRANSFER is part of the DSCSA record and can't be deleted." | Buy an owner's units in place |
| Owner order | Inventory ‣ Rx Tracking ‣ Owner Orders (in the 3PL ‣ Operations section) | a draft, everything. Once confirmed, its owner, parties, lines and instruction can't change ("ORDER is confirmed: its owner, parties, lines and instruction can't change. Cancel it and record a new order."); its references can change until it is done | "ORDER was confirmed: it is kept as a record of the owner's order (cancel it instead)." A draft can be deleted (the ⚙ (Actions) menu, Delete); a confirmed order meets this message there too | Record an owner order |
| Owner export | Inventory ‣ Rx Tracking ‣ Owner Exports (in the 3PL ‣ Reports section) | a draft, its owner, period and note; once generated, nothing ("Generated owner exports are records that must be kept; they can't be changed.") | "Generated owner exports are records that must be kept; they can't be deleted." | Export everything we keep about one owner as one zip |
| Supplier EPCIS file of an owner receipt (also a custody or late file, and a file the owner uploaded on the portal) | Inventory ‣ Rx Tracking ‣ Supplier EPCIS Files | its state, as the receipt goes on; the file itself never | "Supplier EPCIS files are kept as a record of what the supplier sent; cancel the import instead." | Attach the supplier's EPCIS file to an owner receipt |
| Receiving discrepancy of an owner receipt, with the supplier's data or the owner's confirmation recorded on it | Inventory ‣ Rx Tracking ‣ Receiving Discrepancies | its resolution (Mark Resolved, Reopen); the recorded evidence files never | "Receiving discrepancies are part of the DSCSA record and can't be deleted; resolve them." | Release a data-pending hold with the owner's confirmation |
| Gate log row | Inventory ‣ Rx Tracking ‣ Gate Log (in the 3PL ‣ Reports section) | nothing ("The gate log is a record of checks made: its rows can't be changed.") | "The gate log is a record of checks made: its rows are never deleted." | Review the gate log |
The owner's packages and their history follow the core rules for the package ledger (What is kept). To hand an owner, or an inspector, everything kept about one owner, use the owner export (Export everything we keep about one owner as one zip; what it holds: Owner exports).
Files
Every file attached to one of these records is kept for good: it can't be deleted, and its content, name and owner record can't change, for any user:
- the evidence of a jurisdiction record, an FDA annual report record or a facility event;
- the files of an owner instruction;
- the CSV exports of the gate log;
- the files of an owner notice;
- the files of a title transfer, among them the Transaction Statement evidence recorded on it;
- the zip of an owner export;
- the supplier EPCIS file of every owner receipt import (also custody files, late files and the owner's portal uploads);
- on a receiving discrepancy of type Supplier Data Pending, once the supplier's data or the owner's confirmation is recorded: the supplier's transaction statement document, the owner's confirmation files and any file attached to the discrepancy;
- on an owner profile, only the owner's written authorization (Authorization Evidence). The profile's other files, such as its agreement files and files posted in its chatter, are ordinary files.
Trying to delete such a file, for example from the chatter's attachment list, shows an Invalid Operation dialog:
These files are DSCSA records that must be kept; they can't be deleted:
- FILE-NAME: evidence of MODEL RECORD, kept for good
For example: "- ny-3pl-rule-lookup.pdf: evidence of DSCSA Jurisdiction (3PL Licensing) New York (US), kept for good". The file of an owner receipt import is named "supplier EPCIS file NAME of an owner receipt (OWNER), kept for good", and the evidence on a discrepancy "evidence of the supplier's data or the owner's confirmation for discrepancy NAME". Changing such a file's content or name starts with "These files are DSCSA records that must be kept; their content, name and owner can't change:". What to do: see Error: "… can't be changed" or "… can't be deleted" on a kept record.
A file uploaded by mistake stays attached. Where the record has a chatter (jurisdictions, FDA annual reports, facility events, owner profiles), log a note there saying which file is the right one; an owner instruction has none (known issue PF-A05-05, on Record owner instructions).