ITS 833 – INFORMATION GOVERNANCEChapter 9IG AND RECORDS AN.docx

ITS 833 – INFORMATION GOVERNANCE
Chapter 9
IG AND RECORDS AND INFORMATION MANAGEMENT
FUNCTIONS
Dr. Sandra J. Reeves
Copyright©2018 Sandra J. Reeves
All Rights Reserved

This chapter deals with the concept of records management. It is
sort of a crash course on records management. There are those
who have the mistaken idea that records management and
information governance is the same thing. It is not. Information
governance covers so much more than just records management.
This is a very long chapter. It should probably have been
divided or broken into two chapters, but there doesn’t seem to
be a good breaking place. If you look at the next two pages that
sort of summarizes what you need to take away from this
chapter. The chapter is an important one for your semester
project. Further, please don’t make the mistake of thinking that
everything you need to know from this chapter is included on
the power point slides. That is not the case. You have to still
read the book and understand what you are reading.
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CHAPTER GOALS AND OBJECTIVES
Know what is records management
How to implement ERM (electronic records management
Benefits of ERM
Principles followed in ERM
Why is ERM so challenging?
What is involved in inventorying electronic records?
What are the steps in inventorying e-records?
What are the challenges associated with e-records inventorying?
What is the purpose or reason for e-records inventory?
Type of information to be collected in the inventory process
Who should conduct the e-record inventory?
Approaches to the e-record inventory process?
Be able to conduct an e-record inventory using the survey
method
Be able to conduct an e-record inventory using the
questionnaire method
Be ale to combine the survey method and then follow up using
the questionnaire method
What is record appraisal? What is it used for?
What principles are involved in retention scheduling?
What is retention scheduling?
How would you go about developing a records retention
schedule?
Why are retention schedules needed?
What type of information would be included on a retention
schedule?
What steps would you use to develop a retention schedule?
What is an information map? What is it used for?
What do you do if you don’t have an information map?
What are the basic classification of records?
What is the difference between a business function and a
business activity?

What is a “document type”?
What is a record series?
What is the rationale for records groupings?
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See Slide above and on the next page for the requirements of
this chapter
CHAPTER GOALS AND OBJECTIVES…continued
What is a case record?
What are subject records?
Are emails records?
What guidelines would you use to determine whether an email
message should be considered a business record?
How long should old emails be kept?
How will determine how long to retain old email records?
What is a limitations period?
What is the most important consideration in determining the
retention period and destruction of records?
How will you know the legal requirements for retention and
destruction?

What is event-based retention?
How is event-based retention different when dealing with
government entities?
What are the prerequisites for event-based disposition?
What is the criteria for final disposition and closure?
What are typical closure dates?
What is a transitory record?
Final steps before implementing a retention and disposal
schedule
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See goals on this page and on page 2 of slides
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What
“Record” – information created, received and maintained as
evidence and information by an organization or person, in
pursuit of legal obligations or in the transaction of business –
(ISO definition)

“Records Management” – Field of management responsible for
the efficient and systematic control of the creation, receipt,
maintenance, use and disposition of records, including the
processes for capturing and maintaining evidence of and
information about business activities and transactions in the
form of records. Traditionally, used more often in highly
regulated industries such as banking, energy, pharmaceuticals.
RIM – Records and Information Management – beyond RM to
include information –data, e-documents and reports. Must
include policy retention and disposition.
Electronic Records Management (ERM) – Organization,
management, control, monitoring, and auditing of formal
business records that exist in electronic form. Applies business
rules to manage the maintenance, preservation and disposition
of records.
Same principles as for traditional paper-based records
management
Classification
Taxonomy
Retention
Disposition
RECORDS MANAGEMENT AND INFORMATION
GOVERNANCE ARE NOT THE SAME THING
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The ISO defines a business record as: “Record” – information
created, received and maintained as evidence and information
by an organization or person, in pursuit of legal obligations or
in the transaction of business – (ISO definition)
It then defines “Records Management” as the Field of
management responsible for the efficient and systematic control
of the creation, receipt, maintenance, use and disposition of
records, including the processes for capturing and maintaining
evidence of and information about business activities and
transactions in the form of records. Traditionally, used more
often in highly regulated industries such as banking, energy,
pharmaceuticals.
You will also see the acronym “RIM”. This stands for records
and Information Management – It goes beyond Record
Management to include information –data, e-documents and
reports. A professional in the area of Record and Information
Management will have greater responsibility over a wider area
as RIM managers must be proficient in the area of policies for
retention of records as well as disposition of legally
discoverable information and must know the relevant laws as it
relates to each.
Another term you will hear in this chapter is Electronic Records
Management (ERM) – This is more of a hot topic today. It has
moved to the forefront of business issues due to the increasing
automation of business processes and the growth of electronic
documents. Further, greater legislation is being passed out of
increased need. The definition of ERM is the “Organization,
management, control, monitoring, and auditing of formal

business records that exist in electronic form”. That is, you
apply traditional business rules to manage the maintenance,
preservation and disposition of electronic records.
You will use the sprinciples as for traditional paper-based
records management: Things like: Classification, Taxonomy,
Retention, and disposition
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More Definitions!
Information Governance: Policies, processes, and technologies
used to manage and control information throughout the
enterprise to meet internal business requirements and external
legal and compliance demands
Enterprise Content Management (ECM) – Encompasses all of an
organizations unstructured digital content including but not
limited to comprised of ERM, Web Content Management,
digital asset management, enterprise report management, and
other technology sets
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More definitions! From this perspective of electronic records
Information governance is defined as the Policies, processes,

and technologies used to manage and control information
throughout the enterprise to meet internal business requirements
and external legal and compliance demands.
There is also something called enterprise content management
or “ECM”. This is a term you will hear from time to time. It
Encompasses all of an organizations unstructured digital content
including but not limited to comprised of ERM, Web Content
Management, digital asset management, enterprise report
management, and other technology sets. Electronic Records
Management extends enterprise content management to provide
control and to manage records through their lifecycle from
creation to destruction.
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Records Management Business Rationale
Why is RM important in nearly every industry now?
Increased government oversight and industry regulation
Sarbanes-Oxley (SOX)
Changes in legal procedures and requirements during civil
litigation
Changes in FRCP in 2006
IG Awareness
Business continuity concerns
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Traditionally, in the past the kinds of industries that you saw
implementing records management programs were those
engaged in things like banking, energy, pharmaceuticals. This
was because traditionally these industries were subject to
greater regulation. However, this is beginning to change.
There is an ever growing amount of regulation and legislation
that make it relevant to nearly every business, except possibly
only the very smallest business.
The things that have driven this increasing demand for records
management in industries that you didn’t always think of as
having a sophisticated formal records management program are
things like 1.Increased government oversight and industry
regulation. Consider Sarbanes-Oxley (SOX); 2. Changes in
legal procedures and requirements during civil litigation. For
example changes in the federal rules of civil procedure in 2006;
3. the idea of greater IG Awareness; and 4. Competition and
Business continuity concerns
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Challenges for Records Management ?
Why has formal RM become so challenging and costly?
Changing and increasing regulation
Maturing IG requirements
Managing multiple retention and disposition schedules
Compliance costs and requirements with limited staff
Changing information delivery platforms
Security concerns
Dependence on IT department or provider
User Assistance and compliance

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Implementing and keeping up with a good records management
program is not easy. As a matter of fact it is very challenging.
Some of the reasons it is so difficult are listed on the slide:
Changing and increasing regulation-Just when you think you got
it all figured out and understand it, the laws change
Maturing IG requirements – senior management is becoming
more savvy about IG and the need for it, and for record
management
Managing multiple retention and disposition schedules – This is
difficult. Regulations change all the time and it is extremely
difficult to pin down what is appropriate for different record
types. Hard to convince management to retain records the
shortest time legally required due to change of opening
company up to greater risk of litigation by keeping records
longer.
Compliance costs and requirements with limited staff-
Departments responsible for this are generally understaffed
because they are not seen as one of the departments that directly
bring in revenue.
Changing information delivery platforms-More and more cloud
and mobile computing across different platforms make records
management more difficult because of where the different
records are stored and the need to maintain integrity and
security at the same time

Security concerns-you want critical information to be assessable
when it is needed by the right people but at the same time you
have to maintain security.
Dependence on IT department or provider-Because the RM
departments are understaffed, sometimes part of this work is
farmed out to the IT department, or even outsources. These
other individuals don’t have the same perspective and do not
see the critical importance that the RM department or people do.
User Assistance and compliance-Users frequently ignore the
directives of the RM department. They don’t understand the
significance of compliance, and often store shadow records for
their own convenience which creates different versions of same
thing. You have to keep reinforcing the importance of following
procedures and compliance.
BENEFITS OF ELECTRONIC RECORDS MANAGEMENT
IS IT WORTH IT???
Time Savings
Cost Savings
Building Space Savings
Strategic Advantages
Improved capabilities to enforce IG
Improved, more complete and accurate searches
Improved knowledge worker productivity
Reduced risk of legal consequences for failure to be compliant
Improved record security
Improved ability to demonstrate that your organization is using
legally defensible RM practices
Increased working confidence in making searches
Improved decision making
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It is difficult. And sometimes, particularly when you do not
receive cooperation from users in the organization you have to
ask yourself if it is worth it. But it is, the advantage or benefits
are as follows:
Time Savings
Cost Savings
Building Space Savings
Strategic Advantages
Improved capabilities to enforce IG
Improved, more complete and accurate searches
Improved knowledge worker productivity
Reduced risk of legal consequences for failure to be compliant
Improved record security
Improved ability to demonstrate that your organization is using
legally defensible RM practices
Increased working confidence in making searches
Improved decision making
These are the benefits that are more tangible. The things you
can see. But there are even more advantages or benefits, some
of which aren’t so readily identifyable or seen.
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BENEFITS OF ELECTRONIC RECORDS MANAGEMENT
IS IT WORTH IT???...continued

There are additional intangible benefits of ERM
Better control over the creation and growth of records
Improved ability to assimilate new record management
technologies
Increased ability to safeguard vital information
Ability to preserve the “corporate memory”
Increased ability to foster professionalism in running the
business
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These are referred to as intangible benefits. They include things
like the following:
Having Better control over the creation and growth of records
Having Improved ability to assimilate new record management
technologies
Having Increased ability to safeguard vital information
Having greater ability to preserve the “corporate memory”
Having an increased ability to foster professionalism in running
the business
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INVENTORYING E-RECORDS
U.S. National Archive and Records Administration (NARA)
defines an “inventory” as: A descriptive listing of each
record series or system together with an indication of the

location and other pertinent data.
Make sure you understand that it is not a list of each
document o each folder but rather each series or system.
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You will hear a bit about the NARA. This is the U.S. National
Archive and Records Administration. The authority on records
management.
They weigh in on the records inventory process as part of
records management. It is vital that the organization perform a
records inventory. NARA defines this as
“A descriptive listing of each record series or system together
with an indication of the location and other pertinent data.”
You need to understand that a records inventory is not a list of
each document or each folder but rather each series or system.
Inventorying E-Records continued…
Difficulty compared to physical inventory?
Purpose of inventorying e-records?
This is the first step in gaining control over an organization’
records and implementing IG measures .

Same as physical –find problems and use it as a source for
developing a retention schedule.
Type of problems it can uncover?
Inadequate documentation of official actions
Improper applications of technology
Deficient filing systems
Deficient maintenance practices
Poor management of non-record materials
Insufficient identification of vital records
Inadequate record security practice
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Compared to taking a physical inventory it is much more
difficult to inventory e-records . All the same, it is for the same
purpose as a physical inventory.
It is the first step in gaining control over the organization’s
records and implementing an IG program. It also helps you find
problems and it is used in developing a records retention and
destruction policy.
Why do you think they present more of a challenge than
inventorying physical records?

For a number of reasons. One is the fact that you Can’t see or
touch them (the e-records).
This means that You can’t just thumb through records to find
what you are looking for. You have to search online. They
aren’t just sitting in a file room where you can go pull them.
E-records will have metadata attached to them that will help
you distinguish similar looking records but they also will have
shadow records attached to them that makes it hard for you to
distinguish between the copy and the original.
But the inventory can also help you uncover certain types of
problems. For example, the inventory can help you uncover
problems with the following:
Inadequate documentation of official actions
Improper applications of technology
Deficient filing systems
Deficient maintenance practices
Poor management of non-record materials
Insufficient identification of vital records
Inadequate record security practice
Inventory of E-records continued…
We have said the purpose is the same as for inventory of
physical records….but what do we mean?
You want the completed inventory of records to contribute to
the pursuit of an organization’s IG objective in a number of
important ways……benefits of completing you records
inventory
Lets you identify ownership and sharing internally and
externally
Determines which records are physical and which are electronic
Provides a basis for retention and disposition

Improves compliance capabilities
Supports training objectives
Identifies vital and sensitive records needing more security
Assesses the quality and appropriateness of records
Supports the release of information under FOIA, Data
Protection Act and other release requirements
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We already know the e-records inventory is a pain. We already
know that it can be used to uncover certain types of problems.
Also, You want the completed inventory of records to contribute
to the pursuit of an organization’s IG objective in a number of
important ways……benefits of completing you records
inventory
Lets you identify ownership and sharing internally and
externally
Determines which records are physical and which are electronic
Provides a basis for retention and disposition
Improves compliance capabilities
Supports training objectives
Identifies vital and sensitive records needing more security
Assesses the quality and appropriateness of records
Supports the release of information under FOIA, Data
Protection Act and other release requirements

Inventorying E-records continued…
NARA recommends inventory be done at the computer system
level.
Why is that such “Big deal”?
Because it is a deviation from the past
Be mindful of the following:
You should rely on the people who create and use the records a
they will be a good resource
RM is something that everyone wants but nobody wants to do it
People who work with these records will be hard to sell on a
new approach
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The records inventory is the basis for developing a records
retention schedule – which determines how long different types
of records will b held and how they will be archived and how
they will be disposed of at the end of their life cycle.
But you have to first answer some other questions like where
the records will reside and how they are stored and how many
there are and how they are used in the regular course of
business.

In thinking about inventorying the e-records keep a few things
in mind:
You should rely on the people who create and use the records a
they will be a good resource
RM is something that everyone wants but nobody wants to do it
People who work with these records will be hard to sell on a
new approach. It is different and something that they are not
comfortable with.
Generally Accepted Recordkeeping Principles (GARP)®
TIP:
Use an established model to guide you in records inventory –
don’t reinvent the wheel
DIRKS (Designing and Implementing Recordkeeping Systems) –
Australia
Generally Accepted Recordkeeping Principles (GARP)® used in
the United States
Focus is on regulations, risk mitigation, environmental and
operational requirements
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When thinking about the process of how you are going to do the

inventory, don’t reinvent the wheel. There is the DIRKS model,
which stands for deigning and implementing record keeping
systems. Believe it or not this was developed in Australia but
has found its way to the United States and has gained
acceptance.
There are also GARP Generally Accepted Recordkeeping
Principles that have been researched. This is the most widely
accepted method in the US and it focuses on regulations, risk
mitigation, environmental and operational requirements.
Conduct inventory of e-records with certain objectives in mind
Provide a survey of existing e-record situations
Locate and describe the organization’s electronic records
holdings
Identify obsolete-records
Determine storage needs
Raise awareness within the organization
Identify archival records
Leads to e-record keeping improvements
Raises awareness and leads to development o needs assessment
for future
Provides organization with a written records management plan
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When you are thinking about how you are going to do your e-
records inventory you have to keep your objectives in mind.
What is it that you want to accomplish, and this will help you in
developing the technique you will use.
Keep the following in mind:
Your goals or objectives include:
Providing a survey of existing e-record situations, Locating and
describing the organization’s electronic records holdings.
You want to also Identify obsolete-records; Determine the
storage needs of the organization; Raise awareness within the
organization of the importance of electronic records
management; Identify archival records that are vital to the
organization and make sure that they are cared for on a
continuing basis; You want to also accomplish e-record keeping
improvements that will increase efficiency in the organization
which leads to increased productivity; You also want to Raise
awareness which in turn leads to development of a needs
assessment for future and finally you want to Provides
organization with a written records management plan
GOALS FOR THE INVENTORY PROJECT
Make sure the goal is attainable
Make sure the stakeholders know the goals
Segment your efforts into smaller units
This might mean define the scope as a certain time frame, or the
scope might be just a certain functional area of the business
Reinforce the goal periodically and in different ways
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In order to succeed you must Make sure the goal is attainable
Make sure the stakeholders know the goals
Segment your efforts into smaller units
This might mean define the scope as a certain time frame, or the
scope might be just a certain functional area of the business
Reinforce the goal periodically and in different ways
SO….How do you go about conducting and electronic record
inventory
This is according to
NARA guidelines:
Defines Inventory Goals
Define the scope of the inventory
Obtain top level management support
Decide on the information to be collected
Prepare an inventory form
Decide who will conduct the inventory
Proper training for those performing inventory
Learn where the organization’s business files are located
Conduct inventory
Verify and Analyze the results

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How do you go about conducting the e-record inventory? It will
be somewhat different depending on the characteristics of the
organization but for the most part you will want to incorporate
the following into your plan, regardless:
Defines Inventory Goals
Define the scope of the inventory
Obtain top level management support
Decide on the information to be collected
Prepare an inventory form
Decide who will conduct the inventory
Proper training for those performing inventory
Learn where the organization’s business files are located
Conduct inventory
Verify and Analyze the results
AND….What do you collect with the electronic record
inventory
At a minimum you will want to collect the following
information:

What kind of record it is (contract, or financial report, or
memo)
Which department owns it
Which departments have access to it
What application created the records (i.e., email, MS WORD,
Acrobat PDF, etc.)
When was the record created
When was the record last changed
Is the record a “vital” record (i.e. is it critical to the
organization)
Whether there are other form of the record (example, it was
created in WORD but later converted to a PDF file
Copyright©2018 Sandra J. Reeves All Rights Reserved
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What types of things will you be looking for or collecting with
the e-record inventory?
At the very least you want to collect the following:
What kind of record it is (contract, or financial report, or
memo)
Which department owns it
Which departments have access to it
What application created the records (i.e., email, MS WORD,

Acrobat PDF, etc.)
When was the record created
When was the record last changed
Is the record a “vital” record (i.e. is it critical to the
organization)
Whether there are other form of the record (example, it was
created in WORD but later converted to a PDF file (a shadow
record)
When you are dealing with removable media you have
additional considerations like list the records on the particular
volume and the characteristics of the volume like the brand,
format capacity date of manufacture and last date of update.
TOOLS TO USE IN CONDUCTIONG THE INVENTORY -
NETWORK DIAGRAM
Lay out the overall topology of the IT infrastructure in the form
of a network diagram
Before you begin the inventory it will benefit you to diagram
your IT infrastructure……This permits you to…
Helps you understand where to target efforts
Helps in understanding and mapping information flows
It is a very helpful reference
HINT: Start at the central computing room and then follow the
connections
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To understand the things you need to capture for each record
series you will find a network diagram very helpful. In this way
you can layout the overall topology of the IT infrastructure.
How does it help you to have the network diagram before
beginning the inventory?
Helps you understand where to target efforts-where will you
have the greatest problems or challenges
Helps in understanding and mapping information flows and this
shows you who created the record and who uses it. That is
important for assigning responsibility for the record.
It is a very helpful reference throughout the processes that
follow. Helps you get your mind around the concept.
It is a good idea to Start at the central computing room and then
follow the connections
TOOLS TO USE IN CONDUCTIONG THE INVENTORY –
RECORDS INVENTORY SURVEY
SO IMPORTANT TO GET THIS SURVEY FOR RIGHT!
IT MUST SUIT ITS PURPOSE
You do not want to collect data that is not relevant, but you
must be sure that you are collecting all the needed data elements
These forms are commonly used in organizations….you should
be able to get one and modify it to meet your needs for an e-
inventory
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There are different tools you can rely on in conducting your
inventory. One useful took is records inventory survey.
But it only works if it is a good survey. It must ask the right
questions in the correct way of the appropriate people.
Sort of tricky. You don’t want to collect data that you don’t
need but you want to make sure that you do get all that you
need. You don’t want to begin tabulating your survey results
only to find that you didn’t collect certain information that is
necessary to evaluation of the rest.
Again, don’t reinvent the wheel. You will find these used in an
organization. Locate one as a starting point and modify it to fit
your requirements.
Who Will Conduct the Records Inventory Survey?
Generally – Records Management Project Team is formed to
conduct the survey
Assisted by others outside the business unit
May be IT staff members
Business Analysts
Legal Staff
Specialists/consultants
Important to those conducting the survey:

Training in:
Survey methods
Analysis
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Who will conduct the records inventory survey? The records
management project team. As they are generally understaffed,
they will rely out others like people from IT, business analyst,
legal staff, and special consultants.
You can’t just give people survey forms and tell them to go do
it. They have to be trained. You have to make sure they are not
asking leading questions or are going about it the wrong way or
are surveying the wrong people.
Even more importantly, you want to make sure that you are
using the proper analysis techniques. You want results that can
help you for the future. This requires more specialized
knowledge
CONDUCTING THE INVENTORY…

THE APPROACHES
Approach I
Distributing and Collecting surveys
Traditional approach
Relatively inexpensive
Relatively fast
Problem: Lack of Consistency
Approach II
Conducting in-person interviews
Frequently a follow-up after initial survey
Approach III
Direct Observation
Will require more training and better understanding of the
process
Begin in central computer room and work your way out
IF TIME AND MONEY PERMIT, THE BEST IS TO USE ALL
THREE
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There are a number of methods of performing your inventory. It

is possible that you may use only one technique, but more likely
you will use some combination of them. The three most
common include:
Approach I
Distributing and Collecting surveys. This is the Traditional
approach; it is Relatively inexpensive and Relatively fast.
However, Problem: Lack of Consistency
Approach II
Conducting in-person interviews. This is Frequently a follow-up
after initial survey
Approach III
Direct Observation. This will require more training and better
understanding of the process. If you use this technique then it
is better to Begin in central computer room and work your way
out
Example of Records Inventory Survey Form…Pages 161-163 of
text book

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text book…continued
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text book…continued

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CONDUCTING THE INVENTORY…
THE INTERVIEW APPROACH
THIS IS A GOOD SOURCE OF INFORMATION!
This method is time sensitive, so…. You need to make sure you
have identified the proper people to interview
Make sure to interview representatives from all functional area
and levels of the program or service:
Managers
Supervisors
Professional/technical staff
Clerical or support staff
Make sure to include a cross-section who make decisions based
upon information contained in the e-records
Make sure to be considerate of the time of those you are
interviewing (and don’t make your executive sponsors think you
are wasting everyone’s time…Give advanced notice, follow-up
to confirm appointments, stay within scheduled time, keep
interviews under and hour …and DON’T BE LATE
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Interview is a good approach, but you have to be careful in
using it.
It is generally time sensitive, so…. You need to make sure you
have identified the proper people to interview. Don’t waste
anyone’s time including your own by selecting people to
interview who do not know the answer to your questions.
Make sure to interview representatives from all functional area
and levels of the program or service:
Managers
Supervisors
Professional/technical staff
Clerical or support staff
Make sure to include a cross-section who make decisions based
upon information contained in the e-records
Make sure to be considerate of the time of those you are
interviewing (and don’t make your executive sponsors think you
are wasting everyone’s time…Give advanced notice, follow-up
to confirm appointments, stay within scheduled time, keep
interviews under and hour …and DON’T BE LATE
Example of Interview Questionnaire
Page 167
from text book

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DETERMINING THE VALUE OF RECORDS
WHY?
It is part of the process of determining questions related to
retention and disposition schedule of records...the value
assigned to a record affects the retention policy for the record
HOW?
“Records Appraisal” – Analysis of all records within an agency
or business to determine their administrative, fiscal, historical,
legal or other archival value
Goal is to determine how long, in what format and under what
circumstance a record series will be preserved
Will be based upon results of the e-records inventory
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Why do you have to determine the value of each record series to

the organization? Because It is part of the process of
determining questions related to retention and disposition
schedule of records...the value assigned to a record affects the
retention policy for the record
So you have to perform a sort of record appraisal. What is this?
“Records Appraisal” – Analysis of all records within an agency
or business to determine their administrative, fiscal, historical,
legal or other archival value
Goal is to determine how long, in what format and under what
circumstance a record series will be preserved
Will be based upon results of the e-records inventory
HOW DO YOU ENSURE THE ORGANIZATION WILL ADOPT
AND COMPLY WITH THE RM POLICY??
Make sure that everyone in the organization is involved in
records management –the person who creates or receives the
record is the best person to classify it
Don’t “micro” classify - Average worker does not want to
spend a great amount of time classifying records – have only a
few broad classifications
Talk the talk – from the top – have senior level steering
committee with at least executives from legal, compliance and
IT
Walk the walk – Communicate to everyone in the organization
what the policies and where they can find them. Adopt rigorous
training
Measure the measurable-measure the adherence to policy and
adoption of processes where possible
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What can you do to insure the greatest chance of success in
your organization that the people who work there will buy into
the notice, adopt the policy, become and stay compliant?
Make sure that everyone in the organization is involved in
records management. Everyone buys in. –the person who creates
or receives the record is the best person to classify it
Don’t “micro” classify - Average worker does not want to
spend a great amount of time classifying records – have only a
few broad classifications
Talk the talk – from the top – have senior level steering
committee with at least executives from legal, compliance and
IT
Walk the walk – Communicate to everyone in the organization
what the policies and where they can find them. Adopt rigorous
training
Measure the measurable-measure the adherence to policy and
adoption of processes where possible.
GENERAL PRINCIPLES OF RETENTION SCHEDULING
A SERIES OF PRINCIPLES IS COMMON TO ALL
RETENTION SCHEDULES
The retention schedule must include all records regardless of

media and location
All legal and regulatory requirements for records must be
reflect in the record scheduling process
Records scheduling should be proactive, involving setting
schedules in advance and standardizing the process
When there are substantial or significant changes in legislation,
technology and other…and even if no change, still at least
annually
Update and amend the process based upon changes in legal,
technological or business changes over time
Files series that have similar characteristics should be dealt
with consistently
Preserve records of historical value
Optimize RM resources and minimize record keeping costs
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While your organization’s retention scheduling policy will be
different from that of every other organization in some aspects,
for the most part there will be some general principles of
retention scheduling that will be common to all. They are as
follows:
All legal and regulatory requirements for records must be

reflect in the record scheduling process
The retention schedule must include all records regardless of
media and location
Records scheduling should be proactive, involving setting
schedules in advance and standardizing the process
When there are substantial or significant changes in legislation,
technology and other…and even if no change, still at least
annually
Update and amend the process based upon changes in legal,
technological or business changes over time
Files series that have similar characteristics should be dealt
with consistently
Preserve records of historical value-You may not need them
right now, but they are so vital to the organization’s history and
what is referred to as its corporate memory you can’t let these
fall by the wayside and eventually lose them.
Optimize RM resources and minimize record keeping costs
GENERAL PRINCIPLES OF RETENTION SCHEDULING
A SERIES OF PRINCIPLES IS COMMON TO ALL
RETENTION SCHEDULES…..continued…
The records must be retained in a repository (like a file room or
software system) where the record is protected in order to
maintain its integrity
Senior management must approve and sign off on the retention
schedule
Senior management must be able to readily review the policy,
schedule, policy documentation and audit results
There must be complete documentation for the retention policy,
requirements and activities
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Continuing on with those principles that will be common to
most records retention schedules:
The records must be retained in a repository (like a file room or
software system) where the record is protected in order to
maintain its integrity
Senior management must approve and sign off on the retention
schedule
Senior management must be able to readily review the policy,
schedule, policy documentation and audit results
There must be complete documentation for the retention policy,
requirements and activities
WHY DO YOU NEED A RECORD RETENTION SCHEDULE?
Allows for uniformity in the retention and disposition process,
regardless of the media or location of the records
Tracks, enforces and audits the retention and disposition of
records, optimizing the amount of records kept to the legal
minimum
SO WHAT? Why is that important?
Saves on capital costs
Saves on labor costs
Reduces liability

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This is so time and labor intensive and it will cut into the
budget. You may begin to ask yourself. Why do I need a
record retention schedule? Why not just retain records for a
while until I don’t think I need them anymore and then just get
rid of them.
Because, having a consistent records retention schedule will:
Allows for uniformity in the retention and disposition process,
regardless of the media or location of the records
Tracks, enforces and audits the retention and disposition of
records, optimizing the amount of records kept to the legal
minimum
SO WHAT? Why is that important?
Saves on capital costs
Saves on labor costs
Reduces liability

HOW DO YOU GO ABOUT DEVELOPING THE RETENTION
SCHEDULE?
What is a record retention schedule?
It is something that defines the length of time that records are to
be kept.
It is developed after considering the legal, regulatory,
operational and historical requirements
It will include direction on how the length of time is calculated
(i.e. the start date for counting the retention time)
It is developed only after completing legal research and
consultation with the users of the record and the owner of the
record (you may determine after consultation to retain records
beyond the legally required period)
Give strong advice to the users/owners who want to keep the
records beyond the legally required period as this may open the
organization up to the potential for otherwise unnecessary
liability
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So exactly what is a record retention schedule? We are now

sold on the idea we need it, but we still aren’t sure what it is.
A records retention schedule is:
It is something that defines the length of time that records are to
be kept.
It is developed after considering the legal, regulatory,
operational and historical requirements
It will include direction on how the length of time is calculated
(i.e. the start date for counting the retention time)
It is developed only after completing legal research and
consultation with the users of the record and the owner of the
record (you may determine after consultation to retain records
beyond the legally required period)
Many times there are managers and executives who think that
the records need to be retained longer than is “legally”
necessary. In those cases, Give strong advice to the
users/owners who want to keep the records beyond the legally
required period as this may open the organization up to the
potential for otherwise unnecessary liability. If the record has
legally been destroyed then more likely than not it can’t be used
against you.
DISPOSITION AS PART OF RETENTION
What is meant by disposition?
Destruction
Archiving
Transferring
Changing ownership
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We talk about “retention”. But retention is generally not
forever. What happens when you have flagged a record as no
longer being necessary for retention. You will never need the
record again for any purpose. So what becomes of the record
after the retention period?
Then it is disposed of. But this may not mean what you think it
does. It does not always mean destroying it for good.
Disposition can include different things depending on the
record:
Destruction-in this case it is permanently removed from all
media forever
Archiving- this is where you organize or index the records and
hand them over to the historical record keeping unit
Transferring-convert them from one medium to another for
backup.
Changing ownership-sometimes you are going to contract with
third parties to retain your records. Or you transfer them from
one department to another for purposes of preservation.
WHAT TYPES OF THINGS ARE INCLUDED IN THE
RECORD RETENTION SCHEDULE?
Title of the record
Description of the record series
Office responsible for retention of the record
By default this is the office of origin but can change

Method of Disposition
Timing of the disposal
Remember the default is the minimum time legally required
Event(s) that trigger disposal
Date(s) when schedule was agreed, signed and modified
Legal citations or a link to the citation that references the
retention requirement for that group of records
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Your records retention schedule will be different from every
other organization because you have somewhat different needs .
But you want to keep in mind that there are certain types of
things that are included in most record retention schedules.
This would include things like the following:
Title of the record
Description of the record series
Office responsible for retention of the record
By default this is the office of origin but can change
Method of Disposition
Timing of the disposal

Remember the default is the minimum time legally required
Event(s) that trigger disposal – this is a date or the occurrence
of something that makes the time start to run on how long you
have to keep the record
Date(s) when schedule was agreed, signed and modified
Legal citations or a link to the citation that references the
retention requirement for that group of records-probably you are
going to need help with this from the legal department.
Example of Records Retention Schedule…From text book page
172
36
KEY STEPS IN DEVELOPING THE RETENTION SCHEDULE
(U.S. National Archives advises…)
Review the function and recordkeeping requirements for the
organization whose records will be included on the schedule
Inventory the records
Determine the period of time the records are needed for

conducting operation and meeting legal obligations
Draft disposition instruction which include….
File cutoffs and breaks for purposes of storage and disposition
Retention periods for temporary records
Instructions for transfer permanent records to National Archives
where applicable
Instructions for sending inactive records to off-site storage
Organize the schedule and get internal approval
Obtain approval form legal authority where applicable to
federal agencies
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So you know a little bit about the record retention schedule and
what it is. Now you need to begin to think about the steps in
developing the retention schedule
They are listed in order as follows:
Inventory the records
Determine the period of time the records are needed for
conducting operation and meeting legal obligations

Draft disposition instruction which include….
File cutoffs and breaks for purposes of storage and disposition
Retention periods for temporary records
Instructions for transfer permanent records to National Archives
where applicable
Instructions for sending inactive records to off-site storage
Organize the schedule and get internal approval
Obtain approval form legal authority where applicable to
federal agencies
DETERMINING WHAT RECORDS ARE REQUIRED TO BE
INCLUDED IN RETENTION SCHEDULE
Inventory was a prerequisite
Classification of records
Develop the Information Map
Where is the information created
Were does the information reside
How does it get from point of creation to point of residence
What records are created
Who uses these records
How is the disposition of these records handled
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How do we determine which records are require to be included
in the retention schedule? Look at step one from the previous
slide.
We said review the function and record keeping requirements
was the first step in developing the retention schedule.
So what are you doing the review for?
We know we had to perform an inventory and we know we had
to classify the records based upon the inventory.
So we are now ready to develop an information map. This will
allow you to know where the information was created, where it
will finally reside and how it gets from the point of creation to
the point of residence.
This is vital in helping you see the big picture like what records
are created and who will use the records and how the records
will be disposed at the end of their useful life. You will want to
go out and confirm this information map is correct by talking to
every stakeholder. Don’t forget people in accounting and
auditing
But what if your organization does not have a formal
information map. The best solution is to create one. But what if
you do need to do something and there is simply no map and no
time to develop one.
QUICK FIX WHEN THERE IS NO “FORMAL INFORMATION
MAP”?
Compile list of all different record types for each business unit
with essentially same information mapping.
You will forfeit the benefit of having a pictorial map but will

save time
WHAT IF THERE IS NO RECORDS INVENTORY?
Conduct records inventory or survey on your own – this step
can’t be skipped
It is a prerequisite to the next step which is to classify records
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What if your organization does not have a formal information
map and you don’t have time to develop one and you have to
have a quick fix?
In theory you are supposed to develop a list of all the different
record types for each organizational unit or business unit or
department, whatever you choose to call it. It is supposed to
give you the same information but you will not have a
structured form or map that gives you the visual image.
What if there is no records inventory? Then you really aren’t
ready to go on the step of developing the retention schedule.
How could you possibly know what to retain if you don’t know

what the records are or what they contain. You would have to
stop at this point and do a records inventory or at the very least
a comprehensive survey. This step can’t be skipped because it
is vital to the next step of classification of the records.
WHAT ARE THE BASIC RECORD CLASSIFICAITON
GROUPINGS?
Business function and activities
Basic business departments or units (accounting, legal, human
resources, payroll…et.)
It should answer the questions “what were you doing when you
created the record”
Activities – tasks performed to accomplish the business
function. May be more than one activity related to each function
Record Series
Group or unit of identical or related records that are normally
used and filed as a unit that can be evaluated as a unit
Document Type
A group of related records. For example when records are
created by similar processes their document types are equivalent
to the business function or activity.
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40
So what are the basic record classification groupings?
There are three primarily
Business function and activities
These are the Basic business departments or units (accounting,
legal, human resources, payroll…et.)
It should answer the questions “what were you doing when you
created the record”
Activities – tasks performed to accomplish the business
function. May be more than one activity related to each function
Then there is the Record Series
A record series involves Group or unit of identical or related
records that are normally used and filed as a unit that can be
evaluated as a unit
Third is the Document Type
This is a group of related records. For example when records
are created by similar processes their document types are
equivalent to the business function or activity. Yet, document
types can also refer to the format of the record. For
example…minutes of meeting, power point presentation,
WORD document. When you have this type of classification
there is generally not enough information to determine a
retention period because this is so ambiguous
SO WHY ARE RECORD GROUPINGS IMPORTANT?
Information Organization
Information Access
Completeness
Search Speed
Increases Organizational knowledge and memory by providing
context within which documents were grouped
Identification of owner of record and creator
Helps determine who to assign for tracking responsibility
Consistency in retention and disposition

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41
We are caught up with grouping records by business unit or
series or document type. But why concern ourselves with
record groupings at all? Why are they important?
Because by grouping records in a useful and logical method or
fashion you will improve information organization and thereby
information access.
In addition it will insure the records are complete
It will increase the search speed and thereby productivity
It will increase the organizational knowledge and recollection
or memory with regard to providing context for which records
were grouped together and why
Helps to identify the owner of the record and the creator of the
record. Why do you care…because this is needed in order to
assign responsibility for tracking
And finally for consistency with regard to the retention
requirements and disposition requirement and method
RECORD SERIES
There are different types of record series.

Example: Case Records:-no insight into the nature or function
of the record series
Example: Personnel Files, loan folders, accident reports
Name, dates, numbers, places….etc.
They have a beginning and an end but are added to
over time.
Example: Subject Records (topical or functional records):
Contains information related to the specific or general topic and
arranged according to informational content or by function.
They accumulate information on a particular topical function
Example: Legislative history of a law; or training history
or policies and procedures
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Let go back to the second type of classification of record series
for a moment and talk about it more.
There are different types of record series.
Example: Case Records:-no insight into the nature or function
of the record series
Example: Personnel Files, loan folders, accident reports
Name, dates, numbers, places….etc.
They have a beginning and an end but are added to

over time.
Example: Subjct Records (topical or functional records):
Contains information related to the specific or general topic and
arranged according to informational content or by function.
They accumulate information on a particular topical function
Example: Legislative history of a law; or training history
or policies and procedures
RETENTION OF E-MAIL RECORDS
ARE EMAILS RECORDS?
Some and some are not
HOW DO YOU DETERMINE WHICH EMAILS ARE
RECORDS THAT MUST BE RETAINED?
Keep in mind it is not the form of the record, but the content
that determines
GUIDELINES:
Does it document a transaction or progress toward an ultimate
transaction where anything of value is exchanged between two
or more parties
Does it document or provide support of a business activity
occurring that pertains to internal corporate governance policies
or compliance to externally mandated activities
Does it document other business activities that may possibly be
disputed in the future regardless of whether it leads to litigation
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43
Do are emails business records that have to be retained? There
has been considerable debate about that for a period of time.
Some are and some are not.
But how do you know which are and which are not required to
be retained?
If it is a record it will document a transaction or business
related event that may have legal significance or legal
ramifications or may have historical value. More importantly
those that may be the subject of litigation.
Don’t get hung up on the form of the record. Whether it is an
email or not. Remember it is not the form that is important but
the content. You may have pictures or an audio recording of a
meeting or a WORD document, or even a sticky note, or an
email that may constitute a record depending on its content.
You can never be certain about all emails without reading them
and then there may be some question. But a general set of
guidelines to follow include
Does it document a transaction or progress toward an ultimate
transaction where anything of value is exchanged between two
or more parties
Does it document or provide support of a business activity
occurring that pertains to internal corporate governance policies
or compliance to externally mandated activities
Does it document other business activities that may possibly be
disputed in the future regardless of whether it leads to litigation

This is extremely challenging. Basede upon recent surveys 2/3
of all records managers doubt that their IT department really
understand the concept of e-records lifecycle management.
I can’t begin to tell you how very important emails are related
to litigation. And the scary part is that 1/3 of IT managers
report that they would be incapable of locating and retrieving
emails that are more than one year old.
WHAT IS THE RETENTION PERIOD FOR EMAIL?
IT DEPENDS
Nature of business may dictate…may be regulated by
law. This will then vary based upon whether it is state or
federal law and the nature or type of the business and
nature of the email
If not governed by law….You decide…whatever works best for
your organization
All Rights Reserved
44

Lets say you know which emails have to be retained based upon
the criteria or guidelines set for in the prior screen. How long
do you have to keep them? Remember, emails can be a great
source of litigation so you don’t want to keep them longer than
necessary. They are used very very often with wrongful
termination cases..and others of course.
Depending on the type of organization you are dealing with the
retention period may be governed by law. Even then there is
no one definite answer. It will depend on the type of business,
the nature of the email, whether it is of a type that is governed
by state or federal law, and if by state law, then it will vary
depending on the state.
But what if it is not governed by law? Then your organization
can decide based on its own needs….and this can really be
damaging to litigation but keep as short as reasonable
DESTRUCTIVE/RETENTION OF EMAIL?
What is meant by “Destructive Retention”?
An approach to email archiving where email messages are
retained for a limited period of time followed by permanent
deletion of the message from the organization network so there
is no litigation hold or the email has not been declared a record.
What is generally the norm for retention of email?
Nearly ¼ of companies delete email after 90 days (Osterman
Research)
Heavily regulated industries generally retain archived email for
one year or more. Applicable to energy, technology,
communications, real estate. (Fullbright and Jaworski Rearch)
Most common period traditionally has been for 7 years but some
companies take a more defensive posture

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45
What is meant by “Destructive Retention”?
An approach to email archiving where email messages are
retained for a limited period of time followed by permanent
deletion of the message from the organization network so there
is no litigation hold or the email has not been declared a record.
That is, once you have kept the email for the minimum required
period of time get rid of it before an attorney can send you a
letter requiring you to retain it for future litigation. The period
of time when you are required to keep the email will vary
depending on the factors we have discussed. It could be as
short as 90 days or it might be as long as 7 years.
Nearly ¼ of companies delete email after 90 days (Osterman
Research)
Heavily regulated industries generally retain archived email for
one year or more. Applicable to energy, technology,
communications, real estate. (Fullbright and Jaworski Rearch)
Most common period traditionally has been for 7 years but some
companies take a more defensive posture. What I mean by this

is that unless the email has been determined to be a record that
requires retention for a longer period, then it is deleted after 90
days.
Why 7 years? That is the look back period for bankruptcy and
for many other things…like fraudulent conveyances etc.
WHAT ABOUT LONG-TERM ARCHIVAL RECORDS?
Records that have historical value
Records that are essential for preservation of corporate memory
Go to the expert for advice….the corporate or agency
archivist for alternatives
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46
What if you have records that aren’t used today. They aren’t
needed for operations but they have historical significance? Or
they help preserve the corporate memory…remember people
change jobs and are mobile and you need a way to look back
since you don’t have an individual who is guaranteed to be there
forever.
This is very complex and technical and you will need the input

of a agency archivist
LEGAL REQUIREMENTS AND COMPLIANCE?
LEGAL REQUIREMENTS TRUMP ALL OTHER
CONSIDERATOINS
KEY IS TO KNOWING THE “LIMITATIONS PERIOD”
Length of time after which legal action cannot be brought by the
courts….sometimes referred to as Statute of Limitations
Will vary depending on nature of record and State involved
HOW WILL YOU KNOW THE LIMITATIONS PERIOD?
Do the research!
Record Retention citation service that publishes retention
related citations: Example: Code of Federal Regulations or e-
CFR (which is not updated daily)
Problem is with interpretation by laypersons
Consult legal counsel
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The legal requirements for record retention trumps everything
else. It may be nice that your business wants to keep records for
a shorter period. But that does not matter. You have to remain

within the law.
There is something that you have to know for your industry and
your business for each type of record and that is what this book
calls the “limitations period”. This is the period of time after
which action cannot be brought in court. It is generally called
the “statute of limitations” and it will vary depending on the
industry and the type of record involved.
But how do you know the limitations period? You can do the
research yourself. There are subscription services on line that
can help you. Like the Code of Federal Regulations or e-CFR
which is not updated daily. The problem with these are if you
don’t have a legal background it may be difficult for you to
properly understand and apply what you are reading.
EVENT-BASED RETENTION SCHEDULING FOR
DISPOSTION OF E-RECORDS
Event based disposition is where there is an event that triggers
the beginning of the running of time for determining how long
you have to retain a record
Example: The end of a project
Example: Separation or termination of an employee
Alternate definition used by Department of Defense:
Disposition instruction in which a record is eligible for the
specified destruction upon or immediately after the occurrence
of an event. - no retention period is required
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There is this concept of event based retention scheduling. It is
looked at a little differently depending on the industry.
Event based disposition is where there is an event that triggers
the beginning of the running of time for determining how long
you have to retain a record. An example might be the end of a
project. Another might be the termination of an employee. Yet
another might be a work related injury of an employee. Each of
these events might trigger the beginning of the period of time
running for determining how long you have to keep a record.
Alternate definition used by Department of Defense:
Disposition instruction in which a record is eligible for the
specified destruction upon or immediately after the occurrence
of an event. - no retention period is required
This concept is not a simple as it sounds. Documentation may
be poor as to when these events occur and may cause business
organizations to retain records longer than otherwise required.
PREREQUISITNS FOR EVEN-BASED DISPOSITION?
MUST HAVE A TRIGGERING EVENT
This is not always the case!
It is not always clear!
MUST BE ABLE TO HAVE AUTOMATED CAPTURE OF
TRIGGER EVENT
MUST SEND AUTOMATED TRIGGER TO ERM
ERM MUST HAVE RETENTION CAPABILITIES
ERM MUST HAVE DISPOSITION CAPABILITIES

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49
MUST HAVE A TRIGGERING EVENT. This is not always the
case!
It is not always clear! For example. How do you know when a
contract has been completed? Lets say there is a construction
contract. Is it completed when last work is performed or is it
completed after final independent inspections? Or is it
completed when the payment is made to the contractor?
MUST BE ABLE TO HAVE AUTOMATED CAPTURE OF
TRIGGER EVENT . Can’t rely on someone to remember
manually to send this information to the right people.
MUST SEND AUTOMATED TRIGGER TO ERM. Have to have
a way to automatically send the triggering event to the
Electronic records Manager
ERM MUST HAVE RETENTION CAPABILITIES.
ERM MUST HAVE DISPOSITION CAPABILITIES
FINAL DISPOSITION AND CLOSURE CRITERIA
What will be the closure criteria?

What will be the final disposition?
Retention period will vary depending on:
Is the record online vs offline?
If online, is it active or inactive?
If offline, is it onsite or offsite?
Determine the Closure Date
End of Calendar Year?
End of Fiscal Period
Other logical closure date depending on record type
Case Records are treated differently. These are
closed when the case record is completed
Some records require permanent retention
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50
Finally, after you have looked at the legal requirements you
must decide on the closure criteria and on final disposition. So
there are a few other things you want to ask or consider.

Retention period will vary depending on:
Is the record online vs offline?
If online, is it active or inactive?
If offline, is it onsite or offsite?
Then you want to define a clear start date for closure. This may
be the end of a calendar or fiscal year, or it may be something
else, logically depending on the type of record. For example
case records are treated differently. An attorney might close his
case file when the law suit ends.
There are some records, which are rare, that you will never
dispose of.
TRANSITORY “DOCUMENTS”
Documents that do not rise to the level of being considered a
“record”
Temporary in nature
Useful in the short-term
Example: email advertisement
Transitory documents must be considered in master retention
record schedule
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What are transitory documents? Can’t call them records. They
are Documents that do not rise to the level of being considered
a “record”.
Transitory documents are temporary in nature. The are Useful in
the short-term
Example: email advertisement
But still, you have to consider them in the master retention
record schedule
IMPLEMENTATION OF RETENTION SCHEDULE AND
DISPOSAL OF RECORDS
Consider Automated programs where available
Insures correct timing for disposal
Provides audit trail of disposition
Approval of Executive sponsor
Sign off by key Stakeholders
Verify Total and
Complete Destruction
Consider having the authority to review and approve final
destruction once triggered automatically
Certification of record destruction
Ongoing maintenance and review
Implement IG policies to audit and ensure that policies are
being followed
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So now you are at implementation. There is automated software
that will interpret the retention periods and will make sure that
the right records are disposed of at the correct time and will
provide an audit trail of disposition.
You will want to insure approval and oversight. Upon
completion of the schedule you wil wna tot get an executive or
project sponsor to sign off on the retention schedule before it is
implemented.
You will most likely want major stakeholders to also sign off on
this. This records retention schedule should be updated as new
record types are introduced.
You will want to Verify Total and Complete Destruction. Just
because someone hits a delete key this does not mean that you
still can’t retrieve or reconstruct the record.
Consider having the authority to review and approve final
destruction once triggered automatically
Certification of record destruction. You may want to consider
having one final review for those records tagged for destruction.
Something may have come up that require you to change the
destruction policy for certain records.
Ongoing maintenance and review. There will be new record
types introduced over time, or the existing ones may change.
You want to review this at least once a year.
Implement IG policies to audit and ensure that policies are
being followed. You have to insure that you have a legally

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