Every time this discussion comes up I find it interesting to see the variety
of responses and how they are similar but different.  Sometimes it's related
to wheter the institutions are public or private, other times it's based on
the regulatory climate they're in, and sometimes it's the functional area
the RM organization reports to.

In all situations I've been in one of the principal considerations is while
there MAY BE a retention schedule that has been approved by a committee made
up of multiple facets of the organization at one time or another, the
retention schedule is:

- a basis for establishing an organization's obligation to retain information
- a guide that sets the minimum required retention period, and may also
reflect other factors that allow retention beyond that period, and
- a living document, subject to change for any number of reasons

I haven't ever had the luxury of working in an organization where RM was the
"owner" of the records, or the content contained in them.  The records have
always been an organizational information asset that RM had 'custodian
control' over and managed them as part of providing a service to the
organization.  And while we were in part responsible to notify the owning
organizations that the records had met their assigned retention, we NEVER
made the decision directly to destroy them without an approval signature.

In our current scenario, contacts are made twice with the owners (our lists
are verified twice annually to ensure contacts are valid), and if no
response is received, a third contact is made with the department head (cc
to Legal).  If there is no response following the third contact, the records
are delivered back to the owners for further processing.  Automatic requests
for extensions of retention are not approved without a justification, and
the longest extension granted is one year, absent a legal hold.

A number of people have mentioned legal actions that may require suspending
the destruction of some records for a period of time, and a need to review
records to ensure they are not improperly disposed of when this occurs.  

Part of the problem is many organizations DO NOT HAVE mechanisms in place to
make rapid notifications throughout the organization to ensure this happens
in real-time.  And if the word doesn't make it through the system quickly
enough, in some of the cited examples given, records COULD/WOULD BE
inappropriately processed for disposal.  

There may have been reorganizations resulting in functional units having a
different reporting structure since the records were sent to storage, and no
one has gone that far down the line to consider changing the record
relationships.  There may be business plans that will require access to
records that were planned for destruction and no one has had the opportunity
to determine what records are in storage that are impacted by this.  There
could be a merger or acquisition planned that results in a portion of the
records being impacted and needed to transfer to another firm, but no one
has determined that yet.

Does it REALLY make sense to simply follow the retention schedule and
destroy records that you are managing on behalf of others without their
direct approval?  I can't think of too many cases where it does, and as
mentioned by many of my colleagues the "records officer/official" isn't the
person who is held responsible if the policy and procedures clearly document
the actions taken, so "no harm, no foul" if you didn't receive the approval
and the records are still in storage.

In the words of Alex Carras "Mongo just pawn in great game of life..." and
when it comes to making decisions about assets that belong to others, most
RMs hold a similar status.

Larry
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