Nolene,
I think you can look at this in few ways:
Customer asks you if you have Internal Quality Control System and can you proof its efficiency - you mention you does and you can show it and prove it. Bank does not mandate , it only says that according to its requirement, based on probably official requirements, bank should prove that follows it.
Customer asks you about custody of the records - you can prove that you are the only who can make decision about the records and your agreement with the Records Centre provider proves it.
All questions customer asks can give additional thoughts how to improve your service and show your management the importance of yourself
This is my opinion.
Regards,
Alex Babin
--- On Sun, 8/14/11, Nolene Sherman <[log in to unmask]> wrote:
From: Nolene Sherman <[log in to unmask]>
Subject: [RM] Customers Requiring Certain Retention Periods
To: [log in to unmask]
Received: Sunday, August 14, 2011, 2:21 PM
One of our customers, a very large bank, has sent us a "non-negotiable" amendment to it's contract. In it is a clause that requires us to keep certain classes of internal control documents for certain amount of time (7 years .... go figure). These are not documents we create specifically for the customer or documents the customer provides us, but our own internal process documents -- mostly QC and regulatory compliance type stuff. Our own retention schedule has retention for the specified classes anywhere from 2 to 20 years.
They also require us to maintain personal custody of documents they provide to us for the term of the contract (I can't recall the exact wording, but I, and our attorneys reading the clause, interpreted it to mean we could not use an offsite vendor).
Our attorneys asked my opinion. I said that it's pretty common, and in fact suggested, that if a third-party vendor maintains records on your behalf you should make sure that the contract contains a clause that requires records to be retained for your retention periods. But I didn't think that a customer should be able to mandate retention for our own internal records. I also thought that if our normal course of business was to send records to an offsite vendor, we should be able to do so as long as the vendor can prove they have appropriate security in place -- such as providing their SAS70 or similar.
Have any of you had a similar request from a customer? How was it ultimately resolved?
Nolene Sherman
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Records Manager since 1996. Gone wonky since 1998.
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