We are Not Records Cops

I’ve heard of the expression “Records Cops. Is that what the records people do?

Asked by a student and a thread on the records management listserv.

Response:

Unfortunately, many employees within an organization look upon the records manager as “records cops” who destroy records belonging to departments within the organization. I would like to think this is a misconception but experience has shown that it unfortunately is true in many cases. I personally recall clients who did not trust the records group because they destroyed their records without the permission of the department.

Personally, I am not a big fan of records management assuming the role of ownership of company records. Sometimes the records management listserv has a thread on this subject and I notice that there are people on the listserv who believe they are both custodian and owner of the company records. While I take great pride in assuming the management of the business records, I find it difficult to assume that because the records may be in our custody we have the authority to actually destroy the records even if the records retention period has passed.

I prefer to think that the records and information manager is responsible for maintaining the reliability of the records within the organization by establishing, implementing and maintaining the records management program that involves the creation, distribution, maintenance, protection, control, storage and destruction of the records. I seem to remember this from our records management books discussing the “Life Cycle of a Record”?

I firmly believe the responsibility for approving the destruction of records within the organization should be the responsibility of the client as they may have knowledge of records that could be a destruction exception that is unknown to the records manager. Destruction of records by a records manager that were an exception could undermine the goodwill of the client. I’ve actually known departments who rented and stored their inactive records in local storage lockers rather than have the records managed by the records management staff. How many of you have the approval authority to destroy records? If you have the authority, do you destroyed the records of your directors, CEO, CFO, etc., without getting prior approval. My guess you would ask permission or be looking for a new position if you destroyed something without their approval.

Some organizations may have other functions (legal, Accounting, etc.,) in their destruction approval process. For some reason having other functions within the company reviewing the destruction notices seems cumbersome, especially if the organization is very large and with units at different locations. The department should be made aware by other functions if there is a legal hold, tax hold, etc., as part of their normal business processes.

I am a firm believer that a destruction notice be created, if at all possible, by departmental records coordinators, reviewed and sent to and signed by the department owner of the records. The destruction notice or letter accompanying the destruction notice should also ask if there is a reason (legal, financial or administrative) why the records should not be destroyed. Perhaps a hold has been placed on the records by litigation. Maybe the tax audit has not cleared. These reasons would be sufficient to place a hold on the records until the matter is closed. A suspense system should be in place to review holds/tax audit records being held beyond their retention period.

Records that are to be retained beyond the retention period for administrative reasons should be reviewed annually to determine if the established retention period is insufficient to meet the needs of the organization.

In closing, I am a firm believer that records management function should not assume the role of the “records policeman” and the responsibility for destruction approval rests with the department owner