BACKROUND One of the greatest challenges faced by firms when implementing retention rules is effectively managing records that have retention periods predicated upon “event based triggers
Final retention periods in the schedule, however, may be longer than any regulatory retention requirements because they are based on many factors (depending upon the records and function). The set of factors determining retention typically includes (but may not be limited to): Legal/regulatory mandates (minimum retention periods prescribed by law) The longest requirement for records included in that record series
Identify roles Develop a file plan Develop retention periods Determine the scope of the retention policy Design the records repository Develop workflows and methods to move content into the repository Plan email integration Plan for compliance and reporting Keep in mind that you can create policies at the site and document library level
Fewer retention category choices (due to bigger, fewer retention buckets) in a retention schedule can lead to more consistent records management compliance as long as the risks of potentially longer retention periods are taken into account
Start with the retention and legal hold processes: For records, streamline your retention schedule to 50-100 record series/buckets . Julie Gable, Carol Brock, and others (including me) promulgate the benefits of applying the big bucket approach to retention schedules
Related to the aforementioned legal issues is the question of records retention
What I don’t see is a follow-up effort to implement the retention schedule. In a recent project SMEs asked, “What’s the point of updating the retention schedule if retention is not being implemented, and documents are not disposed?” Clearly there are barriers to systematic disposition, and I think the people-process-technology model is helpful in classifying the barriers: People – In-house lawyers are leery of destroying records, even when retention periods have been satisfied
Retention and integrity. This is obvious – but the archive should be able to retain documents for defined periods of time, taking into account legal, regulatory, fiscal, operational, and historical requirements
Review each line with the appropriate Legal expert and determine the appropriate Retention Period for each
For example, technology by itself is not the answer; to make ERM actually work requires building blocks: policies, retention rules, procedures, training, and audit