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From:
"Creamer, William" <[log in to unmask]>
Reply To:
Records Management Program <[log in to unmask]>
Date:
Mon, 4 Jun 2018 15:47:46 +0000
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Considering that the records retention schedule is current, etc.  We don't have the records reviewed internally.

We do get the clients ok to return the records to them, or shred the records, but since our retention plan is the controlling document, we don't ask for any internal approvals.  We do notify any partners who worked on the matter that it is eligible for retention disposition, but rather than an approval, we're looking for Client Contact names or a reason that a matter might not be eligible, such as an impending hold that has not yet been announced.

One of the reasons we do not want partners second guessing the Retention Schedule is a concern over a lack of consistency and possible selective destruction issues.


William P. Creamer
Records & Retention Manager
Willkie Farr & Gallagher LLP
787 Seventh Avenue | New York, NY 10019-6099
Direct: +1 212 728 3448 | Fax: +1 212 728 8111
[log in to unmask]<mailto:[log in to unmask]> | www.willkie.com<https://urldefense.proofpoint.com/v2/url?u=http-3A__www.willkie.com&d=DwIFaQ&c=pZJPUDQ3SB9JplYbifm4nt2lEVG5pWx2KikqINpWlZM&r=b5NZPQUb9_r2rQ3Zd74ATT3aSs9yKyRnJLOhqJvd7fE&m=mY0NdfUK3Ccc0aSUR7XXgP1KN_HvW_jQFn0mosU6jzw&s=KMNxtqQPebUix7tgUSETO_5MH5fQ_XNzwKwiFNrqH40&e=>

-----Original Message-----
From: Records Management Program [mailto:[log in to unmask]] On Behalf Of Blake Richardson
Sent: Monday, June 04, 2018 11:37 AM
To: [log in to unmask]
Subject: [RM] Records Destruction - Approval

Good morning Listserv colleagues, for years I have used a multi-tiered records destruction process for physical records that includes review/approval of records eligible for destruction by the respective department head, Tax, and Legal departments.

However, I was recently asked if review and approval by the Tax and Legal departments is necessary if the records retention schedule is current/accurate, and all tax and legal holds have been communicated and responded to by the respective records custodian.

I am curious if any Listserv records practitioners no longer (or have
never) have records eligible for destruction, reviewed by your Tax and Legal departments.  If so, what was the rationale for not conducting a Tax/Legal review?

Sincerely

Blake E. Richardson, CRM
Corporate Records Manager

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