Message from Earl Johnson:

Good morning,

I'm curious as to whether anyone has a [formal] process for users who may challenge (not the best word, but it's the only one coming to mind right now) or change an item on a records retention schedules (RRS)? In other words, how are you making changes to your RRS in the event that a user wants to change an item on the RRS either via finding new regulatory guidance that may've been missed, or having a sound business reason for wanting to change the retention period for an item.

Is there a formal process for this that you can share either on/off list?

Response:  

We have it written into our retention policy and requires the business to submit a request to the RIM Department for review of the retention change.  The change must include a bona-fide business, legal or regulatory reason.  We in turn review, approve or deny the request.  If we are challenged, then we take it to the Office of the General Counsel for review.  The OFGC does not take a position of approving the change, they only to help mediate a conclusion.  

I have had this happen twice and when presenting our position to the OFGC, I provided the CA statutes supporting my decision.  In both cases, I prevailed.  We are not always so difficult about the retention and try to understand the business reason and if a longer retention is supported.  Recently, we approved a changed to increase a regulatory retention because of the business need to manually sort through years of paper for analysis.  We required all the Directors, affected by the requirement, to affirm that the change was temporary until such time as the situation for the manual analysis is resolved.  We will then re-evaluate and apply a retention closer to the regulatory requirement.  The affirmations are now coming in to support this change.

Al Gamino
Enterprise Technology Analyst
Records & Information Management Department
Sacramento Municipal Utility District
6100 Folsom Blvd, Mailstop MD-2(MD1016), Sacramento, CA 95817
w.916-732-6041 | [log in to unmask]

List archives at http://lists.ufl.edu/archives/recmgmt-l.html
Contact [log in to unmask] for assistance
To unsubscribe from this list, click the below link. If not already present, place UNSUBSCRIBE RECMGMT-L or UNSUB RECMGMT-L in the body of the message.
mailto:[log in to unmask]