We do "Clean out your Records Day(s)" and we also have "Liaisons.
Our program is called "File Maintenance" and it's objective is to have
every employee take at least one day out of the year to bring their files
into compliance with our information management policies.
It's an ongoing program in which we move through the various business
units, departments, and workgroups, focusing on each one individually so
that by the end of the year, everyone has had a "File Maintenance Day."
While the "day" is the most visible part of the program, there's a lot more
behind the scenes things we do.
Typically we start by meeting with the Business Unit's liaison. At this
meeting we'll go over the retention schedules that apply to their
organization, we'll ask about any changes in business practices, new
initiatives, changes in legal or regulatory environment, etc. This
includes any litigation or regulatory investigation that may be going on in
their organization, so we can include this in our communication plan. We'll
also look to see if there are office moves planned or new software roll
outs so we can coordinate our efforts with these activities.
Next we'll go over an inventory listing of the records their organization
is storing off-site, and which will be coming due at the time of their File
Maintenance period. This is also our opportunity to update our contacts in
the organization, to make sure there's an appropriate (i.e. someone still
working for the company, in the same organization, with the authority to
make record keeping decisions) subject matter expert assigned to each
schedule and collection of archived records. Oh, and we'll also schedule a
File Maintenance period for the group, and draft a communication plan.
Before the File Maintenance Day, we'll have the organizations subject
matter experts review their retention schedules and their off-site
holdings. This gives us a chance to update the schedules prior to any
purge activities. We will also start conducting information management
training for the different work groups, giving them program updates,
telling them what's expected of them, why we do this, how to use the
retention schedules, etc. Now, thanks to Sarbanes-Oxley, we tell them they
can do jail time if they destroy anything related to an ongoing, pending,
or foreseen regulatory investigation.
Our basic communication plan includes a kick-off memo from our Corporate
Secretary and General Counsel announcing their File Maintenance Period, a
mention as to why it's important to do this, and a list of resources to
help them on the day. We also have series of template emails dealing with
specific File Maintenance Issues that are usually sent out under their VP's
signature in preparation of the actual day(s). We usually conclude with a
final reminder notice from our Corporate Secretary and General Counsel that
the day is almost here.
During the File Maintenance period we'll usually have at least one staff
member available at the site to deal with any issues or questions that may
come up and monitor the general activity - usually this is the easiest step
for us, and we end up eating a lot of pizza.
After File Maintenance has been completed for an organization, we'll meet
again with the liaison to get their feedback on the activity, what worked,
what didn't work, what we can do better next time. We'll usually report out
our progress and findings at the quarterly meeting with all the liaisons
and solicit additional feedback there.
We're wrapping up our second year of this, and we seem to be getting better
at it. Our first year focused primarily on paper records, but now we're
addressing electronic records as well. With each cycle we're seeing
improvements in our retention schedules, a reduction in "orphaned" records,
and more buy-in from the employees. Check back with me next year and let
you know if these trends continue.
Christian Meinke, CRM
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