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Many of us in records management have systematically had department management and staff sign off on records destruction notifications before records were eligible for destruction.  As we talk about implementing a new ERM environment within our organizations, I question whether this process will still be required.

Did you pick up on the reference to the ERM environment?  This is because ERM is more than technology; it is a combination of policies, people and relationships, 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 employees training and required practices classes for your organization. 

As part of the policy and procedure, 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.  If none, they would simply destroy the records.  When you think about it, it seems kind of strange that when records have been identified as no longer having value to the organization, we ask managements and staff 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 their needs and compliance issues are being met.  If the need arises to retain particular records for different periods of time than the initial assessments and decisions, these changes should be brought to the attention of the RM professionals when the circumstances first become known - certainly, not when the records are about to be destroyed. 

You can improve the visibility of the RM program by contacting management 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 are needed.  In this partnership, there should be open communication of requirements between the legal staff, the business staff and records management, again, when the issues first arise. Appropriate procedural steps would be developed and implemented regarding legal hold and discovery and the user community would need to be made aware of, and trained on, what needs done in these situations.  This partnership is reflected in the Information Governance Reference Model found at:  www.edrm.net

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 who 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 would change.

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 records, now eligible for destruction, are.  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 come 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 informed of 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 management and users before you destroy your organization’s records?