On Tue, Nov 8, 2011 at 7:31 AM, Nancy Ur <[log in to unmask]> wrote:

> I've found
> redundancy in both paper based and electronic records collections,
> sometimes with disparate retentions (for the same record type) or the
> dreaded "perm" tag.
>

Differing retention periods assigned to identical record series can be a
real problem... and should be resolved as soon as possible.

The primary issue is it calls into question all retention periods because
you can't show the basis utilized for establishing them.

In business, as long as you satisfy the MINIMUM required retention set by
any statute, regulation or law, anything beyond that is completely up to
the organization... and if you elect to retain them for a shorter period,
well... so is that... but as discussed last week, either case involves a
'risk based decision'.

Is there any potential risk in keeping things longer than you have to?
Sure... if the records contain potentially harmful information, in
discovery there is the requirement to produce them if you have them.

Is there a risk to discarding them early? A similar risk... requiring the
organization to explain why they discarded them, and potentially having to
face fines, sanctions or penalties associated with not being able to prove
their position on an issue.

As for the 'dreaded permanent', again it's a risk based thing.  If the
decision is it's less expensive to just keep everything forever "just in
case" or because establishing and policing a retention schedule is too much
effort then someone has to weigh the cost of finding a needle in a haystack
and/or responding to a data request if one is received.  And again, the
potential damage of having to produce records that could have been disposed
of "in the normal course of business".  And there's the cost of space,
equipment, labor, storage, etc.

Permanent should require a justification- not just from the individual who
wants to keep it, but at a corporate or organizational level.  In the
Federal Government, there is a clear definition of what records should be
kept permanently... in business, much of it is subjective. And because it
is generally an individual that makes a unilateral decision to apply the
requirement, when that individual is either no longer in the role they were
in, or no longer with the organization- how will anyone else know what the
basis for the decision was?

The worst case is applying permanent to electronic forms of records.  The
cost of periodic migration and conversion to avoid obsolescence of
software, hardware and media to ensure persistent access over even 10-20
years can be staggering, depending on the format it resides in, volume of
information, access patterns and other issues.  A failure to adequately
scope the cost and effort to maintain any electronic content 'permanently'
and not ensuring funds are budgeted annually for curation will almost
always result in loss.

Larry
[log in to unmask]


-- 
*Lawrence J. Medina
Danville, CA
RIM Professional since 1972*

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