Creating and implementing a retention policy is a challenging and time consuming process. Once it’s established, the next big challenge is having it adhered to throughout your organization. The records management group or compliance department is accountable for communication and execution of the retention policy, but to ensure full compliance it takes teamwork with all the departments in your organization. In addition to in-house resources, it is also critically important to partner with and leverage the resources of your company’s offsite Records Management provider.
The first step is to assign to each box and/or file the necessary information needed to execute the retention policy. This information (called index information) minimally is the start date (creation date, or received into storage date) and the length of time that it is needed to be stored. Optimally, additional information is also assigned to boxes and files, such as RSC codes, matter numbers, and/or the compliance rules that need to be followed. Since retention schedules vary based on the type of records being stored, this additional information makes it easier to find records and execute policy efficiently.
A great way to ensure the boxes/files have the appropriate information assigned is by having your offsite Records Management company check for its inclusion at time of collection. If the information is not there, a message can be sent back to the Records Management department to let them know. This proactive approach saves time when searching for documents later, and limits your exposure of having records not follow the appropriate retention policy.
Audit and Tracking
A process needs to be set up where you and your Records Management company audit the index information associated with the records on a regular basis. This will identify records that may be incorrectly classified or missing key information.
Your Records Management company must provide your organization with a method to review the index information associated with records, on demand. This is most often done through a Web-based portal that allows you to run reports to audit the index information on the records in offsite storage.
The next step is a process to review records eligible for destruction. Using the same Web portal used for audit of index information, you should run destruction reports on a regular basis - usually completed quarterly or annually. As long as the correct index information is in place, lists of records eligible for destruction can be parsed out by department for review and sign off.
For the final and most important step in the retention policy, you must be confident in your Records Management partner. After the records are approved for destruction, they must be accurately retrieved and prepared. A process should be in place that checks and rechecks the records to be destroyed to minimize the chance for error. After the records are destroyed, certificates of destruction must be provided to you.
Consistent enforcement of policy is challenging in all organizations. It is critical that you leverage all the resources available to you. By partnering with your offsite Records Management company as part of your retention execution plans, you ensure better and more consistent compliance with the retention policies you worked so hard to establish.