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Establish approved Records Retention Schedules
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Records Management 27.03.2009 Mario Rieger
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Establish approved Records Retention Schedules
ESTABLISH APPROVED RECORDS RETENTION SCHEDULES Record retention schedules are developed based upon legal and regulatory requirements. Retention of general records should be in accordance with this schedule. The operating company should establish retention requirements for records that are unique to the company by conducting retention research. Why not retain all company records permanently? Although it would eliminate the work required to create an accurate and effective record retention schedule, it could also expose the company to significant risks, including: •
Increasing the company’s exposure to costs and litigation burdens of pre‐trial discovery; and
•
Requiring ever‐increasing space requirements and costs for storage of records
Also, it would not eliminate requirements to monitor and audit records to ensure that none are willfully discarded.
Mario Rieger
Digitally signed by Mario Rieger DN: cn=Mario Rieger, o, ou, email=mario_rieger@web. de, c=US Reason: I am the author of this document Date: 2009.08.05 07:29:03 +02'00'
Establish approved Records Retention Schedules
A.
CONDUCT A RECORDS
INVENTORY The starting point for proper management of company records is to identify the types of records that are used by the company (record titles). A record title may define one type of document or represent a collection of different documents that are related and considered a record with one retention period. Conducting an accurate records inventory is the foundation of establishing a solid record retention schedule. By conducting an inventory, all records in the office and storage areas are located, identified, described, counted, and measured. The inventory includes all formats of information including, but not limited to; loose and bound papers, microforms, optical disks, CD‐ROM, videotapes, audiotapes, magnetic tapes and disks. The information gathered will allow records to be systematically managed and will aide in identifying which records should be converted to another medium, i.e. microfilm or imaging.
Establish approved Records Retention Schedules
I. PROCESS OVERVIEW Conduct a records inventory of all departments and facilities where records are created or maintained, including commercial records storage facilities (if applicable), to determine the record titles used. The inventory is most easily accomplished by using a standard form to collect comprehensive information about each record title. Use the form to capture the name, current location, originating department, estimated volume within each location, and the date range of each record category. Also note if records are active or inactive, if records are vital, the media on which records are maintained and how destruction is currently applied. Identify if records are maintained in multiple locations and note any special conditions (for example security requirements) that need to be addressed. The inventory can also be used as an opportunity to document the current condition of company records.
Establish approved Records Retention Schedules •
Document any problems or issues that should be addressed through the program, for example:
o If transfer cases are left open
o If files are left on file cabinets and not put away
o If confidential information is not secured o If electronic media is not properly managed o If hazardous conditions exist such as evidence of damage by rodents or water • Document any differences in practices followed by varying departments
The volume of records can be estimated by measuring them with a ruler. Fifteen (15) linear inches of letter‐sized files equals approximately 1 cubic foot of records. Approximately 5,000 records can fit into a standard 5‐drawer cabinet file drawer Conduct an analysis of the estimate file growth of records in order to identify future space requirements. Summarize the number of records, the potential overall space available, and the classifications of records maintained for each site.
Establish approved Records Retention Schedules Converting the inventory to an electronic format is recommended in order to minimize time required to sort and identify similar or duplicate record classifications.
B.
DEVELOP RECORD RETENTION
SCHEDULES The record retention schedule (RRS) is a list of record titles that identifies the length of time records must be kept by the company. A systematically developed RRS provides a legally acceptable framework for discarding business records that are no longer needed. The record retention schedule may be a master listing of all record titles or individual listings by department or functional area. The schedule reflects research and careful evaluation to determine retention periods that consider the operational and business needs for the records, State and Federal laws, and regulatory requirements.
Establish approved Records Retention Schedules
I. PROCESS OVERVIEW Using the inventory, work with functional areas to determine operational requirements for records within that area. Based on these requirements, establish appropriate guidelines for when record titles become inactive. Research current local, state, and federal laws and regulatory requirements governing the records titles listed on the inventory. In addition, identify internal and external audit requirements that might apply to each record title. Using all considerations, establish a total retention requirement for each title as well as the period of time records will be considered active and must remain in the work area. When all retention requirements have been established, obtain approval from upper company management, the company Board Attorney, and Law Department. The schedule must include a description for each record title, the office‐of‐record indicating the department that is fully responsible for the official copy of the record during its life cycle, the retention period (which can be broken down
Establish approved Records Retention Schedules into active and inactive retention periods), indication as to which records are vital or related to tax, SOX etc., and reference to the law or other factor(s) which determined the retention period. It is highly recommended that, as new schedules are developed, record codes be utilized to allow for linking stored records to record indexes. This is especially helpful when a records management software program is not being used to manage box information. In addition, the schedule uses abbreviations called retention codes to indicate the base amount of time to retain each record. Sometimes a numerical value is also used to indicate years or months in addition to the base amount of time. The code may also be an abbreviation for an event that must occur before the clock starts ticking on the remaining retention time. Once finalized and approved, the retention schedule must be distributed to company departments or divisions. Place the approved RRS on the company Intranet or a Shared drive for all to access and as a company resource. Written procedures must be developed regarding how the retention schedule is changed and controlled.