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Date: | Thu, 24 Jul 2008 14:15:00 -0400 |
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Steve:
Other than the RAIN articles mentioned, I can't think off hand of any
examples. There is no law against extending a retention period (unless
you are a government entity and even that is very, very, rare).
Extending retention is internal policy. Most non-compliance
ramifications will be based on internal policy - that is, when you put
your policy requirements in place you need to also establish and state
penalties for non-compliance because of risk. If you do a risk
management analysis for non-compliance, you can use it to support the
issue.
The risk management analysis could include:
1. Costs to find documentation during a legal search (discovery,
subpoena, court order, etc.). The more "expired retention" material you
have, the more you have to search through.
2. Risk of the wrong version of a contract being referenced or used.
This happens when folks keep the old, expired contracts along with the
current contracts. Depending on the kind of contract this can become a
costly legal or fiduciary issue.
3. Costs to house the expired retention material. Office floor space is
costly (and constantly buying file cabinets and file supplies can add up
in a hurry) and the more material there is, the more costly space is
occupied. RIM should have control over what is sent off-site to
inactive records storage and policy should give you control over not
accepting expired retention records. This throws the cost of storing
the old stuff back on the dept not following the schedule.
Ginny Jones
(Virginia A. Jones, CRM, FAI)
Records Manager
Information Technology Division
Newport News Dept. of Public Utilities
Newport News, VA
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