>
> In discussions with staff, I tend to let them know that retention periods
> have been thoroughly researched with a variety of stakeholders, including
> the office of record, and our research takes into account any
> legal/regulatory, operational, and historical requirements that may impact
> the retention of these records.
>

It's a good idea to explain to staff the practices behind development of
retention periods, and it never hurts to mention who regulates or requires
how long things are retained, so they understand it wasn't an arbitrary
decision.  In most cases, retention is based on legal, regulatory or
statutory MINIMUM retention periods, and consideration is given to business
needs that may dictate they be retained longer, while avoiding any risk
associated with doing so.

While you mentioned 'historical requirements', few organizations take this
into consideration unless there is an archivist or corporate historian on
staff... many times this is completely overlooked.  So, if it is NOT
reflected in the retention schedule, depending on the nature of your
business and/or your industry segment, you may want to discuss this with
someone.



> I also note that when records are eligible for destruction that only those
> that are required for litigation, audit or open public records request are
> to be excluded from the destruction cycle.


You might want to touch on how staff is notified of WHAT records may be
impacted by these conditions and HOW staff is notified of the need to
exclude certain records from destruction.  Some organizations don't have
well documented procedures/practices for staff notification of the placing
of a destruction hold, and even more so, the lifting of one.



> Make sure you include the caveat that in cases of legal discovery (when
> served a subpoena), audits, etc... you MUST NOT destroy ANY records
> regardless of the Retention Schedule.
>


To add a bit to this, it's ACTUALLY PRIOR to receiving a subpoena...  it's
as soon as you become aware of any pending litigation.  You may hear a
story in the news or from a third party related to a product you designed,
manufacture or sell, or a piece of property you have interests in, etc.
that is being looked into.  If you are aware of this, a notice suspending
destruction should be considered immediately.


One thing I've always done prior to launching into training with any
groups/segments of an organization is send out a request to find out if
they have any questions related to how records are managed within the
organization, or their roles and responsibilities... this can help you
tailor the training to your audience.  And always have a sign in sheet so
you can establish a mailing list of these attendees for future 'refresher
training' .  It also gives you a list of who to notify when policy,
procedures or the RM website is updated.

Larry
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-- 


*Lawrence J. MedinaDanville, CARIM Professional since 1972*

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