Minimizing the use of trigger events to increase records retention compliance.

• Author: Corey, Tom

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It can be difficult to comply with records retention requirements that are based on trigger events, so many organizations are seeking to replace them with straight retention time periods. This article outlines approaches for doing this for six trigger events that are commonly used in retention schedules.

When records management primarily addressed paper records, it was manageable to comply with retention periods that included event codes, or trigger events, which are requirements that must be fulfilled before the time for the disposition of that record begins. People kept files, and when they completed a project or a contract ended --which triggered the retention period to begin--they evaluated the records, removed what they did not need, kept what they needed, and cleared up space for future records.

Today, employees create most records electronically, storing and saving official records and non-record information in multiple locations, including on hard drives, flash drives, shared drives, laptops, personal devices, tablets, e-mail accounts, and the cloud. In this electronic environment, using trigger events in a retention schedule is much more difficult for organizations to manage.

For example, if the trigger event for a record is "termination of employment plus three years," the employee must have been terminated before the calculation of three years begins. Then, someone must notify the person responsible for managing that record about the termination to ensure that the retention clock starts ticking, wherever that official record lives.

This is actually an easy example because most organizations can put a date on when an employee leaves. But, when does a contract expire or is a policy superseded?

Some organizations' electronic records management systems (ERMS) efficiently address trigger events, while others struggle to create clear rules for handling trigger events. If the organization struggles with this, an ERMS will not provide the solution, proper disposition of the records will not occur, and the organization will have compliance issues.

To resolve this, many organizations are seeking ways to eliminate retention times based on trigger events and are using instead straight retention time periods, in which the time for calculating the disposition of a record begins at its creation.

Trigger Events to Be Minimized

The following sections outline approaches for eliminating or minimizing six trigger events that...