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What’s wrong with using the Big Bucket approach to Records Retention Schedules?

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There have been discusses in the records management professional about limiting the number of different record categories (records series) in an organization’s retention schedules.  The arguments are that there are just too many different categories of records in a large organization and that not enough records management resources are available to identify and analyze them all.  It is also felt that fewer categories of records would make the classification of records easier for the users.

The fewer records series could be established using a project management approach – follow the work flow and group the different records series by how they are associated at the different stages of the work flow.  Others suggest identifying records series based on the years of retention.  Establish one records series for two-year retention, another for five years, etc. and matching the different records to the most appropriate records series.

It is suggested that records management theory is fine, but we must address the reality of the current situation in organizations these days.

In my many years of establishing retention schedules in organizations, I have held many discussions with senior members of management who argue that retentions schedules are unique and, basically, they have never had to deal with them in the past.  I have said that the structure of retention schedules is not unique.  In fact, those of us managing information are stealing the management control structures that have been proven successful in other areas of the organization.

When I teach the AIIM’s ERM certification course, I am met with silence when I ask the students what the parallel management control structures are in Human Resources and Finance.  These parallel structures are the Organization Chart and the Chart of Accounts, respectively.

I simply ask has anyone seen a truncated Organization Chart or Chart of Accounts in large organizations.  I don’t think so.  In the same, and in this information age, it is absolutely necessary to compile a comprehensive records retention schedule.

My students can tell you my number one general management principle.  That is that you can not manage what you don’t know about.  The different records series must be identified and a value analysis must be carried out on each one.  While I agree that establishing retention periods is important, what is even more important is documenting the value of the records series to the organization.  This is parallel to the Organization Chart in which each job position is supported by an approved job description.

I agree that organizations do not have the records management resources they need.  In this information age, that must change.  For those organizations that are concerned about their levels of staffing, I am happy to suggest they reduce staffing in the HR and Finance areas.  Policies in these areas are well established.  There management control structures are developed and taken for granted by the operating managers.  Fill these positions with records management professionals who need to establish records management policies, including the handling of e-mail and instant messaging, along with the many other information management practices.  There is also the critical need to establish a comprehensive records retention schedule across the enterprise and to provide the necessary communications and training and to enable enforcement of these policies.

There is also the issue of getting employees’ cooperation.  What is currently going on is that organizations are establishing corporate control over their information assets.  This also parallels the corporate control over the human resources and financial assets of organizations that began after the Second World War.

Believe me, staff screamed and hollered when these efforts were first introduced.  For example, having to provide receipts to get reimbursed for business expenses was considered impossible to do.  Employees argued that this idea was ridiculous.  Yet, years later, this practice is taken for granted.  In the same way, individual users will take it for granted that they need to capture their own records into an electronic records management repository.

Is this effort to instill corporate control over the information assets of organizations easy?  Absolutely not!  Senior management will have to buy into the need for this to be done.  Reading the current literature on the damages experienced by organizations, including the negative impact on their reputations, because of poor email management, their inability to handle e-discovery and their inability to protect personal information, I have no doubt that management has no other alterative.

We, as records management professionals, will need to stick to our guns (remain convinced that what has been successful in other practices, Human Resources and Finance is the right approach to follow), we will need to implement enterprise content management (ECM) and electronic records management (ERM) solutions within our organizations and we will have to use all the change management knowledge and skills that we can muster.

What is your experience in developing retention schedules in your organization?

Comments

Submitted by Dan Elam June 18, 2010 - 11:10 AM

Carl, I suspect that if the Records Manager walks into the CFO and says "eliminate people in Finance and give them to me in RM", well, the budget might not exactly be kind to the RM next year. Your points about users getting over their objections is right on the money, but that hurdle can be very high. That is why 'big buckets' exists: to minimize the amount of work require to classify a document. If there are too many buckets, users won't do it. (Every audit we see on a non-big bucket system has an abnormally high number of records in the first code when listed alphabetically). What you give up with big buckets is the ability to do finer level sorting for retention or other purposes. Thus you might keep a document that involves either liability or ediscovery cost risk, but you balance that with a system that users are more likely to use and easier for them to comply with the policy.

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Submitted by James Santangelo June 20, 2010 - 9:01 PM

These are both sides to a very important argument when dealing with large volumes of unstructured records. Fact of the matter is that on one hand, strict record retention policies are very difficult to implement enterprise wide and will fall short of capturing the required records, and on the other hand the big bucket approach doesn't adequately classify the records to meet retention compliance obligations. Using one approach or the other will likely fail, so a compromise can be made.

To improve the chances of a successful implemention of a records strategy, a risk based approach can be used - first determine which records are of higher and lower risk. For higher risk records, a strict retention and classification procedure can be followed since the scope is more limited and can be enforced. For lower risk records, a big bucket approach can be used to try and capture records that would not be captured otherwise. Users will likely make more effort in capturing records when they are preceived to be higher risk and the volume of information being evaluated as a record becomes more focused.

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Submitted by Randy Moeller June 22, 2010 - 3:47 PM

Carl, for now the move to larger buckets will continue at least in most businesses. The example of business expense was a problem that was helped by the change of not having to collect all receipts under $25 and allow authorizations for most missing ones. Heck we don't have a true corporate wide org chart due to our size and the cost it would involve to maintain one is not justifiable. You only want to pay so much for our products. Same with the cost of RM staff. Not justified if easily 80/20 of the folks can use the schedule without difficulty. Not that we would ever have only 100 to 200 r/s as the businesses are too diverse and global. Many r/s can go by a process (procurement, billing, receivables) with a good description since the retention times will be the same anyway. Not hard to figure out how long to keep your copy of that expense report. We also make it easy by letting the people take the few r/s they use and make their own short list on-line so they can ignore the rest of the schedule.

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Submitted by Wayne Hoff June 22, 2010 - 4:26 PM

I appreciate your emphasis of the management maxim you can't manage what you don't know. But I think we're discussing two different information management segments: one is knowing an organization's information, and the other is applying retention periods to it. Both of these are important parts of an overall information management program, and the maxim still holds: if you don't know what information is there, it's difficult to make it available for enterprise search, calculate its probative value in a legal matter, identify the risks associated with it, or finally, determine its proper retention length. Whether I categorize the information in small buckets or in big buckets isn't a reflection on the overall management of the information; rather, it's a reflection on the manner in which retention periods are determined in the organization.

However, if the big-buckets retention schedule is the only means by which the organization's information is identified and evaluated, then I think that the dangers you point to are very strong.

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Submitted by Mike Drolet June 23, 2010 - 10:12 AM

Going to have to disagree . . . to a point. The bucket process is a much simpler process for managing retentions then for trying to maintain seemingly arbitrary retention lengths (this years “keep it forever” record can easily becomes next years “obsolete” record) on what can accumulate to hundreds of separate record schedules. Managing that variety of records retention with a simpler 5 or less set of bucket retention lengths will not only garner support and cooperation from the end users (those that will ultimately be responsible), but will allow for migrations much easier to new systems and even new personnel. When building a records management process, it needs to outlast the builder. A detailed system that is managed by one person will fail when that one person moves on.

And records have a habit of outlasting individuals.

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Submitted by Susan Cisco June 28, 2010 - 12:10 PM

Records management practices are evolving to meet the challenges of managing information born digitally. In assisting our clients with ECRM/RM system implementations, we’ve learned that reducing the number of categories in retention schedules improves their ability to consistently retain records and reduces risk for keeping records too long or not long enough. We limit the role of retention schedules to providing retention periods for information with record value and implement information lifecycle models to provide retention for everything else. We recommend data maps for capturing more detailed inventories of digital information (see http://www.aiim.org/infonomics/quest-for-ediscovery-creating-data-map.aspx for Ganesh Vednere’s excellent “how-to” article).

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Submitted by Carl Weise June 28, 2010 - 3:40 PM

Susan

Like you, I had found Ganesh Vednere’s article to be excellent!

At this time, when legal, records management and IT should be partnering to manage the content of an organization, I would expand his discussion to have this data map also act as a foundation of the records management program. Responding to ediscovery should not be an independent activity. The records management program should be designed to support all ediscovery needs in the future.

Through the effort of developing this data map, we need to identify the different categories of records and content that exist within the organization.

To get to the point of this blog, do we come up with an arbitrary number of categories (big buckets) for management and retention, or do we come up with the number of different categories of records and content based on the greater number of permutations based on record and content type and their values, including different administrative, legal, fiscal and historical needs?

I firmly believe in the latter.

A large organization can have hundreds of records series and content categories. I can see this as the result of Ganesh’s data mapping effort. I have no trouble with this and actually take it for granted. Mike Drolet suggests that “a detailed system that is managed by one person will fail when that one person moves on” and “records have a habit of outlasting individuals”. For the records retention program and, in fact, the records management program to be successful, there is a need for an ongoing information governance group or, my preference, a central records management function – just like HR and Finance. These professionals, CRMs and/or ERM Masters, will oversee the comprehensive retention schedule across all functions and over time.

While organizations can have hundreds of records series, the important question is how many of these records series and content categories are used by the individual users? If these categories are broken down by role within the organization, how many categories does any one user have to deal with? I believe that the answer is relatively few. Are 10 to 25 categories too much for individuals?

Going back to my analogy of the Finance function, why are managers asked to set budget amounts for a collection of expense accounts, rather than one general expense account? The multiple accounts are needed to manage the capital assets of the organization, not to make it easy for the managers. In the same way, the number of record and content categories should be such to properly manage the content. In both cases, working with expense accounts or a number of records series, training should be given initially and feedback provided on our efforts.

Using technology, such as ECM/ERM solutions, using tight integration between the office applications and email, I see the user only being exposed to those records series or content categories that impact the role of the user.

There can also be the use of file plans that provide specific information of those records and content that impact individual departments and users.

Recognizing the push back we will get from people when they are asked to change, I support the use of the big bucket approach as we try to change the way the staff works and start to appreciate the need for records management discipline. However, as users become comfortable with the use of structure to manage their records and content, we need to continue to get more granular to properly manage the organization information.

The bottom line is that we don’t come up with a number of categories to please the users; we need to get to the number of records series and content categories to be able to manage the information assets of the organization. This includes efficient and cost-effective ediscovery.

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Submitted by Mike Drolet July 07, 2010 - 9:36 AM

The problem I have is when your schedules start to number in the hundreds and individual documents end up being a part of multiple schedules depending upon the content of that document at that time. So it becomes unrealistic to try and keep every contingency detailed.

Correspondence alone could easily be 20 different schedules alone when you factor in who initiated it and what the content concerns.

Separating out the retention lengths into manageable buckets makes compliance much easier to manage when you set the retention lengths to capture the majority of current retentions into a few choices. In few cases is keeping something longer than necessary that great a liability to warrant a record specific retention period. If it has a retention length of 1, 2, 3, - 9 years having a bucket for 10 years to hold anything that has a “lower” retention in most cases is not only fine, but also easier to manage for individuals, especially when only a fraction of your documents are electronic and easily reported against. Have another bucket for 60 years to capture the 11-60 year documents. One more for archival “keep forever” documents.

That being said, the Bucket Retention proposal doesn’t replace the need for record schedules. You still have to know what your records are, but what the Bucket Retention proposal does do is eliminate the “Arbitrary” record lengths where folks at that time determine how long this new record needs to be kept. It also eliminates the - “keep it for 2 years after I retire” mentality.

You will always have those “special” records that you need to keep and don’t fit into your existing buckets, but if you can capture 95% of your records within the buckets, 5% “special records” are much easier to manage accurately and consistently on an individual basis than 100% of all your records.

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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