ERM Final Disposition – do you visually check each doc before destruction?

Posted by

I would like to poll those of you out there that are fully into ECM, to the point where you are now actively destroying electronic documents. We are only a few years in and our e-documents are not yet coming up for destruction. I am working on what the procedure would be. We have two camps in our office, one that insists we must look at each document before destruction and approve those destructions; and one that insists that this will be too time consuming for the staff that will be required to approval the documents eligible for destruction. But!, the only other option I’m aware of is “auto mass destruction” as they reach their final disposition dates.

What do you do? Please describe your whole process, as this is all brand new to us and we are starting from scratch.

Thanks!!

——————————
Flagstaff County
——————————

Hi,
Email the business owners the container(folders) that are due for destruction and seek sign off. The document owners that take on the ownership/risk/resources of getting someone to look or not based on each units needs and processes.
It isn’t a one size fits all, You can also prompt units to add caveats to individual documents or folders that become higher risk before they get to destruction.

——————————
DTWD
——————————

Hi All, Our business process is the same for electronic records as paper records – we do send the business owners (Office of Accountability) the Record Series and date ranges that are up for destruction (typically folder level) but also include an electronic link to the detail (document level) should they want to do their own spot check. Some do and some don’t – it is typically up to the business to decide. We do however receive their signature/approval before we destroy anything.

Also, the IM Office does the first review before sending to business owners to ensure there are no record series that are under a Records hold etc. The process is the same for all business units – no exceptions.

This year we will be destroying well over 100,000 documents so it would be impossible to review documents up for destruction at a document level.

——————————
OMERS
——————————

The process I have put in place previously is the same as Jackie’s. System automation to identify content eligible for destruction sends notification first to identified business owner/custodian for review and approval for destruction. Once the business owner/custodian has approved a notification is sent to RM. RM then does ‘spot check’ reviews to maintain a high quality on the process. Other than the random spot checks, RM does final approval for destruction. This process has been reviewed by legal dept’s, and external counsel, for the organizations where I have implemented this and conclusions were that it is highly defensible.

 

A document retention policy should be introduced as an example on a oil and Gas project this would generally be lifecycle of the asset + 10 years for all documents.

——————————
Engie E&P
——————————

We apply the record series retention from the records retention schedule to the folders and documents in our ECM system. We run reports on what is eligible; the records owner and the records manager signs off on the destruction; and then the records are destroyed. The records owner has the option to review any individual document (or all of them) but they generally find it too time consuming and, since they approved the retention, generally approve the destruction without question. Feel free to contact me off line if you have any questions.

——————————
Old Dominion Electric Cooperative
——————————

If you have approved retention schedules, documented disposition processes, and your records have been properly classified by document class and with required retention trigger metadata, then there is no need to review individual documents – you can bulk destroy in accordance with your policy and process. Destruction of electronic records is done based on the metadata assigned to the electronic record including the record class and the retention trigger for the record. For example, if retention for on an employee hire offer letter was ten years past end of their employment. The employee leaves the company and you enter the end date in the end-date metadata field in your system, and that end date is used as the trigger for disposition. Ten years after the employee leaves the company you run a system report of all employees who left the company ten years ago. You then verify that there are no anticipated or in place record protection orders in place (e.g. legal or regulatory hold) that require you to keep the record class past its retention date. Once that is done and you confirm there are no legal holds in place, you can destroy all the applicable records without any need for individual review. If there was a legal hold (e.g. litigation involving that former employee) then you could not destroy that employees records.

This email and its attachments are intended solely for the personal use of the individual or entity named above. Any use of this communication by an unintended recipient is strictly prohibited. If you have received this email in error, any publication, use, reproduction, disclosure or dissemination of its contents is strictly prohibited. Please immediately delete this message and its attachments from your computer and servers. We would also appreciate if you would contact us by a collect call or return email to notify us of this error.
Thank you for your cooperation.

Thanks to everyone that has replied so far! To anyone else reading these, still wanting a wide grouping of responses; keep them coming!

To clarify, we do have the retention schedule in place. It’s just the procedure for destruction of electronic records that is new to us. We have been destroying hard copy records based on the Schedule for many long years.

——————————
Flagstaff County
——————————

One further thing to think about regarding the destruction of electronic documents is how you deal with backups, multiple copies etc. and how you write this into your policies and procedures.

Hard copy records are much easier in this regard. Typically you have one hard copy original stored in an archive and this is destroyed when its retention is reached.

However, with electronic records, you may well have the master record in your ECM or ERM, but you may then have backups of that on a disk-to-disk backup array, you may have monthly backups stored on offsite tape storage etc.

Unfortunately, it is all to easy to create multiple copies of an electronic record and is something which needs to be considered.

——————————
Attric Limited
——————————

Paul makes a good point with respect to e-discovery and backup tapes. You can search for “Sedona Principles” and then discuss them with your legal team. Principle # 8 makes a reference to “… disaster recovery backup tapes …” I recently completed a new IG Policy, which included discussing this principle with my legal team. Happy to discuss this further with you off-line.

——————————
Government of Canada
——————————

Control of backups is critical to your destruction. If your backups are timely destroyed, you may still have a very short window where your main repository has destroyed the asset but it still exists on the backup. We did engage our IG Council and legal teams on this issue. We were able to clear any legal holds from the backups and destroyed 86,000 pounds (21 petabytes) of backup tapes! Felt great!

——————————
DONNA BROKER EPSTEIN
——————————

Leave a Reply

This site uses Akismet to reduce spam. Learn how your comment data is processed.