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Subject:
Re: Fw: Third Party Management
From:
Larry Medina <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Tue, 23 Jun 2015 07:27:11 -0700
Content-Type:
text/plain
Parts/Attachments:
text/plain (62 lines) 
On Tue, Jun 23, 2015 at 7:06 AM, Gary Link <[log in to unmask]> wrote:

> No one? Really? 2600+ people on this list and not one of you helps your
> organization determine if third parties are custodians of your records?
>

Silence does not ALWAYS indicate agreement.

Some of us are unable to speak about these types of issues, except in the
broadest sense.



> Hmmmm.
> I had hoped to exchange ideas on criteria used, standards, processes, etc.
> But apparently I'm the only records manager in the world who does this. So
> I guess I'm on my own....
>

External suppliers and subcontractors (above a certain financial threshold)
have conditions included in their contracts they must comply with for the
management of records in accordance with the Federal Acquisition
Regulations (FAR) and they are responsible for either maintaining certain
records as long as NARA requires, or on closure of the agreement, turning
the records over to us for subsequent management.

We periodically audit their compliance with these requirements and in RARE
cases, when we are undergoing an IG audit, those auditors may elect to do a
'spot audit' of some suppliers/subcontractors.

1. Does your organization have a formal third party/supplier/vendor
> management department or infrastructure or process?
>

So in the context of "records generated related to work performed under
contractual obligation"?  Yes, we do.

2. Are you, or someone in your records program, formally part of your
> organization's vendor management operations with the task of 1)
> determining whether or not the third party is actually
> generating/maintaining/managing records that belong to your organization
> as a part of, or result of their service, and 2) if so, ensuring that the
> third party is following your records retention policies.
>

Yes. To both 1) and 2).  It is either performed by Records Management,
Procurement or on rare cases, an IGAuditor.

Larry
-- 
Larry
[log in to unmask]



*----Lawrence J. MedinaDanville, CARIM Professional since 1972*

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