What constitutes a long-term record? How should organizations manage records with long retention periods, and assure such records are accessible many years into the future? This white paper, the first in a four-part series, focuses on the definition and basic challenges of long-term record retention and introduces the topics discussed in the following papers.
Human Factors of XR: Using Human Factors to Design XR Systems
Managing Long-Term Records Guide
1. What constitutes a long-term record? How should organizations manage
records with long retention periods, and assure such records are accessible
many years into the future? This white paper, the first in a four-part series,
focuses on the definition and basic challenges of long-term record retention
and introduces the topics discussed in the following papers.
DISTINGUISHING LONG-TERM RECORDS FROM
ALL THE REST
What is the temporal threshold that defines a long-term record? Record
retention requirement periods vary, depending on the information’s value to
the business, regulations and jurisdictions. To a certain extent, organizations
with a “keep everything” culture may find that most of their records are long-
term. Every organization will define long-term records differently as well as the
media types used for retention and storage. Archive solutions will also vary.
Despite these differences, there are some simple guidelines to help determine
your organization’s long-term record threshold:
»» Any record designated as “permanent” qualifies as long-term (see sidebar),
as do those records considered historical for the corporation. These records
may not always be in paper or electronic format, but may include physical
artifacts of the organization’s history.
»» Those records with the longest retention periods in the Records Retention
Schedule (RRS) as mandated by business continuity, law or regulation,
typically 10 years or longer.
»» “Event-based” records whose retention may not begin for a long time after
they are created or received.
»» Records whose value continues past their retention period, by transitioning
to a “big data lake” where the information can be used for analytics.
»» Records housed in systems with older technology that may become obsolete
during the retention period of the record itself. (See sidebar on page 2
regarding common long-term formats for electronic records.)
While the exact definition of long-term records may vary based on an
organization’s specific business drivers, media format and storage solutions,
in general, any record that needs to be stored for more than 10 years can be
considered a long-term record.
CONTENTS
—— Introduction
—— Distinguishing Long-Term Records From
All the Rest
—— Retention Strategies for Long-Term
Electronic Records
—— Practices that Undermines Long-Term
Records Management
—— Management Strategies for Long-Term
Records
—— Conclusion
WHITE PAPER
GUIDEBOOK TO LONG-TERM RETENTION
PART 1: CHALLENGES AND EFFECTIVE APPROACHES
PERMANENT
RECORDS
Permanent records document
significant transactions, policies,
decisions or services and
retain legal, administrative and
historical value without regard
to any timeframe. They should
be routinely committed to a
secure archive in order to provide
accessibility for future users.
2. 2800.899.IRON | ironmountain.com
RETENTION STRATEGIES FOR LONG-TERM
ELECTRONIC RECORDS
Changing technologies will have an effect on the management of long-
term electronic records. The main considerations are predictable hardware
obsolescence, ever-changing software platforms and releases, obsolete data
formats and questionable integrity of storage media. These considerations
can force a change in the way you store your records. Below are some
strategies for meeting these challenges:
»» Convert records from proprietary or potentially obsolete formats to standard
archival formats (see sidebar on PDF/A and NARA 2014-10: Appendix A).
»» Extract electronic records from obsolete software, hardware and other
media into a central repository appropriate for long-term retention, so that
records can be moved from retired systems or media with a short shelf life.
»» Consolidate and/or regularly migrate electronic records to the most current
version of the record format to ensure that they will be readable in the
future (e.g, Microsoft Office application files).
»» Convert records from digital to analog, by printing out digital records and
storing them along with physical record — for instance, adding a small
amount of email correspondence documenting contract negotiations with a
set of hard copy contracts.
Each of these approaches has advantages and disadvantages. Before
undertaking a conversion or consolidation, it is wise to raise the subject with
your information governance council or seek legal advice and make sure the
new format will maintain any metadata necessary to prove its authenticity. The
bottom line is that organizations should have a strategy for dealing with the
inevitable obsolescence of software and hardware systems in place today and
provide for archiving and managing records for the long term.
PRACTICES THAT UNDERMINE LONG-TERM
RECORDS MANAGEMENT
While all organizations face the challenges of long-term records management,
certain practices can make things even more problematic. Here are some
situations that could exist:
»» Retention of records far beyond their required period because an
organization does not want to manage event-driven or conditional retention
periods. As an example, a company decides to keep all employee records for
30 years. While the turnover rate is low, managing the records for according
to the retention schedule (i.e., 10 years after employee departure) would
result in more efficient disposition.
»» Consolidation of all records in a department into a single “high watermark”
retention period (i.e., 12 years) where the majority of the records could be
defensibly destroyed in five years or less.
THE PDF/A
DEFINITION OF
“LONG-TERM”
Here’s some food for thought:
long-term can be regarded as
“…the period of time long enough
for there to be concern about the
impacts of changing technologies,
including support for new media
and data formats, and of a
changing user community, on
the information being held in a
repository, which may extend into
the indefinite future.”1
LEGAL IMPLICATIONS
OF FORMAT
CONVERSION
Rules 1001 and 1003 of the
Federal Rules of Evidence state
that a duplicate of a document
is legally admissible unless
a genuine question is raised
about the original’s authenticity.
Similar guidelines apply in other
countries. Duplicates of long-
term records must be accurate
and trustworthy representations
of the originals, securely stored
along with relevant metadata. So,
are long-term records that are
converted or migrated from one
format (e.g., native format to PDF)
to another legally admissible?
Perhaps, but before embarking on
a conversion, involve legal counsel
in the decision.
1
Source: ISO 19005-1:2005 (PDF/A-1)
3. 3 800.899.IRON | ironmountain.com
»» All information for a single activity is kept, regardless of
the legal or regulatory requirements, multiple versions
and drafts, correspondence and other trivial information
that was not separated from the record content.
»» Blanket legal holds are widely used to preserve records,
as opposed to targeted groups of records.
»» No formal email management program.
In all of these scenarios, it is very difficult if not impossible
for Records and Information Management (RIM)
professionals, without the assistance of technology, to
identify the legitimate long-term records they should
preserve and remove the duplicate, obsolete or transient
information from the storage media or physical container.
There is no question that saving everything for the long-
term drives up storage costs and increases the expense
and risk of legal discovery.
MANAGEMENT STRATEGIES FOR
LONG-TERM RECORDS
In many ways, the practices and procedures for managing
long-term records should differ little from those used to
manage any other kind of records. These strategies should
come as no surprise to RIM professionals.
»» Start with an up-to-date and media-agnostic enterprise-
wide records retention schedule and corporate
classification plan. Business, regulatory and legal
requirements are always changing, so the classification
plan and schedule should be reviewed at least annually
and updated as needed.
»» Classify long-term and permanent records using
repeatable processes, assisted classification or
automated classification as much as possible. This
process is much easier when first creating or receiving
the information rather than later on when it is no longer
actively used.
»» Segregate short-term and long-term data. Do not simply
apply a generic, long retention rule to all records created
from a single activity or department.
»» Use a modern data management system, coupled with
defined reviews or periodic processes to manage your
event-based and conditional electronic data and prevent
over-retention of records.
»» Prepare an index of inactive information needed to be
retained for a long period of time to make it easier to
retrieve the occasional record when required for legal,
regulatory or business productivity.
»» When feasible and to reduce ambiguity, the term
“permanent” should be replaced with a measureable
time period (i.e., 30 years).
»» Create an overall strategy for dealing with the eventual
obsolescence of your business applications so the
appropriate records and transactions can be indexed
and stored in a long-term format that can be accessible
for the life of the retention period. This strategy will
ensure that your records are available when needed, and
greatly reduce the number of obsolete applications being
managed
CONCLUSION
Records and Information Management departments face
many challenges when dealing with the organization,
retrieval, disposition and preservation of long-term records.
Consistent strategies for each of the major challenges
and continual governance and review of your information
environment can greatly reduce both the cost and risk of
long-term retention.
Subsequent papers in this series will go into greater
detail on the key issues of long-term retention to outline
procedures, technologies and practical strategies for
addressing these issues, including:
»» Developing an effective media strategy for
long-term retention
»» Managing long-term retention of event-based or
conditional records
»» Management and disposition of long-term records in
databases and structured applications