Stephanie - I think there have been some great points so far in this
discussion.  Here are a few more thoughts.

1) One of the questions to ask is, are there really different kinds of
records in the same folder, or just multiple regulatory rules? If it's
multiple rules, then the longest should apply.

2) If the folder contains different kinds of records, things to consider
include:

   - Is there a compelling business reason to file these things
   together? (look at legacy folders and new folders to be created)  If there
   is, going forward, is there another way to handle these things so that
   retention can be applied to the parts?  If it's hardcopy, sometimes using a
   pocket folder with subfiles can work pretty well. If it's electronic and not
   in an ECM/ERM system, applying retention to the pieces may not be worth the
   effort.
   - What is the risk associated with keeping some records longer than
   legally required or longer than the business requires? See what the legal
   folks say.

3) Someone in the thread made a comment that in ECM/ERM systems, it's very
difficult to apply different retention periods to documents in the same
folder. I disagree. Today's systems should be able to handle document level
retention if required by your business process. It is important, however, to
look at how the system is implemented to see if it can be done. For new
systems, as a RIM professional, you should be asking, how CAN we apply
retention to records in the new system? How can we help design it so that we
can be flexible and successful?

Opinions my own and not those of my employer.

Laurie Carpenter, CRM
Burbank, CA

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