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RECMGMT-L  March 2002

RECMGMT-L March 2002

Subject:

Re: "retain a minimum of..."

From:

Peter Kurilecz <[log in to unmask]>

Reply-To:

Records Management Program <[log in to unmask]>

Date:

Sun, 17 Mar 2002 16:32:42 EST

Content-Type:

text/plain

Parts/Attachments:

Parts/Attachments

text/plain (107 lines)

The following was received as a private response, however the individual did
grant me the privilege/authority to repost it to the list so long as their
name and other identifying information was removed.

Peterk

<snip>
Peter

You wrote...
----------------------------
Alicia hit on the main reason why I do not like "General Schedules" -- they
do not take into account the business processes and business rules of the
agency. yes they are nice guidelines, but I wouldn't stake my life to them.

These general schedules relate more to the paper environment than they do to
the more current hybrid business processes of today that are comprised of
images , paper and databases. I have always believed and strongly suggested
that the records inventory process needs to be based more upon an
organization's business processes/functions/workflows than on the number of
filing inches etc. that we see on the inventory forms.

I think that the General Schedules would be more useful if they were written
as a process than as the individual items that comprise the process.
----------------------------

The international standard on records management (ISO 15489) tells us that
all recordkeeping activities must be based on the business activities of an
organisation.  Here in Australia, we have been doing this for many years
(well, some of us have) - mainly because of the issue of the Australian
standard on records management (AS 4390).  These two standards take a 'top
down' approach, rather than the 'bottom up' approach.    They also rely
heavily on the concept of 'risk management' (something which has always been
done, but maybe not articulated)

I'm not fully familiar with the methods used in USA for developing disposal
authorisation, but I assume that if a 'records inventory' is involved, it
would be a 'bottom up' approach.  Even in a bottom up scenario, a risk is
taken that all the records of a particular type have the same disposal
decision attached to them.  I presume that only a random sampling is done
when appraising the value of the records.

The 'Designing and Implementing RecordKeeping Systems' methodology (DIRKS)
developed by the National Archives of Australia (NAA) and the New South
Wales State Records Authority (NSWSR) were fully compliant with AS 4390.  I
cant speak for NSWSR, but the NAA methodology was updated to reflect the
international standard.

That said, it is very hard to develop general disposal coverage, which takes
in the business needs of all organisations it applies to.  A risk has to be
taken that the business processes in a small number of organisations is
applicable to all organisations.  In most cases, things will be pretty
similar across the board.

... the development of the NAA's last 'General Disposal
Authority', the 'Administrative Functions Disposal Authority'... was
based on an analysis of the business practices of many organisations within
our jurisdiction, as well as the procedural information produced by the
departments with overall responsibility for the management of some functions
(eg, the National Occupational Health and Safety Commission for advice on
Occupational Health and Safety).  Relevant legislation was also consulted,
of course.

Tucked away in the introduction somewhere, is advice to agencies that the
disposal actions are minimum ones, but if the specific organisation has a
business need that is longer, then you should extend the minimum.  This was
particularly important where records are generated in overseas countries -
there might be a legal reason for extending the retention period (and we
didn't have the resources to investigate these for every country in the
world).  In other words, we took a risk that the needs of all business were
being met by our retention periods - this risk was acceptable to us.

Glenn Sanders mentioned the problems involved in ringing everyone up to see
if they were dead or not.  While I know that Glenn suggested this
facetiously, there is a great benefit in aligning recordkeeping with
business processes.  If the personnel system is notified of a death of a
staff member, how hard would it be to somehow raise a notification that the
relevant file can then be moved from the 'active' state, to the 'inactive'?

I cant imagine that all agencies would ever destroy all their records when
the retention period is up.  In my experience, most organisations have a
backlog of records to 'sentence' (determine the appropriate retention period
in accordance with a disposal authority), so in effect they are retaining
records longer than necessary.  In some cases, the disposal decision is
easier the more that time passes, so it is possible to work out the costs of
storage, and compare them with the costs of sentencing, the benefits of
timely destruction, the likelihood of any consequences of the longer
retention and other relevant factors (ie the risk of taking a particular
course of action).  In other cases, it is due to the relative importance
organisations place on recordkeeping.

All that said, the NAA does issue general disposal authorisation which sets
out a 'maximum' retention period.  General Disposal Authority 24 relating to
records generated out of 'data matching' exercises positively requires some
records to be destroyed BEFORE a certain time period.

Anyway, this has been a very interesting topic - one generating lots of
interest.  I have sent this to you, rather than the list, because I don't
particularly want to be associated with making these comments publicly
... However, feel free to take out my identifying
information and post it to the list.  Most people ... who
read the recmgmt list will know who sent it (and some people out there in
the real world in Australia), but I am happy with that.
<snip>

List archives at http://lists.ufl.edu/archives/recmgmt-l.html
Contact [log in to unmask] for assistance

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