If your organization or whomever you are managing records on behalf of are
subject to any Federal requirements, the General Retention Schedules have
guidance on this.  And whether you think it makes sense to retain them or
not, you must.

GRS 16, Item 2

2. Records Disposition Files. 
Descriptive inventories, disposal authorizations, schedules, and reports. 
a. Basic documentation of records description and disposition programs,
including SF 115, Request for Records Disposition Authority; SF 135, Records
Transmittal and Receipt; SF 258, Agreement to Transfer Records to National
Archives of the United States; and related documentation. 
(1) SF 115s that have been approved by NARA. 
Destroy 2 years after supersession. (N1-GRS-98-2 item 16)
(2) Other records. 
Destroy 6 years after the related records are destroyed or after the related
records are transferred to the National Archives of the United States,
whichever is applicable. (N1-GRS-98-2 item 17)
b. Routine correspondence and memoranda. 
Destroy when 2 years old. (N1-GRS-98-2 item 18)

When discussions were being held here regarding deployment of Oracle UCM/URM
(now ECM) there was a question about discarding metadata when a record is
deleted (the options were delete record only, or delete record and metadata)
and the IT folks said delete both.. but I informed them that we had to
retain the metadata for 6 years, just like we do for paper records.  They
balked and said it would take an extensive amount of storage space and it
served no purpose.  I informed them the purpose it served was compliance
with Federal requirements, and they reconsidered their position.

While many may argue it can be a risky situation to retain this type of
data, or paper disposal notices, I see it to be quite the contrary.  It
provides an audit trail as to what was disposed of and when, and in the case
of the electronic records, by whom in an irrefutable manner.  We have had
instances during an audit when records are requested and this documentation
was the only thing that explained why we couldn't produce the records. The
records had been disposed of "in the course of normal business", having met
their retention, receiving disposition approval from the records owners, and
then supported by a destruction certificate.

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Lawrence J. Medina
Danville, CA
RIM Professional since 1972

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