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
Wednesday, June 16, 2010
Reviewing Records for Destruction
Do you have any tips on reviewing records for destruction?
Question was recently asked by an administrator during a review of their department’s filing system.
Response:
While an organization may have a good records management program on paper, with all the proper policies and procedures, there usually is something missing in the process; the lack of consistent and timely reviews of records past their retention period. I am sure that many of you can relate to this problem. As I have stated in previous articles, this is not unique to any one organization, private or public. Without a systematic approach and staff assigned and trained to manage the program your records will not be reviewed regularly.
Here are a few things that I have found that work effectively with any records review:
If you have an existing records management database you can create a listing of records that are due for destruction for each client or department within your organization. Annotate those that may be over-due for review. If you suspect an error in the retention period, write a comment on the index that the record may require additional retention.
If you use an outside vendor to manage your business records they probably have the ability to create listings of records due for destruction. The major vendors in my area have electronic systems that allow the customer to create and publish listings based on criteria established by the customer. Vendors will also create reports to your specifications for a fee.
If your lists of records transferred to storage (transmittals) are in paper mode only, start by reviewing the transfer notices of the oldest boxes in storage to insure the information on the transmittal accurately describes the records within the boxes. I have found over the years that not all records shipped to storage were accurately described. I have encountered transfer notices that did not include the dates of the records within the boxes. Box contents on the transfer notices simply labeled “Projects”. Each box with missing or misleading information will require individual inspection to determine the contents and see if they can be destroyed or re-indexed with the proper information to identify the contents.
As Ellie’s father said in the movie ‘Contact’; “Small moves Ellie, small moves”. The same goes with a records cleanup. Hopefully the client will review the listing and approve the destruction of the records. However, if you cannot get an approval of destruction of the collection, arrange to review them in small amounts. You will have a better chance of getting the cooperation of the reviewer if they are not overwhelmed by the task. The smaller the amount of records the client has to review the better.
Secure a dedicated room to store and review the records so the client does not have clutter in his/her area. You probably already have the clutter in your own office. If you have a collection of records off-site at a commercial records center you may be able to arrange a room to view the records at their site. Generally there is a charge to using this viewing room. Try to have the client set aside specific time during the work day for review and management of their records. Emphasize the importance of time management. I had clients actually request I put a few records at a time in their chair every morning to review.
If the actual owner of the records cannot or refuses to complete the review, you might have to find a person with the authority to approve the destruction and/or would be willing to have someone else who is knowledgeable perform the task.
Try to secure a champion from upper management who will help promote an annual records review program so that is becomes a requirement, not an option.
Review all boxes in storage to insure that they have an appropriate retention period. If your local or state agency within a state that has a formal records management program, use or create a destruction notice that meets the state’s guidelines. Once you have destroyed the backlog, the annual review should become much easier if done on a regular basis.
If you have an onsite records center and/or special areas to store records, do not let them become a dumping ground for non-records. Insist on control of the environment to insure the protection of the records from unauthorized use and review. This is easy to say but a challenge to do. I have taken photographs of poorly managed storage areas and used them successfully in presentations to management staff to emphasize potential risk to their organizations.
The cleanup process is probably one of the more stressful parts of a records managers duties. However, when you have completed the cleanup of the backlog you should feel satisfaction for successfully accomplishing the task.
Question was recently asked by an administrator during a review of their department’s filing system.
Response:
While an organization may have a good records management program on paper, with all the proper policies and procedures, there usually is something missing in the process; the lack of consistent and timely reviews of records past their retention period. I am sure that many of you can relate to this problem. As I have stated in previous articles, this is not unique to any one organization, private or public. Without a systematic approach and staff assigned and trained to manage the program your records will not be reviewed regularly.
Here are a few things that I have found that work effectively with any records review:
If you have an existing records management database you can create a listing of records that are due for destruction for each client or department within your organization. Annotate those that may be over-due for review. If you suspect an error in the retention period, write a comment on the index that the record may require additional retention.
If you use an outside vendor to manage your business records they probably have the ability to create listings of records due for destruction. The major vendors in my area have electronic systems that allow the customer to create and publish listings based on criteria established by the customer. Vendors will also create reports to your specifications for a fee.
If your lists of records transferred to storage (transmittals) are in paper mode only, start by reviewing the transfer notices of the oldest boxes in storage to insure the information on the transmittal accurately describes the records within the boxes. I have found over the years that not all records shipped to storage were accurately described. I have encountered transfer notices that did not include the dates of the records within the boxes. Box contents on the transfer notices simply labeled “Projects”. Each box with missing or misleading information will require individual inspection to determine the contents and see if they can be destroyed or re-indexed with the proper information to identify the contents.
As Ellie’s father said in the movie ‘Contact’; “Small moves Ellie, small moves”. The same goes with a records cleanup. Hopefully the client will review the listing and approve the destruction of the records. However, if you cannot get an approval of destruction of the collection, arrange to review them in small amounts. You will have a better chance of getting the cooperation of the reviewer if they are not overwhelmed by the task. The smaller the amount of records the client has to review the better.
Secure a dedicated room to store and review the records so the client does not have clutter in his/her area. You probably already have the clutter in your own office. If you have a collection of records off-site at a commercial records center you may be able to arrange a room to view the records at their site. Generally there is a charge to using this viewing room. Try to have the client set aside specific time during the work day for review and management of their records. Emphasize the importance of time management. I had clients actually request I put a few records at a time in their chair every morning to review.
If the actual owner of the records cannot or refuses to complete the review, you might have to find a person with the authority to approve the destruction and/or would be willing to have someone else who is knowledgeable perform the task.
Try to secure a champion from upper management who will help promote an annual records review program so that is becomes a requirement, not an option.
Review all boxes in storage to insure that they have an appropriate retention period. If your local or state agency within a state that has a formal records management program, use or create a destruction notice that meets the state’s guidelines. Once you have destroyed the backlog, the annual review should become much easier if done on a regular basis.
If you have an onsite records center and/or special areas to store records, do not let them become a dumping ground for non-records. Insist on control of the environment to insure the protection of the records from unauthorized use and review. This is easy to say but a challenge to do. I have taken photographs of poorly managed storage areas and used them successfully in presentations to management staff to emphasize potential risk to their organizations.
The cleanup process is probably one of the more stressful parts of a records managers duties. However, when you have completed the cleanup of the backlog you should feel satisfaction for successfully accomplishing the task.
Subscribe to:
Posts (Atom)