Hi Jamie,

In today's volatile regulatory and litigation environment, I would recommend
folks review their schedules AT LEAST annually as part of a formal review by
your committee.  Even if an annual review ends up being mostly ceremonial
(for businesses that are not highly regulated), it is still worth the effort
to confirm it continues to meet your needs as is.  Three years is a *really*
long time in today's business world.

That being said, your schedule should be a living document that is
constantly monitored by you and updated when necessary, outside of any full
committee review.  If this is not part of your regular duties, then you
should add it.

So, you've got plenty of ammo to sell a review, IMO, including but not
limited to:

1) identified gaps which increase risk and cost, hamper your ability to
defend any lit hold process, etc.
2) your newly formed group agrees that a review is prudent (if your RIM
program has top-down approval and support, then the word of this committee
should have legs)
3) regulatory and risk exposure are a constantly moving target, and you've
already let it sit for three years without validating that the citations
used to set retention periods remain valid and appropriate.  You may well be
at increased risk, not only for the processes and records that were not
addressed by the original schedule (#1 above), but even those that do fall
under a citation but that citation has changed significantly (or a new
regulation takes precedence).  You can't address this exposure without a
complete review.

Good luck!

Julie


-- 
Julie J. Colgan, CRM

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