A Five-Part Strategy for Records Management

by Julie Gable

Andersen's difficulties in the wake of Enron's collapse are a convincing argument for records management's importance as a business practice. While there are many excellent sources to explain the concept of life cycle management, few explain how to accomplish it.

Records management programs have five parts: policies, retention schedules, procedures, training and audit. Skip any one and the ability to justify information management decisions wobbles like an uneven chair. Here's what to do:

Program implementation will involve the entire enterprise, so put together an oversight team of legal, tax and senior management advisors. Identify people in each department who know work processes and the records involved. These "liaisons" will be useful in program development, rollout and ongoing operation.

Next, draft policies that explain the company's attitudes toward keeping records to satisfy business, regulatory, legal and fiscal requirements. Have these policies approved by the oversight team. Define when and how the company destroys documents — and when it doesn't. For example, policies typically state: 1. that the company destroys documents in due course when they have reached the end of their life cycle, 2. that company officials approve destruction, and most importantly, 3. that destruction activities stop if litigation or investigation is imminent.

Trashing records to cover tracks can lead to Obstruction of Justice charges, which carry fines in the half-million dollar bracket and jail time for corporate officers. This usually gets management's attention.

Develop retention schedules that show who keeps what and for how long, and get approval from the oversight team and the liaisons. Rather than listing every possible document, retention schedules group records into broad categories (called records series). For example, the "Payables" series encompasses vendor invoices, shipping documents, purchase orders, etc.

For each records series define two things: a specific retention rule, based on regulations, case law, or industry custom; and an Office of Record, meaning the department responsible for keeping the record's official version. Record series classifications and their associated retention rules are essential for records management software to work.

Identifying one specific department as the official authority for each records category means that all other recipients have "convenience" copies that can legitimately be discarded at any time. Whether copy holders actually do so is a matter of procedure. The best procedures concisely tell people exactly what to do and how to do it easily.

Publish policies, retention schedules and procedures on the intranet, but supplement this with training sessions to raise awareness, ensure that requirements are interpreted as intended and demonstrate that the company is serious about records management. Establish the expectation that all employees (and possibly even contractors and collaborators) will comply with the program by periodically auditing records activities, reporting back any problems and offering suggestions for improvement.

If all this seems like serious commitments of time and energy to guard against scenarios that may never materialize, consider the records program's broader benefits. Investing in records management provides a procedural infrastructure that can be leveraged across content management, e-commerce, customer service, ERP, collaborative activities and other initiatives.

More than a point solution for avoiding CNN coverage, records management is a strategic overlay for any information management plan.

Julie Gable (juliegable@aol.com) CDIA, LIT, is an independent consultant based in Philadelphia.