12 steps to creating and implementing a records retention ... · 12 steps to creating and...

12 Steps to Creating and Implementing a Records Retention Schedule

Jim Mack, CRM

MN GRINJanuary 17, 2007

January 17, 2007 Retention Schedule Basics 2

Why is this important?

PoliciesRegulatory compliance / best practice

ProceduresPreservation & disposal

ProductivitySpeed & efficiency

ProcessesWorkflow (business process management)


THE BIG PICTURE

What do we have?What are they worth?What do we do with them?


Records Inventory

Data Analysis

Retention Schedule


12 Steps to Retention Scheduling

1. Define “record”2. Choose victim3. Agree on scope4. Conduct inventory5. Analyze results6. Research retention

7. Negotiate time8. Write schedule9. Gain approval10. Provide training11. Audit compliance12. Revise schedule


1. Define “Record”

Recorded information, regardless of medium or characteristics, made or received by an organizationthat is evidence of its operations, and has valuerequiring its retention for a specific period of time.

Glossary of Records and Information Management TermsARMA International, Prairie Village, KS, 2000


1. Define “Record”138.17 Government records administration.Subdivision 1. Destruction, preservation, reproduction of records; prima facie evidence.(b) For the purposes of this chapter:(1) The term “government records” means state and local records, including all cards,correspondence, discs, maps, memoranda, microfilms, papers, photographs, recordings, reports,tapes, writings, optical disks, and other data, information, or documentary material, regardlessof physical form or characteristics, storage media or conditions of use, made or received by anofficer or agency of the state and an officer or agency of a county, city, town, school district,municipal subdivision or corporation or other public authority or political entity within the statepursuant to state law or in connection with the transaction of public business by an officer oragency.

(2) the term “state record” means a record of a department, office, commission, commissioner,board or any other agency, however styled or designated of the executive branch of state government; a record of the state legislature; a record of any court, whether of statewide or localjurisdiction; and any other record designated or treated as a state record under state law.

(4) the term “records” excludes data and information that does not become part of an officialtransaction, library and museum material made or acquired and kept solely for reference…



Recorded informationEvidence of a government transactionValuable to the organization……for a specified period of timeNot dependent on storage medium



Proofthat we have donewhat we aresupposedto be doing.

Mack, 2006


2. Choose Your Victim

…carefully

Are they ready?Cooperative?Supported?Resources available?Is value added?


3. Agree on Scope


4. Conduct the Inventory


Definition of “Records Series”

Group of related recordsfiled and used together as a unitfor retention purposes


Definition of “Records Series”

Data set:

A separate, discrete body ofcomputer data that is logicallyrelated, serves a commonpurpose or function, and thuscan be considered as a separate unit for analysis.


Types of Records Inventories

DepartmentalTraditional (military)Disrupted by reorganizations

FunctionalStrategic (use and purpose oriented)Ownership is diffuse

Process-Focused**Tina Torres, CRM, PMP

“Creating a Process-Focused Retention Schedule”The Information Management Journal, September/October 2006


Process-Based Scheduling

Fewer records seriesEnd users able to classify accuratelyBased on the core processesWork flow is integrated into scheduleRequires in-depth understanding of the

agency and output documentationRetention periods may be longer


Records Inventory Methods

Physical - we do the heavy liftingSurvey – SMEs answer our questionsInterview – we meet the key playersHybrid – whatever works… …in our agency and the organizational

unit, function, or process under study


Questions to Ask

Who?

What?

Where?

When?

How?


Questions to ask – Who?

Who created or received the record?Who uses it in their job?Who controls the content?Who makes sure it is accessible?Who decides how long to keep it?Who can access the record?


Questions to ask – What?

What is the business need for collecting the data?What would happen if we didn’t have access to the record?What value does the record have to the agency?


Questions to ask – Where?

Where does the data come from?Where is it stored?

physical location digital address

Where is the duplicate copy of a vital record kept?Where does the record go when we are done with it?


Questions to ask – When?

When did we start collecting them?When is it declared a record?When does the “retention clock” start ticking?When does it become inactive?When does it become obsolete?


Questions to ask - How?

How many do we have?How do we protect the record from unintended destruction? (backup)How is the data in the record protected from unauthorized access?How is the record preserved for the duration of its retention period? (media)


What’s on the Inventory Form?

TitleOwner / StewardPurposeDescriptionCitationsRetention requirements

Trigger eventLocation

MediaBackupWorkflowQuantity / Accumulation rateData Practices / Access restrictionsSystem requirements


Schedule eRecords Separately?

Yes – Clarifies procedures

No – A record is a record


What’s on the Inventory Form?

TitleOwner / StewardPurposeDescriptionCitationsRetention requirements

Trigger eventLocation

MediaBackupWorkflowQuantity / Accumulation rateSensitivity / Access restrictionsSystem requirements


Who did it /Date

DataPractices

classification

BusinessContinuity

RequirementsOwner

GeneralDescription

New or

Revision

Inventory Form, Page 1


Records Lifecycle Management

Time

Activ

ity Declaration (“trigger”)


Inventory Form, Page 2

RecycleSecure

RecycleSecure

RecycleSecure

DISPOSAL

TotalTrigger event

Records center

TotalTrigger event

Records center

TotalTrigger event

Records centerRETENTION

ReportsDelivery method

WorkflowFiling

Indices

Sourcedocuments

CONTENT

OUTPUTPROCESS

USESTORE

INPUTCAPTURE


www.epa.gov/records/tools

PurposeDescription

Title



TitlePurpose

Description

…about those electronic records…


“completed jointly by employee and review team [records manager]”

Technical Stewards

DATASET


5. Analyze Results

Records as an assetValueHow

valuable?


The “Big Question”

Does your agencyperceive recordsas a cost centeror as a valuableasset?


Fiscal Value

ObligationsAccounts receivableAccounts payable

AccountabilityFiscal responsibility

Bottom lineProof to taxpayers / stakeholders


Legal ValueAre we going to be in troubleif we should have it…and don’t?

COMPLIANCE

Are we going to be in troubleif we still have it…and shouldn’t?

DISCOVERY


Historical (Reference) Value

Will it be going to State Archives?

Are we doing the right thing?


Operational Value

Required

Makes it easier


How valuable are the records?

VITAL Can’t do business without itCan’t be recreated

IMPORTANTCan’t do business without itCan be recreated (although expensive)

USEFULNONESSENTIAL


6. Research Retention

Think like an attorney

There is no “cookbook”

Ask the SMEs

Use your brain


Think Like an Attorney

RegulationDiscoveryLitigationProofStatutes ofLimitations


There is No “Cookbook”

DeclarationRetention “clock”Duration of value

LegalFiscalOperationalHistorical

3-year rule


www.irch.com


Ask the SMEs*

FamiliarityKnown risksLocationProcessesWorkflow

* Subject matter experts


Use Your Professional Judgment

Face validityEnterprise-wide perspectiveClear to someone unfamiliar with jobRelated recordsGeneral schedules


www.naa.gov.au/recordkeeping


7. Negotiate Time Periods

PermanentIndefinite20 years7 years12 months“At least…”“No longer than…”


www.revisor.leg.state.mn.us


www.gpoaccess.gov/cfr/index.html


www.Lawmoose.com


http://public.findlaw.com/library/state-laws.html


Management of e-Records

The majority of daily communications, record-keeping, and governmenttransactions are done electronically.

Deal with it.


It’s all about content,not the storage or delivery media.

We must do somethingto protect and preserverecords on digital media.


Migration / Conversion / Emulation


What about the hard drives?

Issue:Access by employees who have a need to know.

Keep official records on the shared servers.


Once created,eRecords liveforever.


Memory is cheap. Why not keep it all forever?

Have to index themToo many to search efficientlyAll information is not created equalHave to track where everything isSystem redundancy for vital recordsThe records can be discovered


www.CricketTechnologies.com


Scheduling records is a decision-making process that is best done when not under the pressure of a subpoena, disaster, or other crisis.


8. Write the Schedule

Do Ihave to?


Assumptions:

A new records series is discovered The old schedule is out of dateManagement of the records in electronic format is not describedOveruse of “permanent” or “indefinite” retention periodsNot understood by employees


8. Write the Schedule

The following words are banned from RecordsRetention Schedule titles:

records miscellaneousfiles generalforms etc.

olddeadarchives

old Blue files

from Bob’s desk


Schedule Writing Tips

Tie disposal to a recurring eventUse general schedules“Permanent” has to be definedPlan for technological changeIdentify records series requiring

unusual management procedures


Abbreviations


Acronyms


Use the Description field to:

Clearly define who owns the recordClarify roles and responsibilities of the

records’ stewardsShow how the record is usedPoint out where it fits in the agency’s

business planDescribe special handling required


Use Retention Requirements to:

Define the record’s movement through the life cycle processDefine the point when it becomes the

“copy of record”List storage locations and conditionsMap out backup proceduresDisposal instructions


Put enough detailin the description of the records seriesso that anyonecan follow theprocedures andrequirements.


Scheduling Issues:Owner v Steward (Custodian)Standards are criticalUsers can be very creativeEverybody’s records are vital


What’s on the Schedule Form?

Owner / stewardSeries identifierTitle DescriptionRetention requirements

Trigger eventLocationMigration plan

MediaBackup plan

VitalImportantUsefulNonessential

Data Practices classification


www.whitehouse.gov/oa/foia


9. Gain Approval

Get supportfrom the boss


9. Gain Approval

Attorney General / legal servicesLegislative/State Auditor / internal

auditState Archives / records managementBusiness unit (subject matter expert)

Get approval (and buy-in) fromyour Records Management Team:


9. Gain Approval

Information technology services

They are thetechnicalstewardsof ourrecords.


10. Provide Training

IntranetIn-service trainingNewsletterInformation sheetGroup/staff meeting

Excellent service


11. Audit Compliance

Is there an approvedrecords retention schedulecovering all of the records?

Are all employees followingthe approved schedule?

Is destruction / deletionof records documented?


12. Revise Schedule

Retention schedulesare living documents.

Revise them asneeded to enablecompliance.

(This is an exampleof poor electronicrecords management)


What is the result of all this recordsinventorying,analyzing, andscheduling?


A happy boss.

Thanks,Records Guy!


The boss stays out of headlines.

POLICYCompliance


Useless records are gone.

PROCEDUREDisposal


Work gets done faster.

ProductionEfficiency


We’re organized.

PROCESS

Workflow


So…what’s the plan?


The Work Plan

Phase 1 – IdentifyAction: Each employee identifies the documents that prove they are doing their job.Decisions:

Official records v convenience copiesOwnership v stewardshipSorting into groups (records series)


The Work Plan

Phase 2 – InventoryAction: Describe the life cycle of the documents identified as records in Step 1.Decisions:

Length of time that records have valueContinuity of operations planningData Practices (privacy) classification


The Work Plan

Phase 3 – ScheduleAction: Document how the records described in Step 2 are to be managed for their entire life cycle.Decisions:

Data capture methodStorage media selectionBackup strategyMigration/conversion schedulingDisposal requirements and procedures


Need more info?

Jim [email protected]

www.archives.gov/records-mgmt

http://infomgmt.homestead.com

www.mnhs.org/preserve/records

12 steps to creating and implementing a records retention ... · 12 steps to creating and...

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