Chris, your issue is something I see all of the time.  Even with an understanding of the retention/disposition process many of these SAAS vendors cannot comply with desired/requested operations because their technology does not have that ability.  In other words, much of the SAAS world lacks governance capability.

We have adapted our retention schedule to reflect the realities of the repository.  I know it isn't the best nor preferred methodology.  But the fact is that your retention policy is better off being overly long to reflect what really happens then to declare something that isn't happening.

Isn't this a great example for all of us of the value of IG in partnership with RM?  Why don't we have someone with IG knowledge reviewing these contracts prior to a signed engagement?  Same with new applications brought in-house and even storage devices.  Not all storage devices are created equal.  All engagements, purchases, and acquisitions that deal with storage and retention of information should be reviewed for compliance with the organization's information policy.  I'm not suggesting that you can make all of those comply.  You may very well have to modify your expectations (written and declared) to recognize the realities of the world in which you operate.

It is better to align policies and processes with reality than to represent something that is not possible and cannot be demonstrated.

Glad you made this discovery Chris.  At least you know about it and have demonstrated the efficacy of your disposition processes in uncovering a variance.  At the very least, I suggest you document that you are unable to comply with your own written policy.  No organization is perfect.  I believe, however, that the integrity of your operation is increased when you acknowledge in documentation where you aren't (or cannot be) complying.  How we react to these challenges is the real measure of our program's integrity and character.  And finally I believe that is the application of transparency.


David B. Steward, CRM IGP
Director of Records
 
HUSCH BLACKWELL LLP
4801 Main Street, Suite 1000
Kansas City, MO 64112-2551
Direct:  816.983.8860
Fax:  816.983.8080
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