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.

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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 be made.

8. What tools will support the development and ongoing maintenance of the retention schedules? At a minimum, consider the following:

* Infrastructure management tool--contains contact information for the network of department key contacts and can be used to track activity dates

* Records retention tool--contains records data linked to departmental or functional organizational information used to generate the retention schedules

* Legal research repository--contains records-related citations and other legal research grouped by function or category

Although these tools may be housed in spreadsheets or word processing tables, it is recommended that a relational database be considered because it provides a more dynamic environment across all information requirements. For example, a database may contain a table for the organizational contact information, another table for the records data, and yet another table for the legal research. The tables can be linked to each other in a variety of relationships.

Retention Schedule Development

The primary steps in the development of retention schedules include

1. Planning and communications

2. Information gathering

3. Analysis, research, and preparation of draft retention schedules

4. Review and approval

Step 1. Planning

To develop retention schedules, the records manager must establish a network of key contacts, or records coordinators, within each department or function. These individuals, usually designated by department management, should be knowledgeable about the functions and responsibilities of the department, understand the records created, received and maintained, and be the key departmental liaisons to the records manager on all records-related matters. Organization charts can be a useful tool in ensuring all functions within the organization have a designated records coordinator.

In addition to records coordinators, other records management roles and responsibilities should be defined as part of the overall records management infrastructure. These roles and responsibilities include:

* Records committee

This may also be called a records advisory council or records governance group. Regardless of its name, this body should be the senior/executive-level group of individuals that provides the overarching authority for the records management program.

* Key advisors / subject matter experts

These individuals may be part of the records committee and are those subject matter experts who will provide specific retention guidance or decisions on specific topics. At a minimum, key advisors should include legal counsel, the tax manager, and an information technology representative. Depending on the industry and its regulators, other key advisors may be named on an as-needed basis from functional areas such as quality, compliance, regulatory affairs, government contracting, and environmental health and safety. (If the organization comprises various business units with different regulatory requirements, make sure to identify business-unit-specific advisors as well.) Before beginning information gathering, it is a good idea to meet with each key advisor to discuss the overall regulatory environment as well as organization-specific requirements that will supplement or override any regulatory requirements.

Step 2. Communications

To socialize the organization to retention scheduling initiatives, initiate communication on retention scheduling methodology and the importance of retention schedules to the organization. The audience for these communications should include senior management, department managers, and records coordinators, and the communications may take the form of direct correspondence via e-mail, "marketing" pieces in company newsletters, and orientation meetings.

Step 3. Information Gathering