Sunday, June 07, 2009

How do you develop a retention schedule?

Part II

I was asked this question by a department manager who was considering the development of a records management program for his department.

In a previous article in the May, 2009 issue of ‘Soundings’ I stated that the inventory is a crucial step in the development of an effective records management program and will be the primary document used in establishing the records retention schedule within the organization.

The inventory process is also an excellent way to identify possible work process changes and identify records or reports that may no longer be required within the organization. This is where a flow chart may be useful to determine who sends or receives the documents. When I am working with a client I will ask the following questions:
• “What function does your position perform within the organization?”
• “What is your primary responsibility?”
• “What records are you responsible for?”

Records Appraisal and Retention Schedule Development

Once you have the inventory completed, the next stage in the development of a retention schedule is the appraisal of the records listed on the inventory. Types of informational values may include:
• Legal and regulatory value: records required by federal, state, county statues and regulations and form the basis for the retention period established for your records. Following the legal regulations demonstrates your compliance on maintaining your records.
• Fiscal Value: These are records that relate to the financial transactions of the organization and are required for audits and tax purposes.
• Administrative/Operational Value: These are normally records that do not have a legal, regulatory or fiscal value to the organization. They document activities within the organization and are created in the performance of the function. The record owner usually knows how long the records should be retained.
• Historic Value: If the organization has an official archives in-house the records maybe reviewed to see if they document the historic development of the organization. A question on the inventory form may be used to identify those records that may be considered archival.

Some organizations may also evaluate records that they considered as vital. These are records containing information that would be vital to business resumption in the event of a disaster. A question on the inventory form may be used to identify records that may be considered vital. You want to note that the record is vital on your retention schedule and may require additional protection by duplication.

The records appraisal also includes the need to conduct some research into the legal and regulatory (which includes fiscal) retention requirements for the records within your collection.

Some resources for legal research are:
• Software:
o Information Housing Clearing House – Retention Manager 3 (http://www.irch.com/index.htm)
o Zasio - Retention 7 (www.zasio.com)
• Federal (http://www.access.gpo.gov/nara/cfr/cfr-table-search.html#page1)
Washington State – WAC (http://apps.leg.wa.gov/wac/) or RCW (http://apps.leg.wa.gov/)
• Washington State Secretary of State: http://www.secstate.wa.gov/archives/gs_local.aspx
• ARMA HQ Bookstore: “Sample Forms for Archival & Records Management Programs”, ARMA & SAA, 2002 (http://www.arma.org)
• Directory of State Archives and Records Management Programs www.statearchivists.org/states.htm#hi
• Associations may have established a generic retention schedules
• Users within the department may know of a legal requirement.

Once you have completed the legal research and developed the retention schedule you should have the schedule reviewed and approved by an approving authority within the organization to insure that the schedule meets the legal/operational needs. Some of the reviewers could be:
• Legal
• Auditor
• Financial Manager
• Tax
• Department
• Corporate Records Manager
• Corporate Records Committee (major owners of the records)

Additional Resources

Resources that I have used in the past for assistance in creating retention schedules have been:
1. Ricks, Swafford & Gow, “Information Resource Management: A Records Systems Approach”, 3rd Ed, 1992, South-Western Publishing Co.
2. Read & Ginn, “Records Management”, 8th Ed., 2007, South-Western Publishing
3. ARMA HQ Bookstore: “Sample Forms for Archival & Records Management Programs”, ARMA & SAA, 2002 (http://www.arma.org)

You may also want to check out other resources on retention schedule development that are available through the ARMA bookstore at www.arma.org.

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