Guess there's no right of wrong to this, as long as you have  a consistent
set of practices, that's what information governance is all about, right?

Our policy for retention of disposition notices, which goes back to
physical formats of source documents, is to retain them for current year
plus 6 years.  Because the records we're managing are Federal Records, we
follow the GRS, Schedule 16 [item 2(a)(2)] for this.
http://www.archives.gov/records-mgmt/grs/grs16.html

2.    Records Disposition Files.

    Descriptive inventories, disposal authorizations, schedules, and
reports.

    a.    Basic documentation of records description and disposition
programs, including SF 115, Request for Records Disposition Authority; SF
135, Records Transmittal and Receipt; SF 258, Agreement to Transfer Records
to National Archives of the United States; and related documentation.

       (2)    Other records.

        Destroy 6 years after the related records are destroyed or after
the related records are transferred to the National Archives of the United
States, whichever is applicable. (N1-GRS-98-2 item 17)

So, as this was being discussed with deployment of the ERMS, the trainer
was explaining to us there were three options:

Destroy records and metadata
Destroy records and 'select' metadata -(retain for folder, delete for items)
Destroy records and retain metadata

IT said it was obvious, we would destroy records AND metadata.  I informed
them it was less obvious than they thought, because under current
practices, we retain the 'metadata' for CY+6y, and that we would be
required to comply with the same practices for destroyed electronic format
records.  The reasoning is, just becasue we are changing the format the
content is in that doesn't relieve us from complying with existing
requirements for how it is managed.

There were concerns that if during a search the metadata was located
without the records, that could pose a problem... the reason it doesn't is
part of the metadata is a retention schedule code and a destruction date,
which shows why and when it was destroyed, "in the normal course of
business".

What we retain as "metadata" for physical forms of records is: the approved
destruction notice, the actual receipt, and the transmittal/box inventory
for what was destroyed.  This way if there is an audit and records are
requested that have been destroyed, we can produce the records indicating
that WE HAD the record, but that it was destroyed in accordance with policy
and practices.

Larry
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-- 
*Lawrence J. Medina
Danville, CA
RIM Professional since 1972*

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