Records creation is an established and recognized part of the Records and Information Management's (RIM) records life-cycle model. It is covered in RIM text-books and included in RIM course curricula at the Bachelor and Masters Degree levels. The Institute of Certified Records Management (ICRM) tests on records creation subject matter knowledge. RIM related standards (e.g. ISO 15489 - RM) include and depict the information creation portion of the information life-cycle. The content, context and structure of a record is emphasized - including and now especially as it relates to ERM.
As we all know, some highly regulated industries, such as securities and investment banking, regulators (such as the SEC and FINRA) dictate records that must be retained and maintained for specified amounts of time. Other regulators specify retention periods for records, implying creation. There are varying degrees of specificity related to required data within required records. Other records are not dictated by laws or regulation, but are determined to be needed for business purposes and are therefore created or received from third parties. The list of scenarios in this arena goes on.
Given the inclusion of records creation in RIM precepts and the documentation requirements of a firm's external and internal stakeholders, I've found it curious that - across many companies - the scope of many RIM programs (including ERM programs) - includes involvement in the records life-cycle only after records creation. The creation side is typically left to the businesses - often with legal and/or compliance review - but without the benefit of the important RIM perspective. In part the lack is budgetary - RIM programs are often under resourced and over-extended within their current roles. It is also a perceived discipline parameter issue.
Hence, the scope of some records and information management programs begins with the first life-cycle phase after creation - active records management. Other programs only begin true records management oversight during the inactive stage of the records life-cycle - related to offsite storage. There are yet other firms that concern themselves about records only at the point of potential disposition.
I propose a shift to include much greater focus on records creation and controls surrounding it by the RIM community. Why now? It is especially important now due to the increased need for demonstrable transparency.
Transparency has become a buzzword. Specifically, the pressure for business activities to be more transparent is growing. Having records that have sufficient content, structure and context (key precepts in RIM) can be a powerful tool to enhance transparency and, thus, reduce risk. I posit that there is a much greater likelihood that records will be sufficient (in this and other established key arenas related to trustworthiness) if there is input from RIM professionals - as part of an interdisciplinary team - with a records creation focus.
Hence, it behooves RIM (especially ERM) programs to help ensure that all needed records are present, that all needed information (including contextual information and metadata) is contained in and associated with these records, and that records are structured and managed with all controls (not covered here) that will ensure actual and perceived trustworthiness.
The development of ERM programs affords a new opportunity to focus on this important phase of the records life-cycle.
Regards until next time,
The opinions expressed here represent my own and not those of Bank of America (BAC) or AIIM
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