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Subject:
From:
Sam McCollum <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Wed, 24 Oct 2012 16:54:21 -0600
Content-Type:
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Nolene,

   The permanent retention of some documents is the favorite choice of the
'responsable business unit' or RBU when we meet to consider the operational
requirements related to information retention. The problem with this option
is that it is an easy out for those RBU's that don't want to be bothered
with providing dates for that information with the retention is based on an
event date (such as retirement, asset de-commissioning, or expiry of
contract). However, keeping information for 100 plus years is usually not
only expensive but exposes the organization to unnecessary litigation.
   We have resolved this issue by changing the status to 'Permanent with
review every 5 years'. This means that we send a list of information with
this retention designation to the RBU every five years and ask them to
update the event date or confirm that the retention is still 'Permanent
with review every 5 years'.
   The effect of this process is that those RBU's that insist on permanent
retention for operational reasons need to justify their decision every five
years.
   It has been my experience that no information has to be kept
permanently. The retention is always based on an event, and is usually only
kept for 7 (financial) to 10 (legal) years after that event date has been
reached.

Sam McCollum, CRM

On Wed, Oct 24, 2012 at 4:34 PM, Nolene Sherman <[log in to unmask]> wrote:

> We are updating our retention schedule and are refining record categories
> relating to HR benefits. Particularly we are separating categories for
> health and
> welfare benefits from those for retirement benefits, since we feel the HW
> stuff
> can have a much shorter retention period.
>
> Our company engages an outside counsel to work with us for our retirement
> issues. The attorney has cited ERISA sec 209 and its "open-ended" retention
> requirements (as long as needed to determine benefits) and recommends a
> permanent retention for anything related to retirement benefits. We're a
> 120-
> year-old company which will presumably stay around for a lot longer, so
> permanent really is a very long time for us. We understand that retirement
> related problems usually don't surface until the person retires, but we're
> thinking a 60 to 75 year retention (from termination of employee or
> termination
> of plan) should be sufficient to cover 99% of any issues that may come up.
>
> I'm curious to know how other companies have scheduled retirement related
> records and what the thinking is behind their choice.
>
> Nolene Sherman
> [log in to unmask]
>
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>



-- 
Sam McCollum, MBA, CRM, ERMm
President and CEO of SIMC Coaching
RIM Professional since 1983
[log in to unmask]
*Coaching you on your way to success*

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