Document Retention Convention

A couple of recent stories provides some tips on creating a document retention policy and my comments are in italics:

  • Document Retention Prevention Properly define "document" to include information of all types-electronic or paper, historical or transient business record. Be sure to include all the different types of records. (A good starting place is Wikipedia’s entry for Records Management which points to the ISO definition of a "record" as "information created, received, and maintained as evidence and information by an organization or person, in pursuance of legal obligations or in the transaction of business".)
  • Clearly state who and what function is the relevant retention authority for the most widely used categories of documents. (It’s important to have one person, one authority, that everyone can go to with questions about a document and it’s retention status.)
  • Indicate the specific duration of retaining different types of documents. (Any good document retention policy that I’ve seen has listed out every document type and its corresponding retention period. They never cover everything but at least it’s a good starting point)
  • Balance the needs of legal, IT and general users. This isn’t easy, because everyone has different needs, but doing so is worth it. (It’s always about communication across departments and across the company.)
  • Clearly state the reasons that retention is necessary (e.g. Sarbanes-Oxley rules, HIPAA regulations). As those requirements change, the rationale for retention should be reviewed, and any changes to the retention period should be made. (This may be easier said than done, but it’s very important to revisit the document retention policy periodically to ensure that it’s up-to-date and accurate.)
  • Give individual divisions or offices the authority to set retention policies for their own operational documents if approved by or coordinated with the General Counsel or Compliance Office. (This may sound antithetical and a little messy, but it can be a functional way to accommodate the different needs of different departments.)

Tips taken from:

"Effective document retention starts with smart policy" from ITBusinessEdge

"Four tips for crafting a document retention policy" from IDG.no

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