Retention & ESI. Paths to Success. Christine M. Burns. April 24,

Transcription

1 Retention & ESI Paths to Success Christine M. Burns April 24,

2 Retention Schedules: What You ve Done Functional Schedule Conversion April 24,

3 Old Retention Schedule Financial Statements Monthly Financial Statements Quarterly Financial Statements Annual Retain 12M Retain 2Y Retain 7Y April 24,

4 New Retention Schedule Financial Statements Data & Directories Retain X Years or Max. of X Years April 24,

5 Tips for ESI-Friendly Retention Schedules Satisfy Regulatory Compliance Distinguish between requirements and considerations Mitigate Risks Simplify April 24,

6 Payroll Records Example: Some Legal Retention Requirements Employment + 2 or 5 Years Current Year + 8 Years British 6 Years or Less Columbia, Minnesota 3 Years Saskatchewan Other States United States (Federal) April 24,

7 Payroll Records Retention Based on Creation Date Payroll Processing Records Salary, merit and status changes Vacation and overtime payment authorizations Employee reimbursements for tuition and/or relocation services Adjustments and manual compensation check support Payroll registers and period-ending reports April 24,

8 Payroll Records Retention Based on an Event Payroll Deductions & Authorizations Tax status and withholding forms, e.g., W-4s Direct deposit forms Deductions authorizations Defined Benefit Pension Calculation Support April 24,

9 Payroll Records: Operational Retention Considerations Calculate Pension Benefit? Consider Personal Injury/Property Limitation of Action Periods? Consider Potential Liability Under Lilly Ledbetter Fair Pay Act? Consider Limitation Periods in the Dodd-Frank Wall Street Reform &Consumer Protection Act? Destroy Personally Identifiable When Eligible? April 24,

10 What You Need to Do: Today s Agenda Understand Tool s Retention Capabilities Consider Information s Value Collapse Retention by System Type & Information Value April 24,

11 Retention Schedules: What You Need to Do Step One - Exploit Retention Capabilities of Your Tools April 24,

12 Understand Capabilities of Your Tools Examples of Metadata Used for Triggers Date Closed Date Created Date Declared Date Last Accessed Date Last Modified Date Last Retrieved Major/Minor Version Status Status Workflow Trigger Examples of Aggregations Category Folder Record Document Sets Volume Examples of Actions Archive Destroy Export Transfer Inactive Review Wrapped in Workflow April 24,

13 Understand Capabilities of Your Tools One tool may have multiple methods to accomplish the same end result April 24,

14 SharePoint Example: Record Declaration Manual declaration of record via menu April 24,

15 SharePoint Example: Record Declaration Automatic Declaration of a Record When added to a list, or Set in an Information Management Policy for a document library April 24,

16 Understand Capabilities of Your Tools A tool s capabilities can vary widely between products providing the same primary function April 24,

17 Voice Mail Example: Disposition Options available to apply retention to voice mail will vary, depending upon the capabilities of the software in use Stand-alone voice mail server Stand-alone voice mail server, with capability to produce a "link" to an audio file, which can be saved outside the voice mail server Voice messages stored on the server (not a voice mail server) April 24,

18 Reduce Human Intervention A retention schedule with event based or conditional retention periods may still require some manual processing decisions, despite technology improvements to handle these types of retention periods April 24,

19 Consider Alternatives Before Using Conditional Retention Periods: Accounting Change Until Tax Audit or Exam to: XX Years = Typical Tax Settlement /Exam Cycle Use Records Holds for Exceptions April 24,

20 Create Date 10 Years Then Delete April 24,

21 Create Date 10 Years Then Delete Annual Aggregation or Cut Off April 24,

22 Create Date 2 Years Then Archive Annual Aggregation or Cut Off Archive Date 8 Years Then To Be Deleted To Be Deleted 30 Days Then Delete April 24,

23 Create Date 9 Months Then Delete Drafts Create Date 2 Years Then Archive Annual Aggregation or Cut Off Archive Date 8 Years Then To Be Deleted To Be Deleted 30 Days Then Delete April 24,

24 Date Last Modified 6 Months Then Delete Drafts Create Date 2 Years Then Archive Annual Aggregation or Cut Off Archive Date 8 Years Fixed Date 12/31/2015 Then To Be Deleted To Be Deleted 30 Days Then Delete April 24,

25 Consider Alternatives Before Using Conditional Retention Periods: Projects Separate Projects by Metadata, Libraries, Folders... Change Project Completion to: Last Action for Specific Project s Library or Folder April 24,

26 Case Files Characteristics of a Case File Accumulates records and information over time Information is put together either logically or physically Nearly always requires an event-based retention period We think in terms of folders holding Case Files But, what is a folder? Folder Library Metadata April 24,

27 Enter Event Data Manual or Automatically Fed by an Upstream System Event Date 2 Years Then Archive Archive Date 8 Years Then To Be Deleted To Be Deleted 30 Days Then Delete April 24,

28 Last Content Modify Date 2 Years Then Archive Archive Date 8 Years Then To Be Deleted To Be Deleted 30 Days Then Delete April 24,

29 Consider Alternatives Before Using Conditional Retention Periods: General Contracts Typical Active Contract Period? Change Expiration to: 15 Years (5 Year Active Period + 10 Years) April 24,

30 Eliminate the Event Date Expiration + 10 Years General contracts are often active no longer than 5 years Implement retention as 15 Years Create Date 5 Years Then Archive Archive Date 10 Years Then To Be Deleted To Be Deleted 30 Days Then Delete April 24,

31 Consider Alternatives Before Using Conditional Retention Periods: P&Ps Establish 3-Year P&P Review Process Change Until Updated to: 10 Years (3-Year Review + 7 Year Period) April 24,

32 Eliminate the Event Date Obsolescence + 7 Years Establish 3 year review cycle Implement retention as 10 Years Create Date 3 Years Then Kick-Off Review WF Create Date 3 Years + 6 Months Then Archive Archive Date 7 Years Then To Be Deleted To Be Deleted 30 Days Then Delete April 24,

33 Use Versions to Manage Event Obsolescence + 7 Years Establish 3 year review cycle Implement retention as 10 Years Date Last Modified 6 Months Then Auto Declare & Delete Drafts Date Declared 3 Years Then Kick-Off Review WF Date Declared 7 Years Then Delete Prior Versions April 24,

34 Retention Schedules: What You Need to Do Step 2: Focus on information value April 24,

35 Recordkeeping Nirvana: One System to Manage it All Content Related to Company Business Created or Retained Using Company Resources April 24,

36 But Not All Information is Equal Business Need Compliance & Governance Legal Litigation, Gov t Investigation, External Audit Internal Non-Regulated Information Work-in- Progress Official Business Record Core Support Internal Non-Regulated Info Drafts, Duplications, Transient Information & Non-Records Information that Matters Information that Clutters April 24,

37 Determine Value Official Business Record Core Support Internal Non-Regulated Info Drafts, Duplications, Transient Information & Non-Records April 24,

38 Realistic Objective (This may even be a long-term objective!) Focus Resources on Official Business Records & Core Support Official Business Record Core Support Information that Matters April 24,

39 Example: Collaborative Product Design Lab Notebooks Real-time collaborative product design Product Specifications Manufacturing Direction Sets Test Assays Information that Matters Product ideas Project timeline Information that Clutters Lab Results Wish list Project budget analysis Manufacturing Records Status reporting Public competitor information April 24,

40 Management of Official Records These are the golden nuggets Managed in a controlled environment Have approval process for changes Quality reviewed Retained for definitive retention periods Lab Notebooks Product Specifications Manufacturing Direction Sets Test Assays Lab Results Manufacturing Records Information that Matters April 24,

41 Use of Collaborative Product Design Collaborative Open dialog Open debate Regularly monitor to ensure that final information is moved to an appropriate repository Regularly & systematically delete Real-time collaborative product design Information that Clutters April 24,

42 Delete Information that Clutters Focus on Delete Internal Non-Regulated Info Drafts, Duplications, Transient Information & Non-Records Information that Clutters April 24,

43 Non-Regulated Internal Operating Information with Conditional Retention Examples Maximum of X Years after [Event] While Useful for Internal Operations Collaborate with users Accept imprecision of creation-date retention Creatively use existing metadata Date Last Viewed Status or user rating of information Set a maximum period, using a date field that is always populated April 24,

44 Focus Effort/Resources by Value Official Business Record Core Support Be Precise Be Careful Information that Matters Internal Non-Regulated Info Drafts, Duplications, Transient Information & Non-Records Focus on Delete Delete ASAP! Information that Clutters April 24,

45 Focus Disposition on Information that Clutters Focus Disposition on Information that Matters Retention Categories Storage Policy ECM/RM solutions Collaboration w/rm Database applications ECM/RM Solution Collaboration no RM File Shares File Shares Information that Matters File Shares Information that Clutters April 24,

46 Retention Schedules: What You Need to Do Step 3: Collapse Retention Periods for Information with Same Value April 24,

47 Option 1: Select the Longest Retention Period Brand Management & Outreach (5 Years) Product Marketing (10 Years) Collaboration Site 10 Years Corporate Granting (7 Years) April 24,

48 Option 2: Select a Few Retention Periods 3 Years (General) <1 Year (Transitory) 7 Years (Regulated) Archive 3 & 7 Years > 7 Years: Other Repository April 24,

49 Option 2: Select a Few Retention Periods Max+7 Years (Financial Planning) 7 Years (General Accounting) Disposition+7 Years (Assets, Investments, Obligations) 2 Years (Internal Controls) Enterprise Application 7 Years, Disp+7 Years & Permanent Permanent (GAAP Annual Statements) April 24,

50 Act Reasonably Minimize manual entry of metadata Automate through workflow, eliminating conditional retention periods when possible, etc. Replace Review & Approve with Notify Know that information of different values may be managed differently and in more than one system How good does good need to be? Minimize the number of retention periods for systems storing multiple records categories Accept risks in over-under retention for commingled information April 24,

51 Q & A April 24,

52 Retention & ESI Paths to Success Christine M. Burns April 24,