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K E E P I N G Y O U R O P T I O N S O P E N

RETENTION SCHEDULES

AGENDA

• Retention schedule options • What will work best for my organization • Appraisal methods • Determining retention periods • Non-record information • Looking for approval • Retention schedule components & formats • Updating the retention schedule

THE RETENTION SCHEDULE

• The most referenced RIM document is the record

retention schedule!

RETENTION SCHEDULE OPTIONS

• Departmental • Functional/process • Big bucket


• Departmental

• Still the most widely

used • List each individual

record by department


• Departmental


• Departmental

• Retention applied to individual records

• Litigation, audit and inquiry response

• Easy to understand • Enhanced lifecycle

management

RETENTION SCHEDULE OPTIONS (DEPARTMENTAL)

• Retention applied to individual records

• Allows each departmental record to be assigned a retention period.

• This helps to ensure that each record is only retained as long as required.


• Litigation, audit and inquiry response

• Easier identification and production of relevant records.

• Holds can be placed on specific records.


• Easy to understand

• Listing individual record types by department makes it easier for employees to understand how long to retain specific records.


• Lifecycle management

• Retention assigned to individual records

• Records are retained as required by laws and regulations – versus other schedule options that may result in records being retained longer than required


• Potential downsides

• More line items • Redundancy • Conflicting

retention periods • Harder to maintain


• More line items

• Listing each department’s records individually causes the retention schedule to become very lengthy.


• Redundancy

• Multiple departments may have the same record types.

• Example: • The Benefits Department

and Public Affairs department may both have “Correspondence” listed under their portion of the schedule.


• Conflicting retention periods

• The same record type may have different retention periods depending on the department.

• Example: • Accounting may retain

“Policies & Procedures” for 5 years, while the Human Resources Department retains them 7 years.


• Harder to maintain

• Numerous individual record types increases the potential for maintenance activity such as retention period changes, inactivation and deletions.


• Functional

• Group together common record types that are part of an organizational function.

• Regardless of where the records are created or maintained.

• Lists major functional categories and their sub-functions.


• Functional

RETENTION SCHEDULE OPTIONS (FUNCTIONAL)

• Functional reference document


• Considerations

• Requires a thorough knowledge of business processes.

• Demands a significant culture change.

• Results in keeping records longer than required.

• May result in irrelevant records being placed on hold.


• Knowledge of business processes

• Requires a thorough understanding of the organization’s business processes and the records that are part of the functions, resulting in increased development and research time.


• Culture change

• Requires a shift in employee thinking.

• Employees relate their records to the work they perform.

• Focus not on who owns the work, but rather how the work is processed.


• Retaining records longer than needed.

• Individual records that become part of a functional series may have different retention period requirements (based on governmental requirements) – The retention period assigned to the functional group is usually the longest time period requirement – meaning the other records will be kept longer than needed.


• Holds

• A hold may only need to be placed on one individual record type that is part of a functional record series group, resulting in all records which are part of the group being placed on hold.


• Benefits

• Conciseness • Less maintenance • Eliminates

duplication • Reflects actual

business processes • Promotes standard

naming conventions


• Big bucket

• The newcomer (NARA 2004) • Topic of debate in the RIM

community • Gaining momentum • Takes the “Functional”

approach a big step farther • Typically 4 to 5 retention

buckets, e.g. 3, 5, 7, 10 and 50

• Functions are grouped with similar functions.


• Big bucket

RETENTION SCHEDULE OPTIONS (BIG BUCKET)

• Advantages

• Simplifies classification

• Promotes consistency

• Easier to maintain


• Simplifying classification

• Big bucket retention schedules reduce the number of classification choices that employees have to consider.

• Makes classifying records faster

• Promotes the use of auto-classification tools


• Promotes consistency

• Since classification choices are limited it helps to prevent the misclassification of records


• Easier to maintain

• Maintenance of a big bucket retention schedule is easier due to only accounting for the consolidated functions v. individual record types.

• Attributes of records, e.g. retention periods, and name modifications, change more frequently than changes in the nature of a consolidated function.

RETENTION SCHEDULE OPTIONS (BIG BUCKETS)

• Considerations

• Increased retention • Decrease in

descriptive data (metadata)

• Unable to manage event-driven retention

WHICH ONE SHOULD I USE

• Departmental • Functional • Big bucket

• Considerations • Discussions with

stakeholders • Business owners • Legal • Compliance • Tax

• How regulated is your industry?

• Technology

APPRAISAL METHODS

• Inventory • Interview • Questionnaire

APPRAISAL METHODS

• Keep in mind the retention schedule options.

• Departmental • Functional • Big bucket

APPRAISAL METHODS

• Inventory

• Most time consuming

• In-depth review of record types (physical & electronic) and business processes (functional & big bucket)

APPRAISAL METHODS (INVENTORY)

• Tips

• Like records, not each individual document (hanging folder approach)

• Electronic content – not each file, but each folder • Assumption – the

department has created an effective folder/subfolder structure

APPRAISAL METHODS (INVENTORY)

• Tips

• Functional & big bucket appraisal – start by focusing your initial efforts on understanding and documenting departmental processes and workflows.

APPRAISAL METHODS

• Interview

• Not as effective as the inventory method

• Less time consuming • Meet & discuss rather than

physically inventorying department records

• Probe – get departmental personnel to think about their “total population” of records (physical & electronic)

• For functional & big bucket – discuss business processes and workflows

APPRAISAL METHODS

• Questionnaire

• Least effective and time consuming

• Important! - Development of a comprehensive questionnaire – record types (physical & electronic) and business processes and workflows (functional & big bucket)

DETERMINING RETENTION PERIODS

• Consider the value

• Administrative • Legal & regulatory • Fiscal • Historical

DETERMINING RETENTION PERIODS (CONSIDER THE VALUE)

• Administrative (operational need)

• Applies to most records (depending on how regulated the industry is)

• How long do they serve a business purpose?

• Examples: • Policies & procedures • Budgets • Correspondence

• Retain longer than required by outside entities


• Legal & regulatory

• Retention based on legal & regulatory requirements, e.g. HIPAA, GLB, PCI, DOT, FDA, EPA, FACTA, IRS, SEC etc.

• Additional retention timeframes can be added (in most cases) for administrative (operational need)


• Fiscal

• Determines the usefulness of a record in serving as documentation of the organization’s financial transactions


• Historical

• Involves assigning retention periods to records that document organizational history such as photographs, newsletters and press releases


• Research

• Group effort • Records management • Legal • Tax • Risk Management • Compliance • Business owners

• Records Management should take the lead


• Research

• Important! Understand your industry

• Caution! The Internet can provide guidance, but be wary – each organization has its own nuances


• Research

• Document specific citations

• Software • RIM consultants • CPA • Attorney

NON-RECORD INFORMATION

• Volume is significantly greater than record content • The clutter culprit • Should only be retained as long as it serves a

business purpose • Assigning blanket retention periods

LOOKING FOR APPROVAL

• Stakeholder review • Legal and tax approval • Credibility & defensibility

RETENTION SCHEDULE COMPONENTS

• Record series name • Description • Code • Start code • Trigger event

• Retention period • Retention rules • Media format • Vital • Citation

Note: some components may not apply depending on the type of retention schedule used, e.g. functional or big bucket.

RETENTION SCHEDULE FORMATS

• Departmental • Functional • Big bucket • Narrative


• Departmental


• Functional


• Big bucket


• Narrative

UPDATING THE RETENTION SCHEDULE

• Modifications may include: • Change to a retention period • Record name change • Addition of a new record • Deletion or inactivation of an existing record

• Employ a web form template for retention schedule changes • Develop an approval process for retention schedule changes

• Business owner • Legal • Tax • Records Management

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