Is Your Company Clueless? A 10-Point Checklist for your Company’s Record Management IQ

Posted on Sep 11, 2009 in Records Management News

From AIIM: http://www.aiim.org/infonomics/clueless-about-records-management.aspx

What’s your company’s records man­age­ment IQ? Does your com­pany do any of these things? You may need some basic records man­age­ment 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.
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 – with­out 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.

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Best Per­sonal Regards,

Cary