Nolene

No direct experience but I have had customers do an ISO 9000-style QA audit
prior to deciding to go ahead with a contract.

If they are a large and important customer, do whatever they ask! This
translates into a business requirement to keep records, which is the primary
function of any retention program, and if the law, or your current retention
rules say keep a lesser period, business need overrides that. Note I say
'lesser'.

So it's not the CUSTOMER mandating anything, it is one of your front line
businesses mandating something on the basis of an agreement with a customer.
It's their call (the business unit, not the customer), and RM meets that
need, adding any additional compliance period if necessary. (There may be
situations where the law requires disposal after a certain period, but these
are exceptions. We have a few here in Australia, mostly health-related,
where the specified retention period is a maximim as well as a minimum, but
the vast majority of compliance requirements are minimums not maximums)(and
yes, I know my Latin).
And I think your lawyers are wrong. If your company takes 100%
responsibility for the records in question, what business or legal need has
the customer in where you decide to put them? If they were electronic, and
you put them geographically elsewhere in your organisation, maybe even
overseas, or with a hosted service or somewhere on the cloud, it's no
business of the customer. The customer may demand to see the setup (examine
contracts, site inspections etc) but you take responsibility. Do they insist
on paper? Can you go electronic? Ask your lawyers to generalise thier
thinking a little bit.

Cheers
Glenn

Glenn Sanders
Australia
0407 187 333
These views are mine alone. They may or may not be those of any
previous or present employers or clients. I don't know. If I'd asked and
they'd agreed, I would have signed it "Harry Peck and Co and Glenn".
Or whatever. But I haven't, so I didn't.

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