Erin,

Even though I have been a member of this list for some time it has been years since I’ve responded so I’ll reintroduce myself. I have been a records manager, member of ARMA and of this list for thirteen years.  Twelve of those years have been with large pharmaceutical companies with mature records management programs that included policies, retention schedules, posted legal and tax holds, education, and annual compliance reviews which included destruction authorization.  Our retention schedules were reviewed and approved by the business owners as well as Legal.

All destruction authorizations were first sent to the business owners for approval and were then reviewed a second time. For those records with tax requirements, as identified in the retention schedule, Tax performed the second review.  There were multiple instances every year where the business owner authorized destruction for records and the tax department overrode the authorization indicating that the business owner was not the best authority when determining if these records were still needed by the company.

As Legal declined to perform a review, all other destruction authorizations were reviewed by the records management staff for information responsive to legal holds. During the discovery and preservation process of each case records were identified, flagged, and prevented from appearing on a destruction authorization report. Therefore the records management staff were reviewing for new or missed records and once again records authorized by the business owner were retained.  In several instances the second review by Tax saved the company substantial money and records management embarrassment in court.

Both Legal and Tax are dependent on information created by other departments within their company. Even in a corporate culture where records management was well known, the business owner was not always aware of or the best judge of what additional value their records held for the company.  In my experience, a second review seems prudent and has proven to be highly beneficial.

Linda K Frisbie| Manager -  Tax Records |Best Buy Enterprise Services, Inc.
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