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Subject:
From:
Larry Medina <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Fri, 16 May 2008 09:26:07 -0700
Content-Type:
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On Thu, May 15, 2008 at 1:46 PM, L Carpenter <[log in to unmask]> wrote:

> I'm looking at retention periods and how to make them more usable and user
> friendly. The basic premise is rolling out retention rules to the average
> user who may have no previous exposure to records & information management
> or a retention schedule. For basic retention periods, not too hard to do to
> put them into more common language than RIM speak. But, in trying to
> implement retention periods where there are 2 or even 3 conditions that
> must
> be met, I thought it would be good to see what ideas my list serv
> colleagues
> have.
>

"Event plus", or "triggered event plus" retention periods are very hard to
enforce and describe in most systems, much less explain or defend in the
event of a discovery or audit.  For one thing, you must document on a case
by case basis the occurrence of the event or trigger, AND you must be able
to clearly identify what set of records this applies to... and you must make
sure you identify ALL records.  Failure to properly manage this process can
result in claims of early or improper destruction of information, and at
minimum, inconsistent application of retention policies, which can call all
of your practices into question for the balance of your records retention.

Additionally, most retention modules related to content management
applications do allow for event plus scheduling for records stored in
electronic formats, but they aren't very intuitive.  In some cases, it may
be best to determine the SHORTEST POSSIBLE retention period, with a second
action being "review prior to disposition" and then re-schedule them for the
LONGEST POSSIBLE retention for these records and assign them this period,
then in the instructions field, give some qualifier of review for possible
legal need prior to destruction.

Most of these decisions need to be based on a careful consideration of the
risks as opposed to the benefits and then retention is set to meet the
regulatory requirements (as a minimum) plus any other business needs  beyond
that.

Larry

---
Larry Medina
Danville, CA
RIM Professional since 1972

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