Aaron-

If you have an RM Program in place that involved a full inventory of
information assets and an assessment of the required retentions for all
records during development of the program, which would generally involve
your legal, tax and other business management team members, the destruction
letter should be perfunctory.

Approval for assigned retention periods should have been agreed upon and
reflected in the retention schedule which is then used to execute the
actions of managing records for specified periods of time, allowing
destruction to occur when retention has been met, in the normal course of
business.  The only exceptions would typically be if there were a legal
action (or known pending action) that would require retention beyond stated
periods, and RM should be 'in the loop' and informed when destruction needs
to be suspended on nay impacted records. 

In some cases, where records have extended retention periods (25 years of
over) and are managed in a central setting away from the actual originating
department after the records have gone inactive, it is a common practice to
generate a 'disposal notice' 30-60 days prior to planned destruction as a
courtesy requesting a signature acknowledging the action is taking place
from the "owning organization".  

These would include box numbers, volumes of records, inclusive dates and
possibly copies of transmittals or indices, and a signature would be
requested acknowledging the action being taken in advance of physical
destruction.  By sending it 60 days ahead of the action, this gives time for
a cursory review and allow the owning department the opportunity to
determine if there are other business needs or legal actions that have not
been stated.  It also provides sufficient time to follow-up and check with
them prior to the files being pulled form shelves and palletized for further
action.  If the owning organization has any concerns about the manner in
which they will be destroyed, this also gives them the opportunity to make
other arrangements for secure destruction rather than recycling. 

While I think it's an excellent idea to make sure you have your 'ducks in a
row' on this, it may also be a great opportunity to think outside of the box
and ask a similar question on what happens to records stored in electronic
form that have met their retention and more importantly, what happens to
things like backup tapes of images of hard drives stored elsewhere.  These
tend to be simply overlooked and in many cases can be more damaging than the
physical format records.  And when they ARE destroyed, it generally is a
simple push of the button... a unilateral action with no approvals or other
actions.

Larry
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