Well said, Larry: "when you NEED TO FIND SOMETHING, the
fewer buckets it's in, the deeper you have to reach and the more water
you
have to disturb to find something."
Overall, I think there is some appeal to fewer buckets. Here's where I
see some of the challenges when implementing huge buckets: In general,
if the legal requirements for a subset of the big bucket changes, it may
not be possible to easily separate the bucket back out. If you take a
bucket of yellow paint and a bucket of blue paint, it only takes a few
seconds to mix them together into one green bucket. How long and how
much would it cost to separate it back out?
Electronic, you'll be heavily relying on metadata and terminology for
search terms to find information, especially for litigation purposes.
Applying legal holds may be more difficult if everything's just lumped
into the "accounting" bucket but people haven't used consistent or
"good" terms to define the information. Or, maybe the item type isn't
full text searchable.
For hardcopy, long-term in a distributed environment where
sites/departments are sending their own stuff to storage, I think you
run the risk of people NOT labeling box contents well as time goes on.
Intially, people who'd been around during the old system would label the
box "ACC01 - Bank reconcilliations, April 2007"; and the second box
would be "ACC012 - Invoice Copies A-C April 2007" but, as time goes on,
the new people don't remember there used to be different codes, they're
all merged into ACC01. Maybe intially, you get the buy in for both boxes
being in the ACC01 bucket and labeled correctly. As time goes on,
though, people don't know they are supposed to store different
accounting functions separate or they don't use the same terminology.
So, now, you end up with "ACC01 Accounting 2015" and the box might
contain reconcilliations AND accounts payable AND may include more
months. Then you have a litigation matter. The request is to find all
invoices paid to ANYCO in April 2015. There are hundreds or even
thousands of boxes from 2015 related to accounting functions, but
they're all marked Accounting 2015. The company has to pay legal people
to review all the box contents to try to find the needle in the
haystack. Maybe if you have a really, really solid training and audit
function, it could work, but I've found people do better if they have a
code to pick from.
Ways around it I've heard suggested include keeping both the old (the
"crosswalk") and the new schedule or keeping a different schedule for
hardcopy than electronic. Personally, I think that might do one of 2
things: 1) confuse the heck out of the end users or 2) shift the burden
back to a centralized records function that may or may not have the
staff handle it.
One thing I heard at conference was about big buckets and applying event
based retention. While the number of buckets were few, some items within
the same bucket were year based and others event based. It was a very
labor intensive process, to apply retention to the event based files.
Once again, shifting the burden back to records staff...
Getting back to Larry's point, and one made after his, that in huge
buckets, it might be hard, but in "large" buckets that are smaller than
"huge" but bigger than old style schedules, there could be efficiencies.
What do I mean by that? Suggestions of 100-200 buckets vs. 3 buckets on
the "huge" size and 4000 on the "tiny" size might be very doable for an
organization.
The points also made about getting involved with the vendors and IT are
also great ones. Check these things out and develop your opinion. Once
you've developed your opinion, speak up to the vendors if you don't like
the big bucket approach, your voice needs to be heard before the
industry is stuck with something that doesn't work for us because other
people were asking for it and the market responded... If you do like it,
great! I'm sure the list would love to hear about successful
implementations.
Laurie Carpenter, CRM
Compliance Manager
Koch Industries, Inc.
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