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Fri, 27 Jan 2012 23:19:44 +0000
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Records Management Program <[log in to unmask]>
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Angie Fares <[log in to unmask]>
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Records Management Program <[log in to unmask]>
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I ran just such a program for RadioShack Corporation which, at the time, had more than 5,000 locations all US States and two US Territories.  The good news is that it is fairly easy to write excel reporting that can quickly help you identify problems areas where you need to follow up.  The bad news is that even the biggest service players in the industry do not have robust systems in place to truly help you manage the risk.  Only one vendor was willing to hang with me for a few years to develop and refine my program to Phase I.  I don't know if they ever made it to Phase II after I left retail, but at least it was a start.

My problem was that, in addition to thousands of locations in "hard to reach" places in towns that were not in any vendors service area, I had a highly volatile work force which made training a major issue.  When a shred vendor doesn't show up on time, a young kid or an inpatient employee with little or no knowledge of privacy laws is going to take chances and dump things in a dumpster.  I know, because I've had to deal with those situations, too, and the lessons learned were invaluable:  YOU MUST MANAGE YOUR RISK WHETHER IT IS CONVENIENT OR NOT.  

First, I set up file plans for my stores and measured their paper output and based it roughly on sales and size of store.  This helped me to determine what the regular service frequency should be.  Second, I used my national store communication system to remind each store at least 10 days ahead of time that the truck was due to arrive and what day it would arrive.  We have tiny, tiny back rooms and cannot put boxes of PII on the sales floor, so the vendor simply has to show up on time as I would expect any vendor to if I hired to fix my appliances or perform any service for me.  There is no room to store records until a vendor can "get to it" or reschedule for a time more convenient to their driver.  In some states, you are required to shred within a certain time period or, because of a settlement, you are required to adhere to a scheduled shred.  In my case, the least frequent service schedule was quarterly.  I developed reports to measure how much was expected in the container and whether or not the container was empty.  If a container was empty, Loss Prevention was immediately notified to audit the store and secure the records.  If more than expected or less than expected occurred by more than 25%, I could ask Loss Prevention to check with the store manager to see if anything was going on that required assistance or perhaps an offcycle visit.  No one was allowed to schedule for any of the stores except myself.    The shred vendor was required to maintain actual proof of service or I would not pay.  That meant a handwritten signature by someone at the store or a unique bar code swipe that could only be associated with one location.  If I challenged service and the ticket could not be produced or if the ticket indicated that the wrong location was serviced, then I got the credit.  The initial failure rate of the vendors 32% to 38% and I ended up firing two out of three vendors for noncompliance.  BTW...the error rate on the billing was also pretty high, so I had to audit that too.  Again, this was managed by identifying exceptions to the performance of the schedule (I did V lookups using the vendor schedule and the vendor billing.  If the service dates didn't match up, I audited the exceptions).

Internally, I used a customer service ticket management.   Each month, we had meetings to discuss how well the vendor performed to the schedule, went to the correct location, and executed the service without incident.  But it took three years of hard labor to get there.  But, I did not have a choice.  My stores were not completely paperless and I wanted the support of a vendor who could provide proof that we regularly destroyed our records or at least made every effort.  There was no way to document an employee who said they stayed late after hours on a Saturday night and shredded records or simply dumped them and said they were shredded (see RadioShack vs. State of Texas).  Many times my vendor would arrive and the store would not have their boxes triaged per the required procedure.  Thieves would break into a store and pry the box open thinking it contained valuable electronics.  Hurricane Katrina damaged about 30 stores and my vendor was helping me pull records out at the last minute.  And, in the end, if I had to investigate an incident, my vendor was there to provide documentation that we had serviced a store.


Not one single shred vendor in the United States has a fully enabled customer service ticket system in place that manages issues or allows you to view your SIGNED service tickets online to verify that service took place. In fact, many vendors simply bill based on their schedule and don't reconcile service tickets at the end of the day.  It is up to the customer to chase them down, complain, and demand that service be provided.  Shred vendors also do not have systems that alert them when their systems schedule a customer on days that your company is closed.  They have to manually adjust the schedules, so that is a constant irritation because they will reschedule up to the last minute and I did not have that margin for error since staffing was slim and many managers would cancel vacations just to be there to sign the delivery ticket.    No single US vendor has the capability to have customers open tickets on a web page, although one vendor is, I think, getting close.  You send them emails and they retype them into another system, thereby creating more room for error but at least you can pull your schedules online.  Only one vendor gave me capability to view my schedules online and would agree to lock them down two weeks in advance.   I literally managed a million dollar account via email and excel spreadsheets, but there is not much else out there until we, the customers, began to hold our vendors accountable for performance.

If you want some of my "risk metric" questionnaires or some help with your rfp and contract, I can help you.  

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