Hi Med, we've faced a similar issue in that we use a number of 3rd parties who host some of our records. First, we try to make sure that all applicable records are identified in the contract with that 3rd party vendor, and the retention requirements are addressed, including whether the vendor will destroy our records, or whether they are returned to us for final disposition. Just as a side note, we also address what is to happen to our stuff if the vendor is acquired by someone else, [significantly] changes their corporate structure, or goes out of business.
On our records retention schedules (RRS) we identify the office of record for each records series--and it can NEVER be a 3rd party! We educate our offices of record that it is THEIR responsibility to manage the records throughout their lifecycle and according to the RRS--regardless of whether they are outsourcing certain functions/processes to a 3rd party or not. So, in your 1st scenario, we'd identify HR as the office of record and it would appear on their RRS.
The 2nd scenario is a littler trickier, but we'd identify Business Unit A as the office of record, even though the records are processed by Business Unit B. It'd be my opinion that Business Unit A is till [ultimately] responsible for those records. We face something similar with some of our operational records, that re "shared" by multiple departments or functions, each adding a different piece to the same records. We had to draw a line in the sand as to who was ultimately responsible for it, and in negotiating with all concerned, we finally did--though not everyone is completely happy with it.
Thanks, and I hope this helps.
Earl
Pipeline Records and Information Management Excellence... Get PRIMEd!
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Earl Johnson, Jr., CRM
Corporate Records Manager
Colonial Pipeline Company
1185 Sanctuary Parkway, Ste. 100
Alpharetta, GA 30009
Email: [log in to unmask] | Internet: www.colpipe.com
Office: 678-762-2586 | Mobile: 404-402-4420 | Fax: 678-762-2315
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