Mary Beth, let me compliment you on identifying this as a real issue.  I have seen the same problems, especially with products like SAAS.  All too often these systems fail to provide the governance tools to be compliant with our own internal policies.  It is a good case for IG and the role it can/should play at the design and procurement level.

But let's be honest here; most departments are not going to allow an IG policy to keep them from signing up with a product if they believe it is right for the organization.  We will usually have to live with the results.  That is why I agree with your statement of changing retention to recognize the reality of your circumstances.

No one is going to be suspicious if your retention changes from something like Term plus 10 to permanent when you explain in your retention documentation that you are doing it to meet the restrictions of the application.  I believe it enhances the integrity of your program.  We have done the same thing at my firm.  It was for an HR application.  But having an incompatibility between your policy and the auditable real-world information is a big red flag.

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
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