I’ve been away from the Listserv for awhile trying to create an RM program for a national company operating in all 50 states. Steering the Titanic doesn’t begin to describe it, so we are taking baby steps.

The first phase of our program is establishing the network of coordinators for our 15 divisions and 800+ offices (THAT’S like painting the Golden Gate Bridge, to use another tired cliche) and getting a handle on paper records. Our retention schedule applies to all media, but we are not enforcing destruction of unstructured or structured data yet — we will be looking at ECM systems and other programatic ways to handle that in future phases. However, IF an office needs or wants to destroy electronic records, it must be done in accordance with the policy. Our procedures do not require a long list of approvers for destruction — the retention schedule was researched and approved by executive management. We have an attestation form that is completed by anyone destroying records that they did their due diligence and records destroyed were eligible and not subject to legal hold. 

My question is about destruction lists. The General Counsel does not really want to make employees create lists of documents destroyed … he’s of the mind that if the retention period for a document has passed and the document does not exist, then he can argue that it must have been destroyed according to the schedule. I said that people are not comfortable destroying things without being able to prove it, so he has relented and will allow the person destroying the documents to create or keep a list if they want to — he just doesn’t want a policy saying they must. 

My concern is the inconsistency of it with some having lists and others not. I can see that if offices have an index of stored records, then they are likely to use that to create a list of destroyed cartons. But since few offices keep indexes of records in their offices, records that meet their retention without ever being stored are not likely to be listed. I also have several paperless offices that want to start manually destroying unstructured documents on file shares. Those are also unlikely to be listed. There is also the situation of clean-ups for office moves, acquisitions, mergers or divestitures.

So here’s my question: In my procedure documents, do I say they have an option of attaching lists of destroyed records to the attestation; do I say that if they want to attach a list of destroyed records they must include all records destroyed — those in storage, in their office and any electronic records, if they choose to destroy those; or do I just say they must complete the attestation and stay silent on the matter of listing the records destroyed.

Nolene Sherman
Corporate Records Manager
Really Big Company
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