Disposing of Electronic Records - Survey Redux

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Do organizations require pre-approval prior to destruction or deletion of records whose retention periods have expired and for which there are no legal or tax holds? Last December, we released a survey on the topic, and the response rate was two percent. Several blog readers  mentioned that the holiday season was probably not the best time to release a survey and suggested we try again ... which we did. Responses were about the same; however, we added a few new questions, so we have new data.

In general, the results were about the same for the both surveys. Nearly all respondents (96%) in both surveys had a pre-approval process for destruction of physical records stored off-site, and the majority (78-82%) had a pre-approval process for 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.

A pre-approval process for the deletion of electronic records was more likely to be applied to digital records stored on-site (73% in the 2nd survey), especially for high-volume repositories, than for digital records stored off-site or in the cloud (61% in the 2nd survey).

John Phillips proposed four new questions which generated an emerging practice for pre-approval of record destruction or deletion. We learned that among our respondents, RM does not usually have final responsibility for resolving issues and making the decision to follow the retention schedule. Rather, it is more likely to be the business unit owning the records or a collaboration with the business unit. RM is next most likely role to have final responsibility.

Q2  For physical records stored on-site, who has final responsibility for resolving issues and making the decision to follow the retention schedule?  (n = 44)

Q2 Business Unit/Owner 32%; RM 23%; Collaboration 20%;

Q4  For physical records stored off-site, who has final responsibility for resolving issues and making the decision to follow the retention schedule?  (n = 45)

Q4 Collaboration 33%; RM 22%

Q6  For electronic records stored on-site, who has primary responsibility for the pre-approval process?  (n = 46)

Q6 Collaboration/Business Unit/Owner 22%; RM 19%

Q8  For electronic records stored off-site and/or "in the cloud", who has primary responsibility for the pre-approval process?    (n = 37)

Q8 Collaboration 30%; RM/Business Unit/Owner 16%

These findings suggest that to make records disposition/deletion efficient and effective in enterprise content and records management systems, we need the ability to generate a workflow to enable a collaborative approval process. I checked with our SharePoint GimmalSoft Compliance Suite experts and learned that out-of-the-box (OOB) workflows have one disposition approval step. If organizations want to add more than one approval, they can modify the OOB workflows using SharePoint Designer.

 Survey Sample - This Zoomerang survey was emailed to approximately 2,200 contacts with "record," "information manager," "records officer," or "information officer" in their title. There were 49 responses (2%) to the first survey and 46 responses (2%) to the second survey.  Government agencies and oil and gas companies were the most frequent respondents and  represented one-third of the responses in both surveys.

 

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Comments

John Phillips

Automated workflows for RMS retention rule changes?

It seems that the data indicates that a retention action is more often than not the result of a collaborative decision. Unfortunately, most records management software (RMS) functionality does not incorporate a decision-making workflow that supports collaborative input into the final decision on retention or destruction actions. For this reason, documentation of this collaboration is typically non-existent in the actual RMS, requiring the creation of documentation external to the application. It may be good in some cases to incorporate an internal audit trail of this collaborative decision making into the RMS application in order to document the retention decision process. It could also be useful to incorporate a tiered approach to the final changes to the application’s retention rules with an automated workflow approval process. During this process collaborative input is first documented, then an initial rule change is made by an authorized individual, and finally the Records Management Administrator of the application implements the rule.
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Charles Booz

Automated Workflows

John,

I have often wondered why RMS, in its various manefestations (ERM,etc.) hasn't incorporated the features and capabilities of electronic workflow. However,I feel that in this ever more complex world that an "expert system" virtual records manager would be better suited to reduce the recordkeeping burden on organizations and their staff. I am surprised that a number of companies that have developed new solutions consistent with the Information Governance model have not taken advantage of these automated tools?

Thanks,

Chuck Booz
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Don Lueders, CRM, CDIA

Workflows in Record Management Solutions

John and Chuck,

If traditional Records Management Software vendors have been reluctant to include flexible workflow capabilities to their solutions, it has been because they assumed that functionality would be provided by whatever ECM solution it was paired with. It wasn’t that long ago that vendors were creating Records Management Applications (RMA) that were paired with much larger Enterprise Content Management (ECM) systems to create truly complete cradle-to-the-grave information management solutions. (I know this to be true because I used to work for one of those RMA vendors for a few years.) The assumption was that the larger ECM solution would include some level of out-of-the-box workflow functionality that could also be applied to items in the RMA records repository.

Now with all the consolidation that has taken place the notion of a stand-alone RMA practically doesn’t exist anymore, and we have a half-dozen or so big, enterprise solutions that manage the entire lifecycle of content. To my knowledge, all of these solutions provide some level of workflow functionality (though that level varies significantly from product to product). If the product your organization is using doesn’t allow for collaborative disposition approval out-of-the-box, it really shouldn’t require a tremendous amount of customization effort to develop a process that does.

Regards,
Don Lueders, CRM, CDIA
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John Phillips

Yes, But RM Docs Should Not Have to Reside in ECM Applications

Don,

I tend to agree with your assertion about IT and RM assuming ECM workflow would be available. However, it would seem that the creation of documentation about records and records retention related decisions should reside within the framework of the RMA, in order to promote more reliable overall records and system maintenance. It could be done by using ECM workflow tools, but it would just seem better (to me) if the records retention maintenance data/records resided within the RMA applications and related repository data.
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John Phillips

Some Automated Workflows Have to Be Part of Our Future

Chuck,

I agree about the need for automated tools to "reduce the recordkeeping burden on organizations and their staff". The volume of records simply overloads the human side of "accessioning" records as a primary part of the Information Life Cycle. For many purposes, we need a chain saw, not just an axe, to cut the records woodlot. However, human guidance is still needed to operate both high tech and low tech tools.
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Randy Moeller

Sorry i didn't see the survey in my inbox....

Many systems/databases have no retention or workflow capability and the pendulum is on the side of less customization to more out-of-the-box use to lower upgrade costs, etc. The IT group is building a small 'workflow' app for records lifecycle management that checks with business owner, legal and tax to ensure correct retention time is used and no holds exist. This is mainly for decommissioning systems vs. an annual review.

For annual review IT support teams execute a review process with the business owner who checks on any hold and if the retention time has changed. I am not involved nor can I be with 5,000 systems. Info on holds are posted on our retention schedule app website for the business owner to review and provide appropriate direction to IT.
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John Phillips

Re: " the pendulum"

Randy,

Re: " the pendulum is on the side of less customization to more out-of-the-box use to lower upgrade costs, etc."

That is why it might be a competitive advantage for a software vendor to offer documentation/audit trails of retention decisions and changes - out of the box.
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Randy Moeller

the pit too

Hi John - Agree but you and i will not see in our lifetime even 50% of all the 'software' types orgs use with real 'retention/records' managing in them. Sigh.

As IT has realized that they can show big savings to their clients by cutting down the PB to TB, they are jumping on the bandwagon. I hope this drives them to push for the addition of these managing tools.
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Chris Walker

I may be simple, but ...

If we assume that the retention / disposition schedule has been defined correctly and that records are filed as they are supposed to be, why on earth would you want to review what's due for destruction or accessioning? Credible RM tools have enough "brains" to know what's on a hold and what isn't, since those self same tools have been used to place the holds in the first place.
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Art Bellis

Your not simple, its like the emperor and his new clothes :)

Bravo Chris, I was waiting for someone to open the conversation to begin asking the WHY, question. Policy is created so it can express the decision of the company, there should be few exception to the policy. Legal holds is a valid reason for overriding policy but leaving the application of exception to such a broad audience to me makes little sense. Secondly, with the explosion of digital information it becomes impratical to ask every person for their approval, this is a throwback to the physical box management approval process. I think part of the reason the responses supported an appoval process is for the most part the respondant were records and information management folks. If you asked the same question to people responsible for infrastructure, storage and governance your reposnses might lean a little more in the other direction. One mans opinion.
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Randy Moeller

The only thing that's really human repeatable is screwing up....

All kidding aside, I wish it was that simple. Some companies operate with folks rotating roles every 24 months or so. Was there a legal hold??? Gee, I dunno. Not everything transitions well. That and retention times do change. Since most systems do not have real retention (laboratory, various SAP modules) a check is made at review time.

Vendors who manage your records will not make that decision (legal doesn't want them too either) as it puts them in a worse spot if an error was made vs. 'that's what they told us to do'. Goes back to why you have to sign a destruction batch report for those boxes.

Your outside counsel is very pleased to be able to show the batch report to opposing counsel or judge. Nope it doesn't come up with stuff destroyed at your desk, hard drive etc. There has always been two standards for records managed in a 'controlled' environment (off-site storage, system) vs. well you know (desk, hard drive). Blame the legal process and courts. For non-controlled stuff all i need to show is there is an annual process for record reviews (and holds) which is why records cannot be found.
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Chris Walker

Minimize Human Decision Making

Hi Randy

Yeah, I get your points. However, I'd still advocate for taking the human bit out and leaving it to the tools (assuming correct design / config) where possible. Hell, I'd even argue for doing a cost benefit on whether or not automating the decision is worthwhile in circumstances you've described, especially over the long term.

I think the truth of the matter is that as long as we rely on excessive human intervention to ensure compliance, we're not ensuring compliance. (I think I'll tweet that last bit.)
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Randy Moeller

I love mankind, its people I can't stand

Hi Chris,

Linus van Pelt boiled down most issues into a simple statement. I agree that it should be automated per correct design/config. That is the real hurt. It will be a while until those tools are included in most systems regardless of internal apps, cloud based, whatever.

Oh the dream world of apps with a link to a # (or many #), who cares what the # is or when it changes as the app just recalculates. Subpoenas just mean a flag and it doesn't matter how many show up, add a flag for each one. No flag, the # is met and automatically the disposal begins during the light use time of the app.

Sigh. Darn Linus. RM has tried to influence this and failed as IT with business support (saving $$ always gets support) needs to drive it to be more successful.
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Susan Cisco

Would the Results Be Different if We Surveyed IT Professionals?

Thanks to all for your comments! The results represent the RM perspective because the survey was sent to contacts with "record," "information manager," "records officer," or "information officer" in their title. If the survey were sent to IT professionals, I think the results would be different. Do you see value in repeating the survey with IT?

Susan Cisco
512-565-7021
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Chris Walker

It'd Be Interesting

I'm sure the results would be different, though I'm not certain how useful they'd be. You'd certainly have to target IT folks that are involved in information mgt, rather than those that are systems maintenance / development / support focused.
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