Is Your Company Clueless? A 10-Point Checklist.

Having worked for many companies in various industries over my career, I am always surprised when I ask to see a records retention schedule and I get a quizzical look. My next question is: “Do you know what a records retention schedule is?” Too often followed by a slow, side-to-side shake of the head with a verbal statement in a querulous voice (as if to say, “Should I?”), “No?”. That’s when I realize that my client needs major Records Management 101 training.

Here is a checklist to determine if your company needs basic records management training.

1). The company does not have a current records retention schedule. Please notice the word “current” in that sentence. Why stress that word? Too many times a company says, yes, they have a records retention schedule. Then I find out it was established years ago and has not been updated since. Many companies believe that all they have to do is establish a records retention schedule, but fail to plan for the maintenance of the schedule. Laws and regulations change, business changes – the records retention schedule must be updated to reflect those changes. Think of it this way… as we go through life we change our wills, our insurance coverage, the way we invest to meet our changing needs. A records retention schedule must reflect the current laws, regulations, and business needs.

2). The company places a freeze on the destruction of any and all records when hit with litigation. This occurs because companies have no clue as to which records pertain to the litigation, so the safest thing to do is to freeze everything. In a good records management program, records are kept for a reason . . . to record the transactions of a company. Records should always be described in detail using key words, phrases, and records codes which identify the type and subject of the record.

3). The company’s retention period for all records is 7 years. (Or any other blanket “x” number of years.) This is a holdover from the IRS – most people keep copies of their filed tax returns for 7 years. In fact, there are tens of thousands of Federal and state laws and regulations regarding how long to keep specific records. It is a corporate decision to keep the number of retention periods down to a realistic few. The laws tell us how long to keep records at a minimum, corporations can decide to keep them longer. The requirements are getting more complex each day, so corporations are often opting to establish retention “buckets”, thus lowering the number of retention categories. If a record is required to be held for 3 years, a company may opt to put it in the 5-year retention category and do away with a 3-year retention bucket all together.

4) The company’s policy is to keep records “permanently, forever, or indefinitely.” This is a problem on a couple of levels.

• Keeping everything for long term is detrimental to the smooth operations of a company. Regardless of the media, more and more records are stored, making it more difficult to find the information you need quickly and efficiently. Storage is cheap, so often times, IT departments just buy more storage and don’t go back to determine what could actually be purged. This adds cost, but more importantly, it means that whenever there is a search done, the search has to go through all the information that is not needed to be retained, thereby slowing down the retrieval process. 
•  How long is permanent? Can you quantify forever? Realistically, how long does the record really need to exist? In the manufacturing arena, records must be retained on a product for the life of the product – plus a few more years. Even though this may be a very long time, the records retention schedule should reflect the requirement, not just say “permanent.” At pre-determined intervals, this record series should be reviewed to identify if the product is still being used by consumers. The clock starts at the point at which it is determined that the product is not being used. For instance in a medical device manufacturing firm the requirement on a series of records dealing with a product line might be life of product + 5 years (LOP+5). At the point where it is determined that no units of this product are in use, the records need to be retained for five more years.

5) The company thinks the retention schedule only applies to paper records. Many companies have a retention schedule for paper records and a separate retention schedule for electronic records. My approach is to keep things simple. Use one retention schedule for both. The media is only the vehicle on which information is served to the user.

6) Each department is charged with developing its own records retention schedule and records management program. This can spell disaster as you have each department retaining the same categories of records for different periods and causes confusion within the company. Be sure that the records management program is managed by one office, with knowledgeable staff.

7) Employees keep records “just in case.” The law doesn’t tell us to keep records “just in case.” For the most part, the laws concerning records retention are very specific and direct companies to keep records for X amount of time at a minimum. Obviously, for business reasons, a company can choose to keep records longer, but nowhere in retention language is the retention period “just in case.” Executives are usually the ones who want to use this language, perhaps because they just don’t want to deal with the retention question. “Just in case” is not a retention period.

8) The office of record is not identified. The office of record should always be identified on the retention schedule. This helps other workers when going through their records to understand if they are the owner of the record or if some other department is. Additionally, this leaves little, if any, doubt about who should be keeping what records.

9) There is no formal process for reviewing and approving the destruction of records. We perform processes at work every day and give little thought to it, but to protect the individual worker, as well as the company, all processes should be documented. This is no different for records retention review processes. Businesses change, laws change, and events happen that one area of the company may not be privileged to. For example, say customer service had client records and many were scheduled to be destroyed this year. Is it safe for the records to be automatically destroyed? No. The department head and legal need to review the records slated for destruction before they are destroyed to ensure there are no business or legal reasons why the records should be retained. As a records manager, I’m not going to necessarily know that. What should happen is that the records should be placed on a destruction hold, but that does not always occur.

10) There is a current records retention schedule but employees don’t know where to find it. A records retention schedule is a policy. One cannot expect employees to follow the policy unless they are 1) trained to it and 2) know where to find it to refer to it. Too many times, I go into a client’s office and ask for a copy of the current records retention schedule and get multiple (very different) versions of the document. No one really knows what the current version is, let alone how to find it.

If any of the above situations sounds like your company, you need Records Management 101. No need to go into detail, the goal is not to make a records manager out of every employee, but they should know the basics.

How does this fit into ECM? ECM is only as good as the way in which information is managed. Companies constantly throw technology at a problem, adding this system or that system to solve business issues. They put information in these systems without thought about how and when to delete information. They compound the problem this way. Get a handle on what information you have, where it belongs (what system), who “owns” it and when to legally get rid of it. Have a strategy and processes --- we manage finance assets and human resource assets, but we have trouble understanding that it is just as important to manage our information assets. Information is the backbone of any company – with out information, there is no company.

In these monthly columns, I will be exploring specific information management compliance (IMC) considerations and issues as they pertain to ECM from the trenches and viewpoint of a well seasoned end-user. If you have particular topics you would like to have discussed in this column, please contact me at tk.train@imceds.com.

TK Train is a board member with AIIM. I

f you do need RM 101, take a look at AIIM’s Electronic Records Management certificate program .  Also, for a good overview of how teamwork is critical to the success of an ERM program, download (it’s free) the poster, Winning with Electronic Records Management.