Graham, I'm glad you asked that question, I was going to bring up the
same issue.
Our company has Legal Approved/Signoff of the entire MFP/Retention
Schedule year couple of years. When items come up for destruction, I
get Division Managers approval. To break it down, our Legal Council
approves the MFP/Retention Schedule to make sure we are adhering to the
proper retention citations or life cycles.
The Division Managers are giving authorization that the records are no
longer needed and that there is no hold against them.
This seems to satisfy our State/Federal Regulations.
Hope that helps.
Tracey Ann Black
Records Administrator
Business Support Services Division
Massachusetts Municipal Wholesale Electric Company
327 Moody Street ~ PO Box 426
Ludlow, Massachusetts 01056
Direct Line: 413-308-1272
Main Line: 413-589-0141 ext. 272
Fax: 413-589-1585 ~ Email: [log in to unmask]
-----Original Message-----
From: Records Management Program [mailto:[log in to unmask]] On
Behalf Of Graham Kitchen
Sent: Tuesday, July 31, 2007 12:39 PM
To: [log in to unmask]
Subject: Re: [RM] Who gives final destruction approval in your company?
Diane:
I don't fit into the category that you mentioned, but I have a question
for
you (and anyone else).
If the lawyer (or Legal Department of the organization in question) has
signed off on the retention schedule, shouldn't it be the organization's
process to notify the areas concerned that the records are due for
destruction and that they have (so many days) to voice any concerns
before
that destruction takes place?
If this is happening, then there should be no delay in destruction
unless
there is a legal situation brewing.
After all, the auditors, legal department, department of record and the
records management department are all parties to the sign off process
for
the retention schedule.
The procedures should state that in the event of government or other
audit,
or discovery, the destruction process will immediately stop. In all
other
cases, the destruction process should go on as planned.
On 7/31/07, Diane Carlisle <[log in to unmask]> wrote:
>
> Please continue reading if you are:
> In a Fortune 500 company
> With a formal records management program
>
> No -- this isn't a trick question! In your experience, have you seen
> effective, records review and destruction approval processes in which
> attorneys did not sign off on the destruction of records?
>
> We have a client who asked us to explore this issue -- they are
concerned
> about the time it will take for an attorney to review and sign off on
the
> destruction of records for a company their size.
>
> We want to ensure that the destruction approval control mechanism will
> stand up in court -- so have you seen other approaches that you
believe
> are defensible? Are you reviewing your internal approval processes,
given
> the new FRCP changes?
>
> Thanks in advance for your time and input!
>
> List archives at http://lists.ufl.edu/archives/recmgmt-l.html
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