Earl - So mant things to address in this question... Here is a short list
to cause you to ponder...

1) What does the records policy state?
2) Are folks notified annualy that they are to comply with the policy &
related records retention schedules?
3) Do you have an audit monitoring process in place?
4) Does your routine training address the responsibilites and accountabilty?
5) What does your disposition procedure read?
6) Do you have a formal legal hold/release process?  Do the folks who are
on hold receive reminders?
7) Don't forget regulatory or tax holds...
8) I am a big fan of wholesale destruction orders (after
confirmation/signature with tax and legal) for this very purpose... i.e.
A/P Invoices (2005 and prior), HR Personnel FIles (TR+2004 and prior) with
sign-off REGARDLESS of the location or media.
 9) Is there any process for attestation for routine destruction of
physical and/or electronic documents?

DIane Walker, CRM, CMC
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