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Subject:
From:
Larry Medina <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Wed, 25 Nov 2009 12:40:19 -0500
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>
>We have conducted a records inventory and reviewed legal, regulatory and
>business retention requirements.  At this point we would like to identify a
>best practice retention period for records which do not have a retention
>period designated by law.  Three years and seven years has also been
>proposed, but we would like to align with a best practice if possible.
>


Jesslyn-

Welcome to the Listserv, and to the Real World of RM... aka, "It Depends
Land" =)

It may be possible that the description/definition of the record series
you've assigned to these records you can't identify a retention period for
is too specific or that the records may fall into a larger category than
you've assigned to them.

Think more in terms of the function/purpose the records serve (what they
represent or what they're used for) and take another look.  As a starting
point, try the NARA General Records Schedules Index  http://bit.ly/62zRSh
and see if you can come up with a possible category to align the records with.

Also BE SURE that the manner in which your organization views the record is
accurate according to the regulatory agency that establishes requirements
for you... you may be thinking apples to apples, they may be thinking apples
to pears or quince... they're in the same family, but they're quite a bit
different. 

The other thing is the good 'ol "3 or 7 years" periods are a common fall
back, but talk to a number of groups that either produce, receive, or
regularly reference the records and determine a real legitimate business
need for the information rather than falling into the trap of "well, we
might need that" or "let's just keep it 7 years"... if no one can
demonstrate a need that exceeds 4 or 5 years, then there's no sense in
keeping it longer.  And if there's any question, make sure you revisit the
retention period in the future and adjust it accordingly.

As far as "best practice", that's a REAL it depends issue... you might want
to talk to others in the same industry as you that are subject to similar
regulation, others in the State you operate in, or just establish a best
practice for your organization.  Whatever you do, back it up with a review
by legal, operations, audit or any similar components you have to rely on,
and document the decision by a letter to file establishing retention periods
for records by series title, listing examples of the records and the process
you went through to determine the retention period.

Larry
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