Let me clarify again.  Nowhere in my original post did I say that I asked NARA about this issue.  When finding records that aren't in a RCS, then I have to fill out a Records Inventory Form, which asks this question: Does the series have an approved disposition authority?  Answer Yes or No. 

Yes: (List the schedule and item number, give the current disposition instructions, and justify any proposed changes.) 

No: (Propose an appropriate retention period.)  

That completed Records Inventory Form is attached to the SF15 when submitted NARA.  I apologize if I wasn't as clear as I should have been.  

Again, sorry to the folks that aren't Federal agencies.  I just want to acknowledge that I enjoy and am glad that I can network with fellow Records Managers outside the Federal arena.   Now let's all have a group hug!!


Dawn Cooper
Program Assistant
National CMOP IT Program Office
3675 E. Britannia Dr.
Tucson AZ 85706
520-209-3009
 


-----Original Message-----
From: Records Management Program [mailto:[log in to unmask]] On Behalf Of Steven Whitaker
Sent: Tuesday, May 19, 2009 2:03 PM
To: [log in to unmask]
Subject: Re: Question on retention of software licenses

I was not snarking.  I defined the systemic and objective method to
develop retention policy.  I did point out what could happen if one is
asked to define their retention policy methodology by a court or
regulatory agency.  The USA Nuclear Regulatory Commission and the USA
Internal Revenue Service do not mess around, and they do not smile.  I
have testified in front of both.  Other agencies can be humorless too,
like the Securities and Exchange Commission.  It is unsound business
practice to ask others how long they keep their records, and then adopt
something similar.  That is not defensible anywhere.  It also does not
serve your organization because it does not account for your systems,
workflow, procedures, audits, practices, state reqs and local
requirements, if any.  Your retention policy needs to serve your
organization's needs, and protect your organization by satisfying
federal, state, and local regulatory agency requirements.  

How does the USA federal government develop retention policy if they do
not do so using these factors; operational, fiscal, legal, regulatory,
historic?   Any USA fed folks out there?  Tell me how NARA develops
retention policy for agencies, if they do.  Then tell me why a fed RIM
employee is asking the listserv how long others retain records instead
of simply being able to put the request in motion for the NARA RIM
policy makers to develop the policy, since it is apparently not covered
in the VA retention schedule.

I feel for Dawn Cooper.  She asked Nara how long the Veterans
Administration was supposed to retain certain records, and they had no
answer.  Also, apparently they asked her to make a recommendation.

Bruce White CRM, PMP, you used to work for NARA years ago.  What was
the process for developing retention policy?  And..., were they blowing
off Dawn instead of simply taking care of her needs by developing the
policy?


Best regards, Steve
Steven D. Whitaker, CRM
Records Systems Manager; City of Reno

>>> [log in to unmask] 5/19/2009 1:09 PM >>>
<snip>
Finally, I agree with Steve's point to the extent that NARA should be
asked,
but I read the initial question as NARA's having been asked and not
having a
better answer. I think the question that was asked was for this group
to
weigh in on a) current practices and b) the reasoning behind them, in
part
to inform that very decision. So with all respect, Steve, I think the
snarking is not really called for. You are of course correct in your
approach, but I see the list as just as defensible in the sense that
you'd
tell the judge, 
<snip>

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