Julie Cogan's and John Montana's comments are excellent.  

Two of the biggest problems that I have observed are the (1) Lack of
Inventory and (2) developing a retention schedule based an association
and/or limited retention requirements in a Federal/State regulation.  

John's example of using the NARUC to create a  retention schedule without an
inventory of what actual records are being created is records management at
is worst.   If you look at 18 CFR 125.3 or the NARUC you will see that is
does not reflect or has extremely limited records series that you would find
in a utility.   Example:  No reference to Safety, Environmental and limited
entries for Human Resources and other functions.   In addition, the
retention periods reflected in the NARUC are based on what the association
has gathered from its membership and uses the longest retention period
reflected by a members state.

I believe the NARUC is a good reference and starting point of what records
you will find in a Utility, but it definitely doesn't reflect all the
records being maintained.  In addition, the associations publication does
not reflect the legal citations that requires retention cited.   

Good topic.....


Robert W Dalton, CRM
Dalton Consulting
253-229-4555
[log in to unmask]


From: Records Management Program [mailto:[log in to unmask]] On Behalf
Of John Phillips
Sent: Saturday, November 17, 2012 5:06 PM
To: [log in to unmask]
Subject: [RM] Pondering lawyers' minds - RE: Friday Pondering 11-16-2012

John,

Just out of curiosity - when a "typical lawyer" (Inside/Outside Counsel)
tells their management/client that they have created a retention schedule,
what sources/processes do you think they used? I often hear Corporate
Counsels in small organizations say the "did" the retention schedule
themselves, when they often seem marginally informed about records
management in general. I doubt any of them used Retention or Retention
Manager software, for instance.

John

***************************
John Phillips
Information Technology Decisions
www.infotechdecisions.net


-----Original Message-----
From: Records Management Program [mailto:[log in to unmask]] On Behalf
Of John Montaña
Sent: Friday, November 16, 2012 9:52 PM
To: [log in to unmask]
Subject: Re: Friday Pondering 11-16-2012

Absolutely.  If someone claims they've found every single requirement in the
country, either they're fibbing or they don't know what they're doing.
There's no way to even know such a thing, much less guarantee it.

John

Sent from my iPhone

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