This grey area of contract redlines - where redlines could be junk or could
be as important as the final 'record' contract - is an example of where
records managers must provide leadership by defining record ownership
responsibilities in the RM policy and reiterating those responsibilities in
everyday practice. Records managers must resist pressure to do record
owners' work for them. The same way that a records manager is not the
company file clerk, the records manager is not the decider of the value of
every company document. The record owner is the SME of the business process
of which the record is a by-product. RM policy must assign record ownership
roles to a specific job role, somewhere in the company org chart and state
that record owners are responsible for deciding what is a record and what
is not. That role assignment function is the most important function of RM
policy - ISO 15489 says so loud and clear. Without role assignment for
record ownership, a policy is just meaningless platitudes that are
unenforceable. If you have a meaningless-platitude policy then don't be
surprised when people dump records at your door to define.

In everyday practice, the records manager needs to get comfortable
responding to questions about whether a given document is a record by
asking 'who owns this record?' and reminding everyone that ownership
responsibilities are defined in the RM policy. Then the records manager can
offer to help teach the employee how to identify their records using record
class descriptions in the retention schedule, asking questions about their
business process, explaining legal holds facing the record owner. The
records manager might end up doing the work, for example if in-depth
analysis of litigation risk or regulatory risk is needed, or when the
question must be put to an attorney to decide, but the default should not
be that employees or IT dump records or data on the records manager to
define for them.

This role of records managers may seem obvious to records managers but
needs to be explained over and over to everyone else across the
organization.


-- 
Maureen Cusack
San Francisco, CA
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