Event-based records use case: business rules for unknown event dates

This use case examines the process of investigating and identifying accurate trigger events for legacy records. It highlights both the challenges and benefits of developing and implementing a practical events-based records policy.

Description of organization:

An international financial institution headquartered in the US with over 270,000 employees operating in more than 30 countries. Services include consumer and commercial banking, insurance services, investment banking and wealth management.

Challenge:

Ensure the timely disposition of active hard copy records in off-site storage when the event date to calculate destruction eligibility was unknown or in the future. Original efforts focused primarily on providing training and tools (retention schedule, job aids, inventory tracking systems) for those who must ensure that retention event dates are applied to all records considered closed/inactive. Despite these efforts, approximately 1.6 million boxes remained in storage without event dates.

Solution:

The challenge was tackled by forming a task force consisting of the internal Records Management team plus selected members of the user community (to assist with user buy-in to the solution). Representatives from the Law and Audit departments were also active contributors. A detailed analysis of records with event date-based record class codes was completed to determine the volume of records with no designated event date. The various record classes were analyzed to establish a conservative, realistic active period for the various classes. For example, it was agreed that Trust records are considered active for 100 years; for bank account records, the active period is 50 years. When the analysis was completed, the recommendations were presented to the subject matter experts and Law Department and Audit Department representatives to gain their support for this project. The external storage vendor was consulted to determine the scope of assistance their team could provide.

Ultimately, business rules were established for standard “active” periods from the receipt date (the most reliably consistent basis) for all of the event date based record classes. Using these business rules, the vendor updated any blank event dates so a consistent destruction review date was calculated for each box based on the maximum active periods for each of the identified record classes. Using these “future” event dates, the vendor will then be able to calculate destruction eligibility dates, ensuring that all of the event date record classes are destroyed on schedule.

This project was not an “easy sell” to internal stakeholders (records coordinators, record owners and subject matter experts) and took over a year to complete. The analytics were presented to show the benefits to them and to the company, their feedback was welcome and incorporated into the process, costs were covered, and concessions made to certain groups, giving them additional time to add their own retention event date records before a global solution was applied. This ground work delayed completion of the project but enabled the stakeholders to be comfortable with the solution. One aspect worth noting is that this project was intended to be a “one time” project. However, the event dates will need to be revisited on a regular basis as record owners continue to transfer active records into storage. An exception reporting process will be set-up to facilitate this reporting. Additionally, businesses are encouraged to update any calculated event date with actual event dates as they are known.