Chapter 3

Scheduling

In This Chapter

Examining scheduling options

Researching retention periods

Obtaining retention period approvals

Creating the retention schedule document

Implementing the retention schedule

Maintaining the schedule

A retention schedule is a document that provides an organization with direction on how long to keep their records and information, but you need to keep in mind that having a retention schedule is more than just knowing when it’s okay to get rid of something. An organization that implements a well-designed and researched retention schedule can also benefit from better compliance to regulations, use of office space and computer storage, response to legal and audit matters, and record and information life cycle management.

Traditionally, retention schedules have focused on official company records. However, due to the corporate explosion of information, many organizations are realizing that they have huge amounts of electronic data residing on computers and servers that aren’t official company records, but have business value. Companies are now taking action to manage the life cycle of this type of information by accounting for it on the retention schedule.

A big part of developing a retention schedule is determining how long to keep the different types of records and information that were documented during the appraisal. This chapter provides guidance on how to research and determine the correct retention periods for your records and information, along with determining what type of retention schedule to use, how to implement the schedule, and how to give it a tuneup.

Keeping Your Options Open

The retention schedule is the most important and frequently accessed records and information management document within an organization. Therefore, it is vital to ensure that the schedule is developed in a manner that meets the company’s legal and compliance needs as well as the processing needs of employees. A well-designed and formatted retention schedule provides employees with clear instructions on how to classify and retain their records and information.

Completing the appraisal is the first step in developing a retention schedule. The next step is choosing a schedule format. In most cases, the appraisal method you used (departmental or functional; see Chapter 2 for more on the distinction) will be a factor in how you construct the retention schedule.

You find three primary retention schedule formats:

Departmental

Functional

Big Bucket (sometimes referred to as a flexible schedule)

The following sections provide examples of the different schedule formats, their benefits, as well as any issues that need to be considered. This information should be carefully examined by organizations to ensure that the ­retention schedule option chosen meets their legal, regulatory, and operational needs.

Note: The retention schedule examples covered in the next four sections only represent the different formats. Later in this chapter, I go over all the components related to retention schedules. In addition, the retention periods used in the following format examples are only for representation purposes. Later, this chapter covers how to determine the appropriate retention periods for your organization.

Working with the Departmental retention schedule

The Departmental retention schedule is the most prominent of the schedule formats, and it provides your organization with the most detail. (See Figure 3-1.) The Departmental retention schedule — as its name implies — individually lists all record series or types that are assigned to a particular department.

The Departmental retention schedule is favored by many organizations because it’s the one option that provides them with a comprehensive listing of all official company records. Doing it that way helps to provide the following benefits:

Retention applied to individual records: The Departmental retention schedule allows each record type to be assigned a retention period. This ensures that records are only kept as long as they’re required. The other retention schedule options assign retention to functions made up of individual records or apply retention to individual record types based on a limited category of retention periods. Such approaches create the potential of keeping records too long.

Litigation, audit, and inquiry response: In the event of litigation, audits, or governmental inquiries, a Departmental retention schedule allows specific records relevant to the event to be easily identified and collected. The other retention schedule options require employees to know which records are part of a particular function. This may increase the chance that some records get overlooked.

Easy to understand: Listing individual record types by department makes it easier for employees to understand how long they need to retain specific records versus individual records being lumped under a function.

More effective life cycle management: The Departmental retention schedule approach allows companies to more effectively manage the entire life cycle of individual record types. By assigning retention periods to each record, an organization is able to move records to offsite storage or migrate them to less expensive electronic storage on an individual basis, and dispose of specific record types when their retention period has expired instead of managing multiple record types as one large group because they are related to a single function.

Compared to the Functional and Big Bucket retention schedule formats, the departmental approach has potential downsides:

More line items: Listing each department’s individual record series causes the retention schedule to become very lengthy.

Redundant entries: Multiple departments may have the same record series name listed on their portion of the retention schedule. For example, the Benefits department and Public Affairs department may both have a record series of “Correspondence” listed under their area. This creates duplicate entries and increases the length of the schedule.

Conflicting retention periods: Different departments may have different retention periods for the same record series. For example, one department may retain “Policies and Procedure” records for five years, while another department retains them for seven years. This results in inconsistencies in retention periods.

Harder to maintain: The additional line items on a retention schedule results in more effort in updating changes to the record series (changes in retention periods or deletions of an inactive record type, for example).

Scheduling based on function

Functional retention schedules group together common records series that are part of an organizational function, regardless of the department where the records are created or maintained. Instead of listing individual departments and their respective records, the Functional retention schedule lists major functional categories and the subfunctions that support it, as shown in Figure 3-2.

The Functional retention schedule lumps related functions under a functional category. In the example shown in Figure 3-2, all the functions listed have one thing in common — they are part of the Financial Management function. A specific function such as Accounts Payable may have a different retention period from the others. For example, Accounts Payable–related records may need to be retained for seven years, while Budgeting records may only need to be retained for three years.

Following are some of the issues that should be considered before adopting the Functional retention schedule approach:

Requires a thorough knowledge of business processes: Creating a Functional retention schedule requires you to have an understanding of the organization’s business processes and the records that are part of the functions, resulting in increased development time.

Demands a significant culture change: The Functional retention schedule approach requires a shift in employee thinking. Most employees instinctively relate their records to the work they perform; for them, seeing their records as being part of a bigger organizational process can be a stretch. The focus should not be on who owns the work, but rather on how the work is processed.

Some organizations create a separate reference document that provides details about each individual record series listed on their Functional retention schedule. Figure 3-3 gives an example of what that would look like.

The Functional retention schedule provides the following benefits:

Ensures a concise retention schedule: The Functional retention schedule has fewer line items than a standard Departmental schedule. This approach makes classifying records and information convenient for employees. Employees don’t have to classify individual record types; they are able to apply aggregate classifications to all records related to a function.

Calls for fewer record series to maintain: Having fewer individual record types listed on the schedule makes it easier for the organization to update the schedule.

Eliminates duplicate record series: Unlike the Departmental retention schedule, the Functional retention schedule does not contain duplicate record types, which also promotes retention period consistency.

Reflects actual business processes: The Functional retention schedule is designed to mirror the organization’s business processes. This approach provides the ability to quickly identify company functions.

Promotes standard naming conventions: Organizations that use a Departmental retention schedule may have identical record series assigned to multiple departments. Although each record type is identical, departments may refer to them differently. For example, the Customer Care department may refer to correspondence as customer communication, while another department refers to it as correspondence. The Functional retention schedule lists the record type once, using a standardized name and description.

Bring out the big buckets

The Big Bucket retention method is the newcomer to the retention schedule format family. The National Archives and Records Administration (NARA) is credited for being the early adopter of this approach, introducing the concept back in 2004.

Like any new concept that bucks traditional thinking, big buckets have been the topic of heated debates in the records and information management community. Although the Big Bucket approach has not been widely adopted at this point, it is gaining momentum as organizations struggle to find a convenient (but compliant) method to manage their growing population of records and information.

The issue that organizations face today is that they are stuck with way too many categories of records, a state of affairs that can make it difficult for employees to properly classify them. The Big Bucket concept is meant to remedy this. It takes the Functional retention schedule a big step farther by creating a set of retention buckets: — 3, 5, 7, 10, and 50 years, for example. This approach assigns individual records to an aggregate function (like the Functional retention schedule). The function is then grouped with similar functions to create a major function. The major function category is then assigned a retention period. Figure 3-4 illustrates the principles behind the Big Bucket concept.

The example shown in Figure 3-4 represents an organization that has decided (for classification and record-retention purposes) to consolidate three separate accounting-related departments into one major function — General Accounting. The decision in this case was made to use the Big Bucket approach for the organization’s accounting functions and assign a retention period of seven years to this particular “bucket,” even though some individual record series may have a retention period of less than seven years and some may have periods of more than seven years.

The following are advantages to adopting the Big Bucket retention approach:

It simplifies classification. The Big Bucket retention schedule approach makes it easier for employees to classify records by reducing the number of classification choices. The Big Bucket approach makes classification of records faster, thus helping to reduce classification backlogs.

It promotes consistency. Because the Big Bucket retention schedule method lists only major processing functions, it significantly increases the consistency and accuracy of classification and retention.

It’s easier to maintain. The status of individual records series sometimes changes. This may be due to a retention period modification, the fact that the record is no longer created or received by the organization, or by a change of the record’s name. In most cases, the Big Bucket retention schedule can take such modifications in stride because its schedule accounts for major functions instead of focusing on individual records types.

The following issues are considered potential disadvantages to using big buckets:

It can lead to increased retention. Because the Big Bucket retention method lumps related functions into one major function, the potential exists for some individual record types that support these functions to be retained longer than required. The Big Bucket category for General Accounting, for example, may be assigned a seven-year retention period. Imagine, however, that the purchase order records that support the Accounts Payable function, which falls under General Accounting, may only be required to be retained for two years. The decision to retain records longer than required is usually based on risks and costs.

It can result in a decrease in descriptive data. Because the Big Bucket retention method lists only major processing functions, it significantly reduces the amount of descriptive data related to individual records than would be available on a Departmental retention schedule. Records and information managers, attorneys, and tax department employees rely heavily on descriptive data to search for records and information to respond to lawsuits, audits, and inquiries.

It can render event-driven retention impossible to manage. Some records are assigned event-driven retention periods. This means that the retention clock doesn’t begin to tick until an event occurs. Employee personnel files, for example, may be assigned a retention period of ACT + 10 years. “Active” in this case refers to duration of employment. The ten-year retention period starts when the employee leaves the company. If an employee works for a company for 5 years, the total retention period for the employee’s personnel file will be 15 years. Big Bucket retention schedules don’t allow event-driven situations. This issue is commonly resolved by adding conditional retention buckets to handle these types of records.

Deciding on a retention schedule format for your organization is a very important process that impacts the future of the company’s records and information management program. The decision-making process should be a group effort, including the Records and Information manager and the Legal, Risk Management, Tax, and Compliance departments (if applicable). This approach allows each group to carefully examine the formats and determine which method best meets the organization’s needs.

Conducting the Investigation

Now that you have decided upon a retention schedule format, you need to put on your research cap. Whether you choose to use the Departmental, Functional, or Big Bucket retention schedule approach, you need to determine what retention periods to assign to your records and information.

Determining appropriate retention periods involves the consideration of federal and state regulatory requirements, contractual obligations, intellectual property requirements, and statutes of limitations, as well as administrative needs specific to the industry in which you operate. If you operate in a heavily regulated industry such as nuclear energy, petroleum, insurance, or pharmaceuticals, for example, the respective industry’s governing bodies or governmental legislation may have already established the retention period of some of your records.

It only takes a simple search of the Internet to find a multitude of sites telling you how long to keep your records and information — but be sure to take such information with a grain of salt. Retention periods found on the Internet may provide you with retention food for thought, but the authors of these sites don’t know the intricacies of your business. For the majority of organizational records and information, no absolute retention rules exist. Each organization has its own needs and nuances. One organization may keep a record series for a certain length of time, while another company retains the same record series differently. Therefore, retention recommendations found on the Internet shouldn’t be used to formulate the retention of your records and information.

Considering the value

Retention periods aren’t arbitrarily assigned. They are determined by appraising a records value to an organization. As part of that appraisal process, you need to evaluate four primary record value categories:

Administrative: The majority of records kept by an organization are assigned retention periods based on administrative or operational need instead of by applying a retention period based on requirements mandated by outside regulatory entities. In this context, you’re retaining records because you need them to conduct your business — nothing more and nothing less. Examples of records retained for administrative purposes may include policies and procedures, correspondence, and budgets.

Legal and regulatory: In this context, records should be appraised for their legal and regulatory value. Doing so ensures that the records are retained for the appropriate length of time to ensure that organizations are positioned to meet and respond to their legal and regulatory compliance obligations.

Fiscal: A fiscal appraisal determines the usefulness of a record in serving as documentation of the organization’s financial transactions.

Historical: A historical appraisal involves assigning retention periods to records that document organizational history. This includes records such as company photographs, newsletters, and press releases.

Researching retention periods

The credibility of your organization’s Records and Information Management program is gauged in large part by the accuracy of its retention schedule — more specifically by the retention periods you assign to your records and information. The best way to ensure retention period accuracy is to research laws and regulations that impact your company, as well as its operational needs.

The retention of most organizational records is determined by administrative or operational needs. This means that the retention period is not mandated by an outside entity such as the federal government, but by how long records and information serve their intended business purpose. An example of an administrative record is budgets. Budgets are formulated at a specific time of year for the upcoming fiscal period. The document is needed during its respective budget year and is used as a planning tool for the next year. After that point, the budget document likely serves no business purpose to the organization and can be destroyed.

However, the retention period of records such as financial statements, private health information (PHI), and customer payment card data is mandated by federal law or industry compliance standards. In some cases, laws and regulations are vague and don’t provide specific retention periods for records. In these cases, the appropriate organizational employees have to examine the issue and determine retention periods to assign that can help to ensure compliance and reduce risks to the company.

Regardless of whether your records are of an administrative nature or are governed by outside entities, you will still need to conduct research. Using the value categories as your guide, you can begin to categorize your records and information in preparation for researching, determining, and applying retention periods. The retention schedule method you decide to use (Departmental, Functional, or Big Bucket) will have an impact on your research. If you use the Departmental approach, you have to research and determine the correct retention period for individual records. If you use a Functional retention schedule, you need to assign the appropriate retention to each function. If you use a Big Bucket approach, you have to determine the correct retention period for the major functions of the organization.

Researching record retention periods takes teamwork. Normally, it involves the Records and Information Management, Legal, Tax, and Risk Management departments, along with department owners of the records and information. The Records and Information Management department should take the lead, conducting the initial research, making recommendations, and coordinating communications with the other departments.

Understanding your industry, departmental functions, and supporting records and information is the key to starting your retention period research. Becoming familiar with the function of a department can help you understand how to direct your research. The appraisal forms I describe in Chapter 2 — the ones I told you to use when inventorying your organization’s records and information — are a great starting point. An effectively designed appraisal form provides the ability for you to gain insight on departmental functions, how records are used to support the functions, and how long the department is currently retaining the records.

To assist you in starting your research, I want to highlight some record types paired with the retention periods traditionally assigned to them. For example, accounting-related records are usually assigned a seven-year retention period for tax purposes. Figure 3-5 lists some of these record types and their corresponding retention periods. Note: This information should only serve as a guide. You should check with your attorney or tax accountant before implementing any record retention periods.

Mining your natural resources

You have a number of different options when it comes to conducting retention period research. Although the Internet can be a great resource for finding out how different laws and regulations may impact your retention strategy, make sure that you only access the appropriate federal, state, or municipality websites to get information. Third-party sites that boast about how they can “clarify” federal, state, or local laws may be offering (unfounded) opinions and interpretations of a law or regulation.

As you are conducting research into laws and regulations that impact your record retention, you should document the specific citation that provides information regarding record retention. Documenting the citations you’re using as the basis for your retention approach adds credibility and defensibility to your organization’s Records and Information Management program. In addition, it can be a great help to the other departments that need to review and approve the retention schedule. The following is an example of how a citation impacting record retention might look:

Securities and Exchange Commission (SEC) 17 CFR Part 210

In addition to the Internet, retention research software applications offered by some Records and Information Management vendors are a good option for medium to large organizations, as well as those companies that operate in highly regulated environments with multiple geographical locations. In most cases, you purchase the software and licenses and then subscribe (for a fee) to periodic updates, which include new federal and state laws or changes to existing laws. Two of the leading vendors in the United States providing retention research software are as follows:

Information Requirements Clearinghouse, at www.irch.com

Zasio, at www.zasio.com

Another resource to consider when developing your records and information retention schedule is a consultant. You can find many qualified and reputable Records and Information Management consultants who specialize in record appraisals and record retention schedule development. If you decide that this is a good option for your organization, it is important to do your homework and find a vendor that has experience with paper and electronic records and legal and regulatory research, as well as a client reference list. It’s recommended that the records management consultant you choose have been awarded the Certified Records Manager (CRM) certificate from the Institute of Certified Records Managers. The certification provides assurance that the consultant has adequate knowledge of the record retention schedule process. Consulting services can be expensive. However, if you don’t have the necessary experience in-house, or do not have the time to conduct proper research, the investment is well worth the peace of mind of knowing that you have a legally defensible schedule.

For smaller organizations, you can utilize a CPA or attorney to develop your records and information retention schedule. In most cases, this will prove more economical than hiring a consultant.

As you continue your research journey and begin to assign retention periods to record series and functions, you can use the chart depicted in Figure 3-6 to see whether you are in the retention “norm” of a cross section of industries. The chart provides ranges of retention periods and what percent of organizational records are assigned to each range. Note: This chart is only for reference purposes to help you determine whether you are possibly assigning too many records to a specific retention period range. Depending on your organization and industry, your retention period allocations may conform to these guidelines or may vary to some degree.

When conducting research and assigning retention periods to departmental records, you most likely will encounter duplicate records among departments, such as correspondence, budgets, and policies and procedures. In this case, unless a specific departmental need exists, it’s recommended that you assign the same retention period to like record types for the sake of program consistency. (This is not an issue if you are creating a Functional or Big Bucket retention schedule because you are assigning retention periods to functions rather than to individual record series.)

Assigning retention periods to nonrecord information

The volume of nonrecord information in an organization is much greater than the population of official company records. In this context, nonrecord information doesn’t meet the criteria of a record and may include content such as spreadsheets, presentations, and other referential material. The retention of nonrecord or business-value information is not determined or governed by any outside entities. Nonrecord information should only be retained for the length of time it serves a business purpose — after that, it should be ­discarded.

Most companies that come up with retention periods for business-value information are doing so by assigning blanket retention periods. The retention period assigned, however, usually varies by department. A department (and the information it creates or receives) is evaluated for risk and sensitivity. For example, the nature of information in the Legal or Compliance department may be deemed to present more risks or be more sensitive than information received or created by the Facilities Management department, resulting in a longer retention period.

Such an approach would lead one to determine that, for the Legal department (to take that example), all business-value information is to be destroyed after three years from the date it was created. The rationale behind such a directive is that the Legal department’s nonrecord information shouldn’t be of value to the organization after three years. (Note that, if after three years, certain business-value information is still considered important, the information should be reevaluated to determine whether it needs to be classified as a company record.)

Looking for Approval

Obtaining retention period approvals is an important step in the development of the retention schedule. Retention periods shouldn’t be developed in a vacuum by any one employee or department. Although the Records and Information manager (and staff) drives the initial retention research process and documents retention periods and applicable citations, approval should be a team effort.

In most companies, the approval team consists of department management (owners of the records and information), the Records and Information manager, and a representative from the Tax and Legal departments. This approach provides a comprehensive and expert review of the retention periods, and can help spot any issues that may result in adjustments to how long the records and information need to be kept.

Department management

Department management and their staff are the owners and users of the records and information. They have the most knowledge of how long records need to be retained to support the processing of departmental functions. In addition, they can provide important insight into the active period of their records. This is the period that the records need to be readily accessible for processing. Understanding the active period allows you to assist the department in moving the records to an inactive storage location, which helps eliminate clutter in the department.

Paying a visit to the Tax department

Your Tax department or tax accountant should review the retention periods you have developed to ensure that they adequately meet the organization’s tax-reporting obligations. The Tax department can provide you with information regarding tax retention periods related to routine functions as well as tax audit requirements.

Legalizing your retention

The Legal department plays a vital role in the review of the records and information that will be listed on the retention schedule and the assigned retention periods. A legal review helps to ensure that organizational records and information are retained in a manner that improves the company’s defensibility, reduces risks, and provides credibility.

The Legal department understands the types of organizational functions that are prone to litigation and risks and knows how long the records that support the functions should be retained to improve the company’s position.

Creating the Retention Schedule Document

After you receive the necessary retention period approvals, you are ready to begin constructing the retention schedule document — that crucial piece of paper (either real or virtual) that will be distributed throughout the organization to provide employees with the direction they need to manage the life cycle of their records and information.

Some organizations, especially those that use the Big Bucket retention schedule approach, may only have one retention schedule that is used throughout the company, while other organizations that use either Departmental or Functional retention schedules may deploy multiple retention schedules. Usually companies that use multiple retention schedules do so because they have different operations with distinct functions.

An effective retention schedule is designed to provide information in addition to just retention periods. The following sections list the different components of a retention schedule and describe how they benefit the organization.

The pieces to the retention schedule puzzle

Although the retention period assigned to a record may be considered the single, most important piece of information on the schedule, other parts of the schedule are also important in managing its life cycle.

When choosing the components to be included as part of the retention schedule, remember that a schedule’s primary purpose is to help employees manage their records, so keep it as simple and easy to read as possible. Cluttering the retention schedule with things that have no meaning to employees will reduce adherence. Some organizations create separate schedules for employee use and Records and Information Management department use. The former schedule is simplified and only contains items that are relevant to departmental employees, while the latter schedule provides more detail that can be useful in the event of an information hold order or audit.

The following is a list of commonly used retention schedule categories. The list contains information that is specific to the Departmental retention schedule format. However, some of the categories are common across all retention schedule formats (Departmental, Functional, and Big Bucket). Common categories are denoted with a C.

Record series name: This is the official name of the record. Avoid using nicknames or abbreviations.

Record series description: This section is used to provide details about the record, such as departmental nicknames or abbreviations used to refer to the record. In addition, this section should be used to provide information about how the record is used in support of a function.

Record series code: The record series code is a unique identifier for the record series. This type of code is used primarily in conjunction with a records management or Enterprise Content Management (ECM) software application. It allows the system to track activity related to a specific record type. The identifier is usually comprised of an alphanumeric code such as FIN0001. This represents the first record series in the Finance department.

File plans: A file plan is a classification scheme describing the different types of organizational files and records. The file plan document is separate from the retention schedule and provides additional information about a record. Some organizations opt to not use a file plan in lieu of an effectively developed retention schedule. (File plans often make use of record series codes.)

Start code: A start code tells you when the retention clock should start ticking. You find several common start codes, such as Current Month (CMO), Active (ACT), and Permanent (PERM). Some organizations also use a start code of Tax (TAX). Start codes are used in conjunction with retention periods, such as CMO + 3 years.

For example, a start code of CMO means that the retention period starts in the month that the record was received or created. A start code of ACT means that an active period exists prior to starting the retention period. An employee personnel file may have a retention period of ACT + 5 years. The active period is the duration of employment, whereas the five-year retention period begins when the employee separates from the company. The next one is self-explanatory — PERM means that it is retained forever. The start code, TAX, indicates that the retention clock starts ticking in the current corporate tax year.

Trigger event: A trigger event is an occurrence that starts the retention period of a record. A trigger event pertains specifically to the ACT start code. Every record series that is assigned an ACT start code has a trigger event. This includes records such as contracts, employee files, and policies and procedures.

In the case of a contract, the trigger event is when the contract expires. An employee file experiences a trigger event when an employee separates from the company. The trigger event for policies and procedures occurs when they are updated or superseded.

Retention period (C): The retention period represents how long the record series or records related to a process or function need to be kept before they can be destroyed. One option to the standard Total Retention Period section is to break it out into two additional sections — an Active retention period and an Inactive retention period.

The Active period represents the time frame that the record series is frequently accessed and needs to be stored in the department or on online storage (electronic records) for quick retrieval. The Inactive period is the period of time in which the record series is no longer frequently accessed, but still must be retained for tax, legal, or regulatory purposes. Records that have reached their inactive period can be taken out of file cabinets and placed in box storage. Inactive electronic records can be migrated to near-line or offline storage.

Retention rules (C): Retention rules provide information to departments on what to do with a record or groups of related records after the retention period has expired. For example, retention rules could specify which records will be destroyed and which will be forwarded to the Records and Information Management department for permanent archival.

Media format (C): Media format pertains to whether a record series or groups of records are in paper or electronic format or both. (An example of both would include Accounts Payable invoices.) An organization may receive paper invoices from one vendor and electronic invoices from another.

Retention periods apply to record series (or, in the case of a Functional or Big Bucket retention schedule, related groups of records), regardless of their media format. In addition, during a lawsuit, audit, or inquiry, a Media Format section in the retention schedule allows the person searching for relevant records to know that the information is in multiple formats and that he may have to search file cabinets as well as electronic applications.

Vital (C): This section of the retention schedule alerts employees to what record series or groups of related records are vital to the organization in the event of a disaster. By indicating on the retention schedule which records are vital, employees can know at a glance which records have been earmarked for special protection so that they can be accessed quickly to assist in business resumption efforts. When using the Functional or Big Bucket retention schedule format, you should provide information about specific records that are considered to be vital to a function.

Citation (C): This area of the schedule provides information on what laws and regulations govern the retention period of a record series or function. This information allows organizations to respond to questions from outside parties in the case of lawsuits, audits, or inquires as to why certain records are still retained or have been destroyed. When using the Functional or Big Bucket retention schedule format, you should indicate laws and regulations that apply to specific functions.

Organizations using a Functional retention schedule may use all or some of the previous “common” categories, plus the following categories:

Departmental category: This section lists the departments of the organization, such as Accounts Payable, Facilities Management, and Legal.

Record group: This category provides further description of the record types assigned to the department.

Process description: This section provides information regarding the department’s processes and the records that support departmental functions.

Big Bucket retention schedules may use all or some of the “common” sections in addition to the following:

Functional category: A functional category is comprised of multiple departments. The functional category General Accounting may be comprised of Accounts Payable, Accounts Receivable, and General Ledger.

Departmental category: This section lists the departments assigned to the Functional category.

Functional description: The description provides details about the function and related processes.

Use Figure 3-7 as a quick reference tool to determine which record retention schedule components are assigned to each schedule format.

Sampling retention schedule forms

Many options exist for documenting your record retention schedule. Some organizations use a form format, while others prefer to use a narrative format — both methods are acceptable. In this section, I have you take a look at both approaches so that you can determine which format works best for your company.

Form formats

Organizations that use a form format may choose to do so because they feel it is an easier read — just like how scanning bullet points can be easier on the eyes than reading a document that is full of paragraphs. The form option lists the categories in a logical sequence, regardless of whether you are using a Departmental, Functional, or Big Bucket retention schedule. Figures 3-8, 3-9, and 3-10 provide examples of the different retention schedule formats using the form option. Note: Additional retention schedule form examples are provided in Appendix A, available online at www.dummies.com/go/recordsmanagefd.

Narrative formats

This approach conveys what is usually found in the form format without the form structure. The narrative option can be used for all retention schedule formats. Figure 3-11 represents a Functional retention schedule using the narrative approach.

Implementing the Retention Schedule

Now that your retention schedule document is complete, you need to decide the most effective way to implement it across your organization. Employees are looking for Records and Information Management guidance. The retention schedule provides what they need. It is the most accessed program document. Therefore, it is important to select a distribution method that can get the document on the monitors of the masses.

Keeping it electronic

The retention schedule should be distributed electronically. In addition, employees should be instructed not to print the retention schedule or download it to a hard drive or network drive. Departmental retention schedules are usually updated several times annually. Functional and Big Bucket schedules are modified less frequently. If employees are printing or downloading the schedule, they may not have the most current version, which can lead to records and information not being retained appropriately.

The ideal distribution outlet is the company’s intranet. By developing an intranet website where employees can access the retention schedule, your company can help ensure that its employees are applying the correct retention periods. If your company doesn’t have an intranet, you can place the retention schedule in a designated folder on your network that is accessible by all employees. Small businesses that do not have an intranet or company network can print the retention schedule as needed and inform employees when updates have occurred.

Providing direction

When introducing the retention schedule to the organization, it’s a good idea to create an accompanying “directions” document of some kind. Such a document can help employees understand how to read and use the schedule. The document should provide information on each retention schedule category as it appears on the schedule.

Although the retention schedule is somewhat self-explanatory, some Departmental retention schedule categories are traditionally a point of confusion for employees — such as record series codes, start codes, trigger events, media formats, and vital. Providing additional information and directions on how to interpret these categories can help employees feel at ease with the schedule.

Updating the Retention Schedule

Retention schedules are dynamic — they change, some types more than others. Retention schedules are developed based on business functions, legalities, regulations, and administrative needs. Chances are that if changes occur in any of these areas, they will result in a change to the retention schedule.

Modifications to the retention schedule may include a change to the retention period of an existing record, the addition of a new record, or the deletion of a record no longer in use. The Departmental retention schedule is the most susceptible to change, while the Functional and Big Bucket formats are the most immune.

For example, if the federal government enacts a change to a healthcare privacy and protection law, such a change may impact the retention of one or more record series on the departmental schedule. In this scenario, a Functional or Big Bucket retention schedule needs to be reviewed to determine whether the retention period assigned to functions (and supporting records) is adequate to comply with the changes in the law.

In many cases, you may not be aware of a change in a law, regulation, or business process that impacts the retention period of a record. Therefore, it’s recommended that you create a mechanism that allows employees to submit a change request form to the retention schedule.

Creating a template or web form that can be made available on the company’s intranet is an ideal way to allow employees to submit their changes. A template form (see Figure 3-12) ensures that you are provided the required information that you need to start the change process. If your company does not have an intranet, an e-mail template form can be created for the same purpose.

In addition to processing periodic retention schedule changes, it is recommended that a comprehensive review of the organization’s retention schedule be conducted on an annual basis. A review of this type helps to ensure that the retention schedule is staying current with organizational changes. The following list describes some areas to target during the review:

Acquisitions or divestitures: Has the organization acquired any companies during the past year? Most acquisitions result in new operations, functions, and records being added to the organization. In addition, has the organization divested itself of any operations? If so, the retention schedule needs to be updated to reflect the change.

New or defunct departments: Has the organization created any new departments not listed on the current retention schedule, or deactivated any departments that were listed on the retention schedule?

Consolidation of departments: Have any departments combined operations? If so, their functions and records may need to be combined on the retention schedule.