Armedia

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 a large number of members in your organization’s different record series categories.  Managed separately this means one retention policy for each individual record type.  If you only have a few different types of records to manage this is not such a big problem but it is especially difficult when you are dealing with hundreds of different types.  Additional complication comes in when you are managing permanent records that need to be archived to another organization such as NARA (National Archives and Records Administration). 

Careful consideration should be taken when creating an electronic retention policy design because trying to manage and control hundreds of retention policies that can have the tendency to change can become unmanageable very quickly.  The support and maintenance cost along with the compliance risk can eliminate your ROI and create a solution that fails to meet the goals for which it was designed.

One way to simplify and try to reduce the overhead associated with managing so many different policies is to group schedules together within your series according to their function or another applicable categorization scheme and their dispositions. 

The following basic strategy is an example of how this can be accomplished:

• Create “buckets” representing the 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.

This concept is probably better understood using a simple example, lets use the following scenario as an illustration:

• You have 5 different high-level record series groups.
• Each series group has 100 individual members.
• The schedule for each member ranges from temporary dispositions of 1 month to 10 years to permanent records with a duration of 25 years or more.
• Each of the record series contain members that share a common purpose or function.

Using this example some basic consolidation steps would be:

1. Define each high-level record series group as a separate “bucket”.
2. Within each bucket you can create categories based on function such as whether the members are administrative, case related, procedural, etc.
3. Within each of these sub-groups you would start to combine your 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 3 months to 5 years you can create a single retention policy with a disposition strategy of destroy/delete after 5 years and include each of these members under the policy.  By doing this you only need a single policy that can apply to 25 members instead of having 25 separate retention policies.
4. Follow a similar process for each high-level record series and you can turn, what was in the case of our example, 500 individual retention policies into a number that is much more manageable making it easier to control and disposition your formal records.

Some items to take into consideration when consolidating retention policies are:

• Work with your records managers and any outside agency, such as NARA, you archive records to before implementation, make sure you have their 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.
• Designing 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 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 err on the side of caution.  Make sure you have the right people involved and do not put yourself at risk.  The goal is to reduce your overhead while minimizing risk and maintaining compliance.  You probably made a significant investment in your electronic records management solution and you need to be sure to keep the protection and savings that a solid design provides.