On Wed, May 15, 2013 at 11:26 AM, Tod Chernikoff <[log in to unmask]>wrote:
> And to make the waters even murkier in some instances in the public realm
> that I have seen, some agencies consider the background material
> non-records/working files once the policy/schedule is approved, and subject
> to faster disposition - eliminating background material some may consider
> important. One current public client keeps this type of material
> (transfer/disposition lists as well) for three years after approval/action.
> The other public client conforms to GRS 16/2.
>
> Tod Chernikoff, CRM, CIP
>
If you are a Fed Agency, and you want to deviate form cited requirements,
you either have to submit a "Mother May I" request to NARA, or take a
chance on doing something counter to the Regs.
If you are a Contractor to a Fed Agency, you have a little more leeway...
but not much. You can keep ANYTHING YOU WANT longer than required, citing
business needs as the reason why. No need to ask permission, you just add
it into your schedule under disposition actions./instructions. You cite
the Fed requirement as your "Retention Instruction"... then in disposition
you cite. "Retain for X after retention is met, to satisfy business need"
And yes, you CAN destroy the background material, but in our case BECAUSE
the Agency does (and has nothing to go back and refer to) we retain it in
the event of an IG Inspection when we are asked "if the retention is X, why
don't you have that?" we can then say "because when that record was
generated, the retention was Y"
This is going to become EXTREMELY important if/when the proposed new GRS
are issued, because the lack of a clear crosswalk at this point and the
SEVERE aggregation of retention periods is going to result in utter chaos.
*********
AND SPEAKING OF THIS... I'm sure there are a wide number of individuals
that at one time or another have been subject to the Federal retention
instruction of "retain for 6years and 3 months" associated with certain
financial related documents? Were any/ALL of you given the same
understanding that I was over 15 years ago that the period was based on
addressing the difference between the FFY (Federal Fiscal Year) which
begins on October 1st and the calendar year, which ends on December 31st?
I was shocked to read what the REAL REASON was for the 3 month differential
and I'm curious did ANYONE know that this wasn't the reason for it?? (I'll
let you ruminate for awhile before posting the true reason)
*********
Larry
[log in to unmask]
--
*Lawrence J. Medina
Danville, CA
RIM Professional since 1972*
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