On Fri, May 2, 2014 at 7:32 AM, Wagstaff, Ellen <[log in to unmask]>wrote:

> Hi. My name is Ellen Wagstaff and I am a list serve lurker. I am in need
> of some advice on rewriting an existing policy on approval for record
> destruction. Currently and historically, our company policy has stated:
>
> "Destruction of official records will be done ONLY after all the following
> conditions have been met:
> -        The approved retention period has expired
> -        Written approval has been received from the originating department
> -        Concurrent has been received from legal counsel."
>


This is one that comes up here pretty regularly, and I can say, without
equivocation.... It Depends.

Every organization does things differently, and this is an issue that
should be clearly addressed in policy... and if you HAVE an existing
policy, and you are intending to change it, you have to ensure any/all
stakeholders are informed well in advance of any changes being made.

Ginny is correct in saying that if your retention schedule was sent on high
to the mountain, and the tablets it was inscribed on have been blessed by
all the powers that be, you should be allowed to implement it without the
need for any further approvals.   And I'm sure that "blessing" includes the
Legal Counsel notifying you of any/all pending or actual litigation as soon
as they know about it to ensure you suspend the destruction of any of those
records, even though the schedule WAS approved.

Others that mentioned means of 'escalating' the request for response are
ALSO correct, if you operate in the paradigm MANY of us operate in.
Records Management is a SERVICE organization, with a splash of Compliance
thrown in for good measure.  Our expenses (labor, space, etc) are paid for
either out of overhead (General and Administrative) funds, or we may be a
charge back organization, recovering costs on a line-item basis for actions
performed.  But in any case, the records we manage on behalf of our
organizations DO NOT BELONG TO US... they belong to other portions of the
organization... we are simply custodians.

For this reason, and I've been in various positions in a multitude of
organizations and industries, Records Management NEVER has made a
unilateral decision, even when we are supported by an approved retention
schedule, to pull records from the Record Center and send them for disposal
without an approving signature from the "owning organization" who sent the
records for storage.

We have never exercised the "implied consent" rule- we have always
escalated within in organization and we inform them that after the 2nd
escalation, if we do not receive a response, we will be physically
returning the records to their custody, for further action. After this has
happened once within an organization, we ALWAYS get our responses by the
second request.  People don't like having 15-50 boxes show up in their
corridors.

The primary reason we wait for at least two cycles is things happen. People
change responsibilities, they go on vacation, they go out for extended
medical leaves... and they may not be able to respond within 30 days.

No right or wrong, it's simply a matter of policy and either being risk
tolerant or risk averse.

Larry
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-- 


*Lawrence J. Medina Danville, CARIM Professional since 1972*

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