Electronic Record Disposition; The RM Perspective

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Most RM professionals expect to apply the same collaborative pre-approval workflow used for disposing of boxes of physical records stored off-site to electronic records according to recent Gimmal surveys and conference calls with RM professionals. The most frequent reason given for needing the pre-approval process is to check for pending or threatened litigation, audits, or open records requests which could require attention from multiple stakeholders, especially legal.

Among those with experience applying the pre-approval approach to electronic records, there were mixed results: "We tried a pre-approval process tied to the record's author and provided quarterly reports and notifications when records were eligible for destruction. If the records needed to be retained longer, record authors were asked to check a box. If they didn't check the box, the records would be destroyed. This was very cumbersome because people leave the organization or move to new positions. Many were unwilling/unable to make a decision. We have discontinued the process for now and are trying to come up with a streamlined, consistent, and automated approach for disposing of both electronic and physical records."

Though in the minority, there are strong voices among RM professionals who think applying the paper process to electronic records won't work: "I believe that our profession will have to come to terms with the fact that we can't exert controls over the entire electronic environment. To think we can do so is delusional."

Is a risk-based approach possible in which organizations focus on records that expose them to the greatest risk and apply controls accordingly? We're planning a more extensive analysis of the survey and conference call data including business (use) cases in a white paper on electronic record disposition. Your comments and suggestions are encouraged. 

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Comments

Chris Walker

I'm Concerned

I find it a bit surprising that RM pros who think that a paper approach won't work with electronic records are in the minority. We all know that paper isn't going anywhere soon, but the growth rate of electronic records is faster than that of paper records.

The majority is going to have to wake up, soon.
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Randy Moeller

Lowering walls, building trust

There are three groups that often prevent auto destruction, IT, business owner and Legal. You can toss in the skittish RIM folks if you like. It may be based on a fear factor but also the limitation of the system in managing retention, holds (tax or legal), and the issue of knowledge transfer as folks rotate out of roles that touch the system and decision process.

When looking at the diverse landscape of systems (scientific instrument test data, procurement, payment, manufacturing line data or electronic batch record, etc.), most do not manage retention or holds so you are left with little choice but to create a review and disposal process. Even some of the ECM systems have an issue with multiple holds forcing some tracking process or again a review and disposal process.

Even if you have a system that can manage retention well (including recalculation when the time changes) and multiple holds (two litigations and a tax hold anyone?) you will still have to rely on the information being known so the process of adding/removing/changing can take place without error. That relies on the weakest link, humans.

It's up to the humans to do the adding/removing/changing. The less perfect a system, the larger the process to band-aid the issue. In companies where a large part of the population rotates to new roles every 24 months, continuity becomes an issue with documentation and knowledge. Things just wind up being a little grayer than we like.
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Carl Weise

Electronic Record Disposition; The RM Perspective

Susan, I appreciate your blog and enjoy discussing this topic.

It has always appeared somewhat strange that we want to make this extra effort to reexamine the records at the time that they are to have no value 3-years, 10-years or 30-years later and they are about to be destroyed.

I have written in previous blogs that the record owners, knowing that they could review the records and, perhaps, prevent the destruction of the records, at a later time, would not give serious consideration, up front, when we were making the initial retention decisions. It was almost like they would allow the records management professionals do whatever they wanted, knowing that at a later time, the record owners could override that decision.

Clearly, there is an important theme that runs through the management of electronic records and that is that we now need a partnership between legal, business leaders, records management and IT. With this arrangement, there is the need for active, real-time communications between the groups. If one of these groups learns of new information about the records, this should be passed on in a timely manner to the others, particularly, the records management staff. For us to be successful, this will need to be achieved. The partners in this effort should be held accountable for the prompt dissemination of any new information. From this, there should not be any new and urgent situations that should surprise us as the records are about to be destroyed.
We are taught that the records and information belong to the organization and it is the records management professionals who act as the custodians of that content. We have the responsibility for managing the records and destroying them at the approved times and we have the ECM/ERM systems to carry this out.

In her blog, Susan points out that pre-approval of the destruction of electronic records can be hindered by practical issues, as well.

Change can be difficult for all of us. Some may say that we have always done it this way with pre-approval of destruction. As Susan points out, it may be time to reconsider. This pre-approval process may also have been used to reduce the risk that records management professionals may make mistakes in the destruction of some records.

We need to build this environment of common concern for the information assets of our organizations. There needs to be this partnership of appreciation for the importance of records. Any new circumstances with the records should be communicated up front and the records management professionals have to ensure that their controls and systems carryout the appropriate destruction of the organization’s records.

Tell us about how you are growing this partnership within your organization.

What are your thoughts? Do you believe that we can have a partnership with active and real-time communications to protect and manage the records within our organizations?

I will see you at the following events:
• April 24th – 27th, ERM Master class in Amsterdam, NL
• May 8th – 11th, ERM Master class in Silver Spring, MD

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Richmond Bubuama

Electronic Record Disposition; The RM Perspective

I share with the comments by Carl. It is a great challenge for us RM professionals to let staff know that "the same principles that exist for the physical Record Management also applies for electronic records" Some even claim electronic records MUST not be destroyed and should last forever. I agree with the need for collaboration with the various teams and departments. But more importantly legal, internal audit and Tax or in other instances treasury departments MUST necessarily be part of the approval process. IT departments should give out the necessary administrative rights to the RM to perform without much hindrance. Similarly, the retention and disposition policies should be flexible enough to allow reviews by the various departments when required.
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Blake Richardson, CIP, CRM

Is Volume Dictating Our Actions?

Many organizations conduct a multi-layer approval process before destroying a box of records, business owner, records manager, tax and legal. Approving the destruction of a few hundred boxes of records is a manageable process. However, if this same group of approvers had to review every document in every box it suddenly becomes an unmanageable process - similar to, but still dwarfed by the potential number of electronic documents that may be eligible for destruction during any given destruction cycle. I am hesitant to concede that we should modify an established organizational process based on volume alone. However, I am also a realist and know that approving electronic destruction at the document level will become a full-time career for those involved. I believe we have to categorize/summarize electronic content (with the ability to drill down if needed) by doc type/keywords etc in order to make the process work.
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isabelle Viel

Pre- approval process : what level of details ?

Thank you for this very interesting post. Given the large amount of data, especially whith electronic records, to your opinion what level of details would be appropriate for the pre approval process ? Thank you.
isabelle
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Stephen Dale

Re Electronic Record Disposition

I'm only surprised that this is a minority perspective. RM's are in the same position as King Canute - you can't hold back the tide of electronic records. With global information now doubling in size every 74 days, you have to take a practical and pragmatic approach to what you can manage. A risk-based approach seem eminently sensible to me.
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Susan Cisco

King Canute - You Can't Hold Back the Tide of Electronic Records

Stephen, I had to look up King Canute to learn the story of how the Viking king sat on his throne ordering the sea to turn back. It's a great metaphor to help us understand the options in managing the sea of electronic records.
Susan Cisco
512-565-7021
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Susan Cisco

Level of Detail for the Pre-Approval Disposition Process


Isabelle, thanks for your comments. Rather than pre-approval documentation, consider the use of destruction logs to provide evidence and verify completion of electronic record destruction. Keep information on the destruction log to a minimum, starting with the unique identification of a record (number, filename, or record title). Additional information to capture on the destruction log includes the significant dates of the piece of content’s lifecycle, e.g., creation and destruction dates and system-generated documentation. Susan Cisco 512-565-7021
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Mitch Shults

How do you 'focus on records that expose them to the greatest risk and apply controls accordingly'?

Your comment reminded me of some of the Bayesian inferencing approaches that I've seen applied in the 'big data' context by national security actors who are looking for large-scale patterns in the data that could imply a threat.

I wonder if a technique like that could be used to address the risk challenge. It takes huge amounts of computing power, memory and bandwidth to execute the necessary algorithms and store the resulting graph-oriented data that reflects the assessment, but those things get cheaper every day.
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Jon Tilbury

Electronic and Paper are different

I agree electronic and paper workflows should be different - electronic volumes will be larger, the processes are different and the automation demands will be significant. However, it is a difficult job to persuade RMs with years of habits built up to accept this. We tried this with one RM (an Archivist) who told us "we have been using this process for the last 100 years, why should we change now" - difficult to answer that one.
When we implement an RM or Archival system we aim for maximum automation in the workflows but most important make them easily changeable - as time goes on the digital model will win over and people will get fed up with having to manually approve 100s of actions per day.
Jon Tilbury
Tessella
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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