Condition critical: developing records retention schedules: hot topics in the records management field warrant a new look at old retention schedules or the need to build a well-planned, comprehensive retention schedule. This ongoing process requires thought, planning, and documentation to ensure the proper maintaining of important records.

• Author: Fischer, Laurie

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Enterprise content management, data privacy, Sarbanes-Oxley internal controls, and e-mail mismanagement are all high-profile, hot topics that have garnered the interest of senior-level management--topics that have increased awareness of the importance of the records management function within organizations.

Records retention schedules are, in fact, the critical component of all records management programs, since they identify records to be managed by the program as well as how long the records are to be retained. Records retention schedules are the primary tools that assist an organization in the management of its records because they provide the rationale behind retention policy as well as direction and guidance on other recordkeeping requirements and conditions.

Establishing and implementing records retention schedules provide very visible benefits, since these activities:

* Help ensure an organization meets all legal/fiscal retention requirements for all records, regardless of media

* Identify records requiring enhanced protection or control

* Identify the record custodian for all multi-copy or official records

* Reduce the floor space dedicated to the storage of active records by allowing the disposal of inactive, duplicate, or obsolete material

* Establish timeframes in which records are to be transferred on a scheduled basis from active to inactive storage areas

* Provide the go-ahead to purge unnecessary records from inactive records storage areas

Retention Scheduling Considerations and Decisions

In advance of developing retention schedules for an organization, there are a number of key considerations regarding their scope, format, and maintenance that require discussion and decision. Although not comprehensive to every organization, the following considerations are likely to be relevant to most.

1. Is the organization starting from scratch, or is it refreshing existing retention schedules? It is often easier to start from scratch, especially if the organization has inherited legacy retention schedules that have been cobbled together over time or has witnessed organizational changes without the schedules having been updated. Regardless of the approach, it is important to be mindful of existing records inventory that may have been mapped to former retention schedules.

2. What is the scope of the retention schedules? Although all of the organization's records should be included on its retention schedules, the size and complexity of the organization may indicate a need for a phased approach to the development of the retention schedules beginning with those areas of highest risk or those most likely to be subject to audit or investigation.

3. Will the organization develop functional retention schedules or more detailed departmental retention schedules? A functional retention schedule is one that describes broad groups or categories of records. A departmental retention schedule contains more detailed record series information specific to a department. Although departmental retention schedules tend to contain a greater degree of specificity and less potential for an end-user to miscategorize records, departmental retention schedules require a higher degree of time and effort to maintain.

4. What method will be used to gather information to develop the retention schedules? There are two primary methods to gather detailed information on an organization's records:

   * Individual, face-to-face meetings with departmental representatives

   * Standardized questionnaires distributed and completed by departmental or functional key contacts

   Although the first method is more time-consuming, it is the preferred method because it allows personal contact with the departmental or functional key contacts and more specific questioning regarding a department's records, eliminating some of the follow-up activities typically required after using the questionnaire method.

5. How will common or general records be handled? Individuals within the organization may keep copies of records for administrative, reference, or operational purposes for which the official records exist elsewhere. Examples include copies of expense reports or check requests, copies of contracts, and a manager's copy of employee files. Although not the official records of the organization, employees need direction on how long to retain these records. The records manager may decide to include these on all of the departmental or functional schedules or may develop a separate, stand-alone retention schedule for them.

6. Who will perform the research into regulatory recordkeeping requirements? Will it be the records management department, the legal department, or outside counsel? Further, as regulatory requirements change, how will the organization stay abreast of changes that may affect the retention time periods assigned to records?

7. How will retention schedules address electronic records? In many cases, the owning department of electronic records is not the same department or function that serves as their custodian, so a decision regarding the placement of electronic records must...