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Having taught the AIIM courses around the world, the topic of whether department managers and users should be notified before records are destroyed, within an ERM environment, has only come up a few times.  It leads to an interesting discussion!  For other people, I wonder if this issue has come to your attention, yet, or if we assume we will just carry on with the long standing practice of notifying department staff.  I have the inclination that this practice will no longer be needed.

Do you notice the reference to the ERM environment? That is because ERM is more than technology; it is a combination of policies, people, practices and technology. In an ERM environment, the records management (RM) professionals would conduct sound analysis of the values of the different categories of records. Using these findings, organization leaders would make business decisions on the retention periods and disposition. Your organization should have records management policies and procedures in place supporting these decisions, the importance of which should be stressed in new employee training and regular training for staff. 

As part of the policy and procedures, the central records management function would be responsible for the destruction of the organization’s records. In running the destruction process, they would review the results for any glaring errors that did not make sense.  When you think about it, it seems kind of strange that when records have been identified as no longer having value to the organization, you ask the managers and users for permission to destroy the records.

A best practice in Records Management is that the program should not be developed and operated in isolation. RM professionals need to work closely with representatives from the legal department, business units, and IT to ensure needs and compliance are being met.  If the need arises to retain particular records for different periods of time than the initial assessments and decisions, that should be brought to the attention of the RM professionals when the circumstances first become known.  You could improve the visibility of the RM program by contacting the managers on a regular basis, perhaps, annual, to ask if any new issues have come up with any of their records series. Your program should address the legal departments’ issues when it comes to preservation of evidence in litigation and government investigations and preventing the destruction of records that need to be retained.  In this partnership, there should be open communication of requirements between the legal staff and the business staff, again, when the issues first arise. Appropriate procedural steps would be developed and implemented regarding legal holds and discovery and the user community would need to be made aware of, and trained on, what needs done in these situations.

I appreciate that this notification practice in the past was often due to poor RM discipline and inconsistency in documenting our holdings. With no, or poor, classification structures and with different jargon being used to describe the older records, RM professionals needed to contact the records “owners” to identify the records and sign off on their destruction. The lack of sound and enforceable policies and procedures upfront meant RM professionals needed a mechanism to confirm that there were no issues in actually destroying records.  In the past, I found many business managers were not serious, initially, about making sound retention period decisions because they knew that they would have the opportunity to change their minds at a later time when the records were to be destroyed.  This needs to change – it’s not practical for operations staff to review large quantities of paper files and volumes of electronic content.

In our new ERM environment, using technology with controlled vocabularies, including a classification scheme and a metadata model, the RM professionals would know what those 10 year old, or 40 year old, records were.  If the legal department and the department managers have not brought any issues to our attention in regards to specific records, the destruction process should be carried out by the RM staff as a routine function.

It is vital for members of our organization to understand that records and information belong to the organization, and comes under the control of the organization as they are captured in an ERM system. RM professionals, in their custodial roles, are responsible for the proper destruction of the records according to the approved records retention schedule.  It is clear that the RM function must be part of an integral team that establishes and maintains governance over these corporate assets. In addition, all staff must take on the responsibility of keeping the RM staff up to date with any circumstances that might impact the retention of records.

Do you think you would ever be comfortable enough in your ERM environment to do away with notifying managers and staff when you destroy your organization’s records?

What are your thoughts?