One of the often-overlooked challenges of electronic records management is the control and maintenance of retention policies. This is particularly difficult if you are faced with many different record series categories in your organization, which is increasingly the case for modern enterprises. When managed separately, organizations maintain a unique retention policy for each record type. If you have only a few different types of records to manage, this approach works well. However, it becomes more and more difficult as the volume of unique record types increases. Further, if your organization is required to manage permanent records that need to be archived to another organization, such as NARA (National Archives and Records Administration), additional challenges come into play.
Tracking and controlling hundreds of retention policies that are likely to change as regulations and other organizational and operational factors change can become unmanageable very quickly. The support and maintenance cost along with the compliance risk can significantly dilute ROI and leave you with processes and tools that fail to meet the goals for which they were designed.
Legal, compliance, IT and records management teams can address this issue and add efficiencies to the records management function by consolidating retention policies. This can simplify and reduce the overhead associated with managing dozens of policies across various record types. This can by done by grouping schedules together within your series according to their function or another applicable categorization scheme and their dispositions.
The following is an example of how this can be accomplished:
- Create “buckets” representing high-level record series areas.
- Group record series members within the “bucket” into categories based on function and comparable disposition schedules.
- Define and assign a common disposition strategy to each functional area that is representative and compliant for all record series members.
To understand what this may look like in practice, consider this illustration:
- You have five unique high-level record series groups.
- Each series group has 100 individual record types.
- The schedule for each record type ranges from temporary dispositions of one month to 10 years, to permanent records with a duration of 25 years or more.
- Each of the record series contain record types that share a common purpose or function.
Using this example, basic consolidation steps would include:
- Define each high-level record series group as a separate “bucket”. Within each bucket you can create categories based on function such as whether the members are administrative, case related, procedural, etc.
- Within each of these sub-groups you would combine applicable members based on corresponding disposition schedules. For example, within a record series “bucket” if you have 25 members that are administrative records, and they have temporary dispositions with durations ranging from three months to five years, you can create a single retention policy with a disposition strategy of destroy/delete after five years and include each of these members under the policy. By doing this, you only need a single policy that can apply to 25 record types instead of having 25 separate retention policies.
- Follow a similar process for each high-level record series and you can reduce what was in the case of this example 500 individual retention policies into a number that is much more manageable making it easier to control.
Key when consolidating retention policies include:
- Work with your records managers and any outside agency, such as NARA, that you archive records with before implementation, make sure you have buy-in for the initiative.
- Identify the special record series members and handle them separately with their own policy as needed to help reduce compliance risk.
- When grouping record series members within a retention policy based on disposition schedules be wary of regulations that can be applied, it is generally best practice to only hold certain records for as long as necessary and no longer.
- Design an automated process for declaring formal records which will reduce workload and provide a better user experience for your records contributors/managers. If you have or choose to implement an automated formal records declaration process you can provide more flexibility and room for growth by using something like an XML file or table to map the individual record series members to their applicable location in the formal file plan where the retention policy has been applied.
- Consider structuring/restructuring your formal file plan after the consolidation strategy and apply your retention policies at the applicable level and allow the policy to be inherited by all formal records within that section of the file plan.
This information is an example of how retention policies can be simplified, but in practice, it is best to customize policies and processes according to your organization’s unique needs and risk profile. Make sure you have experts involved to avoid unexpected risks and oversights. The goal is to reduce overhead while minimizing data risk and maintaining compliance. Given that electronic records management solutions are significant investments, and the growing impact of complex privacy and data governance laws, it’s critical to protect your organizations with a solid and sustainable design.
The views expressed herein are those of the author(s) and not necessarily the views of FTI Consulting, its management, its subsidiaries, its affiliates, or its other professionals.