Disposing of Electronic Records - It's About Time

Susan Cisco

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Keywords: records management, disposition of electronic records, information lifecycle

By Susan Cisco, Director

December 19, 2011 - 7:20 PM

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When it comes to recordkeeping many organizations default to keeping everything, especially if the records are electronic. I'm noticing a shift in the discussion from the initial states in the information lifecycle (creation and retention) to the final state (disposition). Maybe we've reached the tipping point, and organizations are beginning to direct their attention to getting rid of electronic records whose retention periods will expire soon/have expired.

I conducted a brief survey (December 13-15) to explore current practices for disposing of records whose retention periods have been satisfied. Nearly all respondents (96%) had a pre-approval process for destruction of physical records stored off-site, and the majority (78%) applied a pre-approval process to physical records stored on-site.  The most frequent roles involved in pre-approval process for the destruction of physical records were RM, Legal, Tax, and the department that owns the records.

1. Does your company require pre-approval for destruction of physical records stored on-site?   (n = 49)

Yes

 

38 responses (78%)

2. Does your company require pre-approval for destruction of physical records stored off-site?  (n = 49)

Yes

 

47 responses (96%)
 

A pre-approval process for the deletion of electronic records was more likely to be applied to electronic records stored on-site (high-volume repositories were mentioned). For more than half of the respondents, a pre-approval process for electronic records stored off-site or in the cloud was not applicable.

4. Does your company require pre-approval for deletion of electronic records stored off-site?  (n = 49)

Not applicable

 

25 responses (51%)

5. Does your company require pre-approval for deletion of electronic records stored in the "cloud," for example, payroll and benefit information?  (n = 49)

Not applicable

 

31 Reponses (63%)
 
There was wide divergence of opinions on the need for a pre-approval process for disposing of electronic records -- from no pre-approval requirements to a controlled process consistently applied to physical and electronic records:
  • "We have not implemented controls over electronic records as of this time, but in approved documentation the same approvals will be required for electronic as we currently utilize in the paper world."
  • "There are policy requirements but no procedures or tools for managing electronic records. E-disposition is therefore in the hands of the process owners."
  • ”I would like to see movement towards non-approval process to streamline the destruction and keep things consistent." I'm assuming this respondent expects up-to-date and approved retention and disposition rules and controlled processes and that records are destroyed according to the rules and controlled processes sono further documentation of final disposition is necessary.

Survey Sample - This Zoomerang survey was sent to 2,218 contacts from Gimmal's database with "record," "information manager," "records officer," or "information officer" in their title. There were 49 responses (2%).  Government represented 25% of the respondents' industry, and 26% were in the energy industry.  Ten percent were employed in utilities and 10% in the manufacturing industry.

 

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Comments

John Phillips

Interesting Survey - Hard to Make Conclusions

Submitted by John Phillips January 04, 2012 - 1:29 PM

Susan,

The idea for the survey seems a good one – how comfortable are people with automating deletion of records?. Apparently, they are not very comfortable with the practice. However, the December time frame was probably not the best to get much attention. Many people, like myself, have the Holidays on their brain and feel they are already overtaxed for timely responses to much of anything.
I think you should redo the survey in a couple of months to get more than the 2% response. Anyway, it would be easy to use the results of such a survey to ask how realistic an attitude is that emails (considering the VOLUME) could ever be credibly accessioned and reviewed prior to destruction.
John
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Susan Cisco

John Phillip's Comments

Submitted by Susan Cisco January 05, 2012 - 2:49 PM

John,
Thanks for your comments. I think redoing the survey in the spring to encourage more participation is an excellent idea. Perhaps you can help me tweak the questions to better understand respondent attitudes on the efficacy of pre-approving content prior to disposition.
Susan
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Shelley Podolny

Data Disposition

Submitted by Shelley Podolny January 05, 2012 - 12:15 PM

The challenge is not so much the approval process, but rather the identification of electronic records that can be disposed of. Most companies have not applied retention schedule metadata to unstructured information and therefore can't be sure what to dispose of and when. This leads to an ongoing build-up of legacy data that is becoming more and more of a burden (and expense) for most companies. Such data will live forever unless some action is taken. Sifting through unstructured electronic information to identify what to keep for legal, regultory or business reasons seems overwhelming, but that's what needs to be done in order to delete the rest. The good news is that there are processes for doing this defensibly and cost-effectively and companies should be encouraged to explore such options. Once legacy data has been cleaned-up, methods for tagging data with retention requirements going forward can be applied so that such data build-up doesn't continue. At that point, responsible parties will feel more comfortable giving approval to delete unnecessary data.
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Susan Cisco

Shelley Podolny's Comments

Submitted by Susan Cisco January 05, 2012 - 3:12 PM

Shelley,
Thanks for reviewing the survey results. I loved your NYT Op Ed where you recommended "clean up the stockpiles of dead data that live around us, be wiser data consumers, text less and talk more." For those who missed it: http://tinyurl.com/6rgnwvh
Susan
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Tenley Kanwischer

Destruction Approvals

Submitted by Tenley Kanwischer January 24, 2012 - 12:36 PM

I would also like to see the survey redistributed. We are looking to simplify our destruction approvals for hard-copy records and shift to a few "governing bodies" in Law and Tax, who may give their blessing once a year to destroy. Our current process is to send many individual reports to attorneys and others, who may or may not have the time and/or past knowledge about the file(s) in the report. Rather, I'd like to have more confidence in trusting our retention schedule requirements and move away from the detailed granularity of approving specific files. As we move to destroying electronic records and "non-records", it will be even more important that we have a simplified, streamlined, automated process. I am curious about what others are doing to address this as well. Thanks.
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Susan Cisco

Redistribution of Survey

Submitted by Susan Cisco January 26, 2012 - 9:55 AM

Hi Tenley,

I'm willing to redistribute the survey. Would you be willing to review the questions before I redistribute? If yes, please forward your email address to susan.cisco@gimmal.com.

Thanks,
Susan
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Susan Cisco

Redistribution of Survey

Submitted by Susan Cisco January 26, 2012 - 9:55 AM

Hi Tenley,

I'm willing to redistribute the survey. Would you be willing to review the questions before I redistribute? If yes, please forward your email address to susan.cisco@gimmal.com.

Thanks,
Susan
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Meg Duncan

Purge guidelines

Submitted by Meg Duncan January 25, 2012 - 12:19 PM

I'd love to see an updated response. I agree with John Phillips, that December might not have been a good time. I'd like to know if anyone has developed any guidelines for the technologists who build the programs for unstructured and structured systems.
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Susan Cisco

Redistribution of Survey

Submitted by Susan Cisco January 26, 2012 - 9:56 AM

Hi Margaret,

I'm willing to redistribute the survey. Would you be willing to review the questions before I redistribute? If yes, please forward your email address to susan.cisco@gimmal.com.

Thanks,
Susan
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Ron Layel

Further reseach?

Submitted by Ron Layel February 07, 2012 - 5:18 PM

I agree with others that further reseach may be very useful on this general area of electronic records disposition. Maybe the questions could be broadened to gather info not just on the approval for destruction, but also on the practice of e-records disposition -- e.g. frequency, methods (auto or manual), and what are the drivers (storage space, legal risk, facilitating access, etc.)
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Susan Cisco

Survey Redux

Submitted by Susan Cisco February 08, 2012 - 4:06 PM

Ronald, I am redistributing the survey. If you would like to participate, please forward your email address to susan.cisco@gimmal.com
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Gordon Hoke

Planning for post-destruction

Submitted by Gordon Hoke March 15, 2012 - 3:43 PM

This is a valuable discussion. In planning for post-destruction storage, are there any industry standards (or even rules of thumb) to estimate the percentage of emails in a general email system that qualify as records?
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