Brett, by "Review/Authorization Process for Records that are eligible for retention" do you mean a process that takes place IMMEDIATELY BEFORE the disposition of a specific set of records at a specific time?

If so, my current practice is we do NOT seek such authorization; it was provided at the stage when the records retention and disposition schedules were developed.

In the past, I did have to deal with such a process, and it was AGONISINGLY slow (as in, years), as no fewer than 17 distinct unit heads in the legal department had to review and approve it. This process was, for them, at the absolute bottom of their list of priorities, thus accounting for the delays.

I'm leaving aside holds for litigation, regulatory requirements, and audits, which are exception-based situations.

Best regards,

Fred
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Frederic J. Grevin
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212-312-3903 (w)

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