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Subject:
From:
"Roach, Bill J." <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Thu, 13 Oct 2005 07:52:09 -0500
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>>All records scheduled for destruct are reviewed by legal.<<

Legal reviews those that were associated some kind of
audit/investigation/litigation hold.  However, records that have never
had a hold would be reviewed by legal prior to destruction.  The
Retention Schedule is the authority for disposition of records.  Legal
should review exceptions.  As we move forward with comprehensive
retention schedules we need to avoid the concept that functional manager
"approve" disposition of records.  Their role is to identify  records
that may be exceptions to the retention policy so the group responsible
for retention decisions can evaluate the need.

>>No need to go back to the other organizations again.<<
I have seen several instances where this process would have failed.  In
each case, the information being retained was subsequently needed for a
future audit, investigation, or litigation.  At the time the records
first would have appeared on the disposition schedule, the functional
areas would have signed off on disposal.  However, by the time the
original actions were resolved, new actions or activities required
further retention of the documents.

Bill R

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