When weighing the risk of storing cartons that may be past due for destruction and discoverable versus the risk of destroying cartons that should be retained according to laws and regulations, many companies opt to err on the side of over-retention versus the terminal and irreversible option of destruction. 68% of respondents to the 2016|2017 Cohasset Information Governance Benchmarking Survey stated that users cannot let go of information under their control.
Many users will wedge records into a record class with a longer than necessary retention period rather than classify to the appropriate record class. When disposition lists are presented to business owners they will often ignore them or refuse to authorize. Legal and Compliance will often reject disposal requests that are based on cartons with manual destruction eligibility dates because they may not be based on current laws and regulations governing retention.
A Records and Information Management (RIM) program needs to have the proper executive sponsorship in order to succeed. Partial measures will often lead to confusion and further intransigence on the part of the business units. A directive that all records should be classified to the company retention schedule and that all retention should be driven by system-generated destruction eligibility dates will drive compliance with company policies and allow decision makers to trust that the destruction eligibility dates are driven by current laws and regulations.
Business processes regarding which types of active records are sent to offsite storage should be considered when the retention schedule is implemented into the records management system. For example, it may be known that all records of a certain type are sent to offsite storage only after the triggering event has occurred. In this case the record class can be implemented to utilize the storage date as the base date for calculation rather than require the population of an event date.
58% of respondents to the Cohasset Survey stated that eligible information cannot be readily separated from information that must be retained or is needed for legal holds. A policy for carton creation should be mandated to box together only like records in order to minimize “mixed” cartons in which records with shorter retention requirements or records not subject to legal hold are over-retained. The records management system should be set up to ensure that minimum metadata standards are met for all cartons received into the system. Each carton should have a record class, departmental ownership, contents description and a “to date” (latest records date in carton).
In addition to future-proofing the RIM program by ensuring that all new cartons will be assigned a valid record class and that all destruction eligibility dates will be driven by the retention policy, the company will need to deal with unclassified legacy cartons and cartons with undefined retention. While it is possible that many of the legacy cartons are past due for destruction, a deliberate process is required to classify these records so that they appear on a system-generated disposition list for review. Periodic reviews should be conducted to assess cartons with undefined retention. Cartons with indefinite retention periods should be reviewed to determine whether they can be reclassified to a fixed retention record class. Cartons with event-driven retention periods should be reviewed to determine whether the retention event has transpired in order that the event date can be populated to allow for the calculation of the destruction eligibility date.
81% of respondents to the Cohasset Survey felt that the “keep-everything” culture is a challenge to their Records and Information Management program. Simply having a compliant Records Retention Schedule is not enough. It must be implemented into the records management system with the proper business processes in place to support it or users will not feel empowered to make the important decisions with regard to the defensible disposition of records.