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Date: | Fri, 19 Sep 2008 12:04:56 -0400 |
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> ... I believe you missed Judy's point. You have a legal requirement
>(minimum) and a organizations business requirement which may be longer than
>the legal requirement. She had to explain why her records were retained
>past the organizations business requirement. Didn't destroy per her
>retention schedule.
And this is a common problem with extended retentions (the that surpass the
published period for destruction). Most RRS include:
A record series code (number/alpha)
A series title
A description of the series, that may include examples
A citation of source for the retention period
A retention period
AND... A disposition instruction
This last component is the most important one, because it tells you what to
do with the records once they meet the required retention period. It could
state:
Destroy by shredding
Destroy by recycling
Transfer to Archive for Reference
Return to Owning Organization for Review
Destruction Moratorium imposed, Do not destroy until lifted
So you may have records that are supposed to be destroyed 6 years and 3
months after they were issued, but if there is a legal case pending that
places a moratorium on destruction, then you don't destroy them.
If an owning organization is involved in R&D related to a record series and
may have an ongoing need to a portion of the records in a series, and you
return the records to them they will determine if the records need to be
transferred to a different series with a longer retention and the "clock
starts ticking" all over for these.
By having this disposition instruction as a component of the retention
schedule, if during an audit records are found that exceed the retention
period, you can clearly explain why they weren't smiply destroyed and still
be in compliance with the schedule.
Larry
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