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Approaching Retention Schedules Without Getting Pricked

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**Views expressed in this blog are my personal views and not those of my employer. Any reference to any living person or organisation, past or present, is entirely co-incidental**

How do you approach the, sometimes, thorny subject of Retention Schedules?

This question, on the face of it, appears to be quite simplistic. I can hear you saying “we develop Retention Schedules to determine how long we should keep Records generated/processed/retained by ourselves”. However, different organisations adopt different methodologies in the construction of their schedules such as:-

1. Bucket style – select a limited number of categories and determine the appropriate Retention Period for the majority of Records (e.g., 80%). You can have an exceptions category to cover those Records which, within that category, require a longer or shorter Retention Period.
2. Detailed Schedule – develop a list of all Records generated/processed and/or retained across the organization. Review each line with the appropriate Legal expert and determine the appropriate Retention Period for each.
3. Detailed Schedule – develop a list of all Records generated/processed and/or retained for each department within the business. Review each line with the appropriate Legal expert and determine the appropriate Retention Period for each.

When determining the appropriate Retention Periods it is not just legal requirements which must be given consideration. The following should also be taken into account:-

1. Business requirements
2. Tax investigations
3. Regulatory requirements – including industry/subject specific requirements e.g. HIPPA, SEC, FSA etc.
4. Corporate laws/regulations

Equally important is consideration which must be given to jurisdictions for companies which operate on a multi national/global basis.  There are further decisions to be taken such as do you produce Retention Schedules for:-

1. Each country
2. Each region (e.g. Americas, Asia Pacific, EMEA)
3. Global

Further, do you simplify matters (thereby introducing some degree of efficiency) by adopting a common period across a country or region – for example all customer records across EMEA shall be kept for x years?

Having determined your approach in respect of the above you should carefully consider how the Retention Schedules should be published. Here are some suggestions-

1. Publish on your Intranet
2. Forward (schedule/link) to Risk Officers/Country Officers/Legal and Compliance Officers, Business Heads and COO’s
3. Group and 1-2-1 training of appropriate personnel
4. References within any intra-company Newsletters/other publications

References should be made to Retention Schedules in the Records Management Policy.

Above all Retention Schedules should be clear and concise. If not easily understood they will be ignored – at the company’s peril!

You will note I have not mentioned how Retention Requirements are built into systems containing electronic records – this discussion is for another day!

How does your company compile/distribute Retention Schedules?

Comments

Submitted by Mike Drolet June 09, 2010 - 2:02 PM

Its funny, when I took the position of Maine Department of Transportations "Director of Document Management" I was told to not worry about Records Management, that someone would be hired to fill that position later. So naturally, all the work I did over the last two years have been identifying and classifying the documents going into our electronic DM system with the intent of someday applying RM to it. Fast forward 2 years and I get asked to solve our RM problem (mainly that we don't have an active one, just a sort of carrying on with the old process of storing records with no purging at all going on).

Reviewing the older process left me wondering how MaineDOT ever managed RM in the first place and left no wonder why when the Records Manager who developed this system left, it all fell apart. It was a very detailed records identification and scheduling process, which grew so large that schedules began to overlap, individual types of document were found in multiple record schedules, similar record series with vastly different and seemingly arbitrary retention lengths existed, in essence . . . not something that could work without a watchful eye.

I pitched a simpler process for getting our RM back in line and married to our existing DM system. It involved "buckets" for managing retention lengths, and 7 specific records templates to cover 95% of all of our records with 2 additional templates to manage the remaining 5%.

Imagine my surprise when I began actively reading up on RM theories and learned that Buckets wasn't my unique take on the subject.

I'm still in the process of combing through all the detailed existing record schedules for our agency as well as understanding the "General Schedules" that exist for every Maine State Agency, but initial meetings with end users who have a direct stake in the various documents and records are very good. Almost hands down the "Bucket/Template" idea is quickly and easily understood and has the potential (if set up properly) to provide a consistent process that will far outlast any one person.

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Submitted by Roger Poole June 11, 2010 - 8:50 AM

Mike - great comment. You have "hit the nail on the head" so to speak! Using the Bucket approach is not always welcome by the theorists. However, the essence of a good Records Management Programme is that the tools (such as Retention Schedules) are easily understood. The business users like the bucket approach as it makes it easier for them to comply. Make it too comlicated and they will not play ball. Seems like you were born to be a Records Manager!

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This post and comment(s) reflect the personal perspectives of community members, and not necessarily those of their employers or of AIIM International